Privacy Policy | Newsquest Media Group

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We publish more than 200 regional newspapers and magazines in print and online around the UK. We also operate a number of digital and specialist media businesses such as LOCALiQ, s1, Exchange & Mart, and Newsquest Specialist Media. Details of our brands can be found <a href="/news-brands">here</a>.</p><p>We respect your rights to privacy and we are committed to protecting your personal data in accordance with the law when you are dealing with us. This privacy notice tells you how we collect and look after your personal data and what your privacy rights are.This privacy notice is provided in a layered format so you can click through to the specific areas set out below.</p><ol><li><a href="#who-we-are">WHO WE ARE</a></li><li><a href="#the-data-we-collect-about-you">THE DATA WE COLLECT ABOUT YOU</a></li><li><a href="#how-your-personal-data-is-collected">HOW YOUR PERSONAL DATA IS COLLECTED</a></li><li><a href="#how-we-use-your-personal-data">HOW WE USE YOUR PERSONAL DATA</a></li><li><a href="#disclosures-of-your-personal-data">DISCLOSURES OF YOUR PERSONAL DATA</a></li><li><a href="#international-transfers">INTERNATIONAL TRANSFERS</a></li><li><a href="#data-security">DATA SECURITY</a></li><li><a href="#data-retention">DATA RETENTION</a></li><li><a href="#your-legal-rights">YOUR LEGAL RIGHTS</a></li><li><a href="#changes-to-this-privacy-policy">CHANGES TO THIS PRIVACY NOTICE</a></li></ol> </div> <li class="legal-item content medium"> <div class="up-position" id="who-we-are"></div> <b>Who We Are</b><br /> <p>Newsquest Media Group is made up of different legal entities:Newsquest Media Group Limited, Newsquest (Herald & Times) Limited, Newsquest (Clyde & Forth) Limited, Newsquest (Midlands South) Limited, Newsquest Specialist Media Limited, Newsquest Direct Limited, CN Group Limited and subsidiaries.</p><p>The identity of the relevant Newsquest Media Group company appears at the foot of each Group website and in each of our publications. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.</p><p>There may be other privacy policies that apply to certain services we provide. Please read these when you register or subscribe for these services.</p><p><strong>Contact details</strong></p><p>Please contact our privacy team for all queries, requests, or complaints, including those addressed to our Data Protection Officer (DPO) using the contact details below.</p><p>Privacy Team</p><p>Newsquest Media Group</p><p>Email address: <a href="mailto:privacy@newsquest.co.uk">privacy@newsquest.co.uk</a></p><p>Postal address: Newsquest Privacy Team, Unit 5, Kings Meadow, Osney Mead, Oxford. OX2 0DP</p><p>Newsquest have an Information Commissioner's Office (ICO) registered Data Protection Officer (DPO) who oversees the work of our privacy team. Our registration ID is Z8884774.</p><p>Details of our DPO can be found on the ICO website using the following link</p><p><a href="https://ico.org.uk/ESDWebPages/Entry/Z8884774">https://ico.org.uk/ESDWebPages/Entry/Z8884774</a></p><p>I<strong>f you have a complaint, we would appreciate the chance to deal with your concerns. So please contact us in the first instance. You always have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues</strong><a href="https://protect-eu.mimecast.com/s/90wwCwVNNcGv7jj0sqGt2l/">(www.ico.org.uk</a>).</p><p>For European Union (EU) and European Economic Area (EEA) citizens, including those permanently residing in the EEA or EU we also have a European registered Data Protection Officer.</p><p><strong>Changes to your data and preferences</strong></p><p>It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you have registered for an account with us for some our services, we provide a details page, where you can update your personal information at any time and change your marketing preferences.</p> </li> <li class="legal-item content medium"> <div class="up-position" id="the-data-we-collect-about-you"></div> <b>The Data we Collect About You</b><br /> <p> </p><p>Personal data means any information about an individual from which that person can be identified. We collect it because it helps us run our business and serve you better. Categories of personal data can be grouped together as follows:</p><ul><li><strong>Identity Data</strong> includes name, username or similar identifier, marital status, title, date of birth, gender, photograph.</li><li><strong>Contact Data</strong> includes billing address, delivery address, email address, telephone numbers and location details.</li><li><strong>Financial Data</strong> includes bank account and payment card details and credit references.</li><li><strong>Sensitive Data</strong> means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. It also includes information about allegations and convictions for criminal offences.</li><li><strong>Transaction Data</strong> includes details about payments to and from you and other details of products and services you have purchased from us.</li><li><strong>Technical Data</strong> includes internet protocol (IP) address, your login user-name (never your passwords), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.</li><li><strong>Profile Data</strong> includes your user-name, purchases or orders made by you, your interests, preferences, feedback and survey responses.</li><li><strong>Usage Data</strong> includes information about how you use our website, products and services.</li><li><strong>Marketing and Communications Data</strong> includes your preferences in receiving marketing from us and our third parties and your communication preferences.</li></ul><p>In this Privacy Notice we will refer some of these categories when explaining what personal data we collect and how we use it.</p><p>We also collect, use and share anonymous data such as statistical or demographic data. For example, we may aggregate your Usage Data to calculate the percentage of users reading a particular story, advertisement or other element of the website. However, if we combine or connect anonymous data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.</p><p>Unless they are properly the subject of editorial material in our news and magazine titles or you consent for a specific purpose, we do not collect any Sensitive Data about you. If you use S1 Jobs, you may be invited to upload your curriculum vitae for archiving with us and viewing by permitted organisations. You should avoid including Sensitive Data, but you can amend or delete at any time through your account.</p><p>We may need personal data to perform a contract for services you order from us (such as advertising) or to meet a legal obligation on us. If you do not provide it, we may have to cancel your order, but we’ll let you know at the time.</p><p><strong>Third-party links</strong></p><p>Our websites may include links to third-party websites, applications and plug-ins (such as ‘Facebook recommend’). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. These other organisations may use information about your visit to our websites. For more information on how these organisations use information, please read their privacy policies. We do not control these third-party websites and are not responsible for their privacy statements.</p><p><strong>Third-party Processors</strong></p><p>Our carefully selected partners and service providers may process personal information about you on our behalf as described below:</p><p>We have partnered with Arkadium to provide free online games that are monetised using advertising. Arkadium processes the data of players who choose to access our games platform only. The data includes the following:</p><p>• Login System - Email, name, game score and games recently played (if logged in).</p><p>• Platform Functionality - IP address, web requests, time and duration of visit, non-specific geographical location, cookies.</p><p>• FreshDesk - Player email, name, complaint, and device specifics (screen size, operational system, etc.)</p><p>• InMobi/Quantcast - Consent and preferences.</p><p>Arkadium does not collect any sensitive personal data.</p><p>Arkadium process personal information about you on our behalf to ensure proper game functionality, understand players’ preferences, provide website accessibility (ADA), to serve ads, to process and rectify complaints and support tickets, and to honour players’ data collection and processing preferences. More information about how Arkadium process your personal data can be found in their Privacy and Cookie Policy <a href="https://www.arkadium.com/gb/privacy-policy/">https://www.arkadium.com/gb/privacy-policy/</a></p><p> </p><p>If you apply for a job role with Newsquest Media Group Ltd including LOCALiQ, we use The Predictive Index to conduct Behavioural Assessments for our purpose of producing bespoke second stage interviews. </p><p>It is our legitimate interest as a business to invite candidates and employees to complete Predictive Index Behavioural Assessments. The data processed includes full name, email address and the answers to the Predictive Index Behavioural Assessment.</p><p>More information about how The Predictive Index process personal data can be found in their Privacy notice <a href="https://www.predictiveindex.com/privacy/privacy-respondent/">https://www.predictiveindex.com/privacy/privacy-respondent/</a></p><p> </p><p> </p><p>Digital Marketing Service Providers</p><p>We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:</p><p>(i) HubSpot, Inc. You can view the Privacy Policy & Data Processing Agreement here: <a href="https://legal.hubspot.com/dpa">https://legal.hubspot.com/dpa</a></p><p><strong>Children</strong></p><p>We do not as a rule directly offer children under 16 products or services or obtain information about them (except in newsgathering). Children may sometimes be invited to take part in prize competitions and promotions, in which case we will require parental or legal guardian consent.</p><p><strong>Data protection in newsgathering</strong></p><p>We gather information for the production of our news and other information services (“editorial information”). The editorial information is intended for publication and may incorporate extensive personal data about individuals, including Sensitive Personal Data. The free press serves a vital function in an open democratic society and the law recognises its importance by exempting the press from most of the data protection provisions where there is a proper journalistic purpose. We respect the rights of privacy of people who find themselves in the news and we seek to comply with the relevant data protection principles where we reasonably can.</p><p>News and features are published in print and online by each of our titles, and also distributed by social media such as Facebook and Twitter. They may be passed for publication by other titles within the Newsquest Media Group or syndicated to third party publishers in any medium in the UK or around the world. Our websites are focused locally in the UK, but of course they can be viewed from anywhere in the world. After first publication, in print or on the home page of our websites, we will keep copies in publicly accessible paper or searchable online archives. These archives are an important historical record. They are intended to be kept indefinitely. We will not delete, annotate or amend the archives unless the law so requires, or there is an inaccuracy or an important update.</p><p>We may also record and store unpublished information about individuals and matters of general interest for any length of time with a view to publication in the future, for example background research in developing stories or longer-term information held for the preparation of an obituary. We seek to review this information at least every seven years and discard it if we think it is no longer relevant or accurate.</p><p>On our websites and social media pages, we host facilities where people can post comments about news stories and other matters. These posts are uploaded automatically by the poster without our intervention and may contain personal data. It is the poster who consents to processing of this material and is primarily responsible for it, but we operate user terms and an acceptable use policy which we may enforce against users on receipt of a complaint. A ‘report this post’ link is provided and we will respond to complaints using that link.</p><p><strong>Data about other people</strong></p><p>By supplying us with information about someone else, you confirm that they have authorised you to provide us with their information (including Sensitive Personal Data) on their behalf.</p> </li> <li class="legal-item content medium"> <div class="up-position" id="how-your-personal-data-is-collected"></div> <b>How your Personal Data is Collected</b><br /> <p> </p><p>Separately from our news gathering activities, we collect data from and about you in order to run our business.</p><ul><li><strong>When you give us information:</strong> You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. And you will give us personal data when you:<ul><li>purchase from us advertising or other products or services;• use our website;• register and comment on our news stories• subscribe to any of our services or publications;• request marketing to be sent to you;• enter a competition, promotion or survey; or• take part in an event we have organised.</li><li>When you enter your email address on our website (either to log in, or to sign up to a newsletter, or similar) or when you use our app, we may share personal data or other information that we collect from you, such as your email (in hashed, pseudonymous form), mobile advertising identifier, IP address, or information about your browser or operating system, with our partner LiveRamp and its group companies, acting as joint controllers. LiveRamp uses this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your identifiable personal data and will not be used by LiveRamp to re-identify you. We place this code in our first party cookie or a LiveRamp cookie and allow it to be used for online and cross-channel advertising. It may be shared with our advertising partners and other third party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc). Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy and opt-out <a href="https://liveramp.uk/privacy/service-privacy-policy/">here</a>: You have the right to withdraw your consent or opt-out to the processing of your personal data at any time."</li></ul></li><li><strong>Behavioural information:</strong> As you interact with our website, we or third parties posting advertisements to our site may automatically collect Technical Data about your devices and Usage Data about your browsing patterns by using cookies and similar technologies. Those third parties may also receive Technical Data and Usage Data about you if you visit other websites employing their cookies and aggregate this data to build Profile Data about you and your interests and preferences in order to target advertisements tailored to your interests. We or they may obtain additional information from other third party sources (such as answers to surveys) to enhance Profile Data. The third party advertising networks posting ads to our sites include Google, AdEx, Rubicon and Criteo. By way of example, you can find Criteo’s privacy policy at: http://www.criteo.com/en/privacy-policy. Please bear in mind that none of the techniques we use will actually tell us who you are – we do not use these techniques to collect your name, email address, postal address or phone number.</li></ul><p>We have no direct control over them, but we will seek obligations in our contracts with third party advertisers that they do not use the personal data they gather for any purpose other than the uses we have authorised and told you about in this Privacy Policy and Cookie Policy. </p><p><strong>If you are concerned about the risk of unauthorised use of your personal data, you should refuse to give consent to cookies when asked.</strong></p><p><strong>Cookies: it’s your choice</strong></p><p>Using cookies means we can show more of the ads that are relevant to you and fewer that are not. Cookies control the number of times you see them and measure how effective the ad campaign has been. Effective advertising helps us to keep our websites and their news content free for you to use.</p><p>To help you make an informed decision, on a first visit to any of our sites you will be presented with a consent notification. If you choose the Accept option you are agreeing to accept cookies and similar technologies to help our site work, to help us understand how it is used and to personalise content and advertising.</p><p>Alternatively you may wish to choose Show Options to see a list of main types of cookies served together with more details on each cookie within that family. You can change the settings to block any or all of them. Once set, those choices can be subsequently modified by you at any time, most easily via the Manage Consent link at the foot of the site. Alternatively, you may wish to make changes via your browser. To help you do that we have published a how to list of the main browser types <a href="http://www.newsquest.co.uk/cookie-policy">here</a>.</p><p>Initially, you only need to engage once with the consent notification, irrespective of the choice(s) you make. However, because we have an obligation to record and understand what we can show to you, the consent notification will persistently appear until you make those choices clear and may re-appear in modified form for any user should we need to tell you about subsequent changes.</p><p>You can find out more about behavioural advertising and how to opt out of it selectively at youronlinechoices.com click on the AdChoices logo that you will see in the corner of advertisements that carry behavioural targeting cookies. If you want to opt out of receiving this targeted advertising, it does not mean that you will no longer receive advertising when you are using our websites; it just means that the advertising you see will not be customised for you.</p><p>You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. But if you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about cookie control the cookies we use and how to opt out at any time, please see our<a href="http://www.newsquest.co.uk/cookie-policy/">Cookie Policy</a>.</p><ul><li><strong>Marketing messages:</strong> When we send emails to you (see marketing in section 4 below), they will contain pixels. Our system uses them to collect Technical Data about the opening of the email and your clicking on any links. They also tell us if you go on to purchase products or services promoted in the email so that we can evaluate the success of the promotion. They are not used for targeting ads.</li><li><strong>Third parties or publicly available sources:</strong> We may receive personal data about you from various third parties and public sources as set out below:<ul><li>When you are online, we may gather Technical Data and Usage Data from cookies used by analytics providers such as Google. (You can opt-out of Google Analytics monitoring your behaviour on our web sites by going to: <a href="https://tools.google.com/dlpage/gaoptout/">https://tools.google.com/dlpage/gaoptout/</a>);</li><li>If you log in to our websites via Facebook or Google you are granting permission to share your Facebook or Google Contact and Identity Data with us, your networks and any other information you have chosen to share according to your Facebook or Google account settings; if you log in via Twitter, we receive your avatar (the small picture that appears next to your tweets) and Twitter username.</li><li>Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Barclaynet (their privacy policy is available at <a href="http://barclayscorporate.com/digitalchannels/privacy">barclayscorporate.com/digitalchannels/privacy</a>).</li><li>Financial Data, specifically credit reference information from consumer credit reporting agencies, such as Experian (<a href="http://experian.co.uk/consumer/privacy">experian.co.uk/consumer/privacy</a>).</li><li>Identity and Contact Data from data brokers or aggregators, such as as ZoomInfo Technologies, Inc (<a href="https://www.zoominfo.com/legal/privacy-policy">https://www.zoominfo.com/legal/privacy-policy</a>).</li><li>Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.</li><li>Identity, Contact and Profile Data from surveys and polls where you have consented to your information being used.</li></ul></li></ul> </li> <li class="legal-item content medium"> <div class="up-position" id="how-we-use-your-personal-data"></div> <b>How we use your Personal Data</b><br /> <p>We will only use your personal data when you agree that we can or else the law allows us to. Our newsgathering activities have been covered in section 1 above. The law further recognises that a business can properly use personal data to meet its legal obligations and perform contracts with its customers. We can also lawfully use your personal data if it is necessary for our legitimate business interests, provided the use does not interfere unduly with the rights of individuals. Where we rely on our legitimate interests to use your personal data, we will have weighed up any impact the use may have on you and limited our use only to what is necessary. We will explain why the processing is in our legitimate interests if you ask and you can object if you want to.</p><p>Some processing will only be done where we have sought your consent. We will tell you what information we would like to use and the reason why. You have the right to withdraw your consent and we will stop using your personal data and delete it unless we can demonstrate that another legal basis applies.</p><p><strong>Contracts and services</strong></p><p>Contract and/or legitimate interests are the legal bases we rely on for using personal data when we:</p><ul><li>Carry your advertisements or provide a subscription or news alert;</li><li>Register you as a customer for a service;</li><li>Provide a service to you, including processing a CV or your response to a job ad or property or vehicle listings;</li><li>Provide customer support, contact you about your account with us, send service updates or other non-marketing communications;</li><li>Contact a website user where a checkout journey is not completed;</li><li>Keep records of communications with you if you contact us;</li><li>Administer and publicise events, competitions, promotions and opinion polls;</li><li>Deal with editorial complaints;</li><li>Invite customer reviews or carry out market research;</li><li>Manage readers’ comments posted to message boards or other reader contributions;</li></ul><p><strong>Marketing</strong></p><p>Legal basis: your consent and/or our legitimate interests.</p><p>You may receive marketing communications from us by post, telephone, email or text if you have requested information from us, purchased products or services from us, purchased a third party product or service we have promoted (such as readers’ travel), or if you provided us with your details when you registered for an account, entered a competition or other promotion and, in each case, you have not opted out of receiving that marketing. These messages may be about any of our products, services or promotions (which may in some cases be provided by third parties). We may use your Identity, Contact, Technical, Usage and Profile Data from our interactions with you to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We will make sure it is clear when you can make these choices, for example, by giving you boxes to tick if you want to receive marketing.</p><p><strong>Third-party marketing</strong></p><p>We will not share your personal contact data with any person outside the Newsquest Media Group of companies for their own marketing purposes unless you have clearly agreed or it is lawful for us to do so. We will share the contact details of our local business customers with our partner ZoomInfo Technologies, Inc., the information services company, who use them to validate their contact details on our behalf.</p><p>We might offer you the opportunity to receive information from selected partner organisations that we work with. We will name those organisations and provide you with the opportunity to hear from them by means of an opt-in tick box.</p><p><strong>Opting out of marketing messages</strong></p><p><strong>You can ask us to stop sending you marketing messages at any time by following the link on the message or otherwise contacting us </strong><a href="mailto:privacy@newsquest.co.uk"><strong>here.</strong></a></p><p>Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of an agreement for a product or service from us.</p><p>You can opt out of all telephone marketing messages from all parties by contacting the Telephone Preference Service at <a href="http://www.tpsonline.org.uk/">www.tpsonline.org.uk </a> For unwanted post, contact <a href="http://www.newsquest.co.uk/privacy-policy/www.mpsonline.org.uk">www.mpsonline.org.uk</a></p><p><strong>Personalised advertising</strong></p><p>Legal basis: your consent</p><p>We need to sell advertising in order to fund our free-to-access news services. We may use your information to enhance our service to you by providing a more personalised experience. We collect the Technical Data and Usage Data that you give us through cookies and similar technology when you visit one of our websites. We use it to provide you with editorial content and advertising on our own websites that we believe is more relevant to your interests and preferences. This is called ‘online behavioural advertising’. We will also enable third party advertisers to show advertisements to you directly on our websites which are tailored to you according to information they have gathered independently, including information about your browsing history on their own or other websites. Using what is called ‘audience extension’, we may also enable advertisers to show you their advertisements on other websites. These advertisements are tailored to you using the information we have obtained from your browsing on our websites.</p><p><strong>Analytics</strong></p><p>Legal basis: our legitimate interests and/or your consent</p><p>This means Usage Data, for example the numbers of your visits to a website or advertisements you see or click on) to help advertisers measure the effectiveness of their advertisements and promotions.</p><p><strong>Monitoring and improving our services</strong></p><p>Legal basis: our legitimate interests</p><p>We may use personal data to monitor and improve our services, such as:</p><ul><li>Identifying, warning or barring disruptive website users (eg on our message boards) who breach our terms of use. This may involve disclosure of personal data to appropriate authorities, including the police or claimants considering legal action;</li><li>Statistical analysis to help us develop the content, design and delivery of our products and services.</li><li>Sharing your personal data with external auditors to verify aggregated statistics about circulation and usage of our websites.</li></ul><p><strong>Change of purpose</strong></p><p>We will use only personal information consistently with the purposes for which it was originally collected and we will tell you if we plan to use it for a different purpose. We will make sure we delete personal data securely when usage ends unless there is a reason for keeping it longer.</p> </li> <li class="legal-item content medium"> <div class="up-position" id="disclosures-of-your-personal-data"></div> <b>Disclosures of your Personal Data</b><br /> <p> </p><p>We may share details of our customers with agents or sub-contractors who help us deliver our services. This may include other Newsquest Media Group companies and by way of example the following third parties:</p><ul><li>ZoomInfo Technologies, Inc, to validate contact business details on our behalf;</li><li>Central Index, a trading name of <a href="https://protect-eu.mimecast.com/s/fj-VCMwqqIQl36oiwAFvp">Web.com supplier of online business directory</a></li><li>Deloitte, a provider of design, marketing communications and ad production solutions;</li><li>EKCS, a provider of design, marketing communications and ad production solutions;</li><li>ABC Auditing, performance measurement</li><li>Adestra and Advance, email marketing services</li><li>Amplify My Sales Ltd, a marketing adviser</li><li>IBM, IT support</li><li>MediaForce Group, an advertising sales agency</li><li>Naviga UK, IT support</li><li>Getty Images, a provider of artwork images</li><li>Adobe Stock – a provider of artwork images</li><li><a href="http://www.newsquest.co.uk/terms-conditions/marketing-services/">ReachLocal</a>, digital marketing services</li></ul><p>Any external sub-contractors who access your information in the course of providing services on our behalf will be governed by contractual restrictions to make sure that they protect your information.</p><p>We may make other organisations’ services available through our websites. If we process any personal information which we collect when you access a service provided by another organisation, we do so under this privacy policy. Information these other organisations collect is governed by their own privacy policies.</p><p>If you are attending an event organised by us or an event partner, data may be shared for event administration purposes and disclosed for event publicity (including photographs).</p><p>We may share with auditors and advertisers reports containing aggregated statistical data about the use of our websites. This aggregated data does not include any names or address details that could be used to identify you or contact you.</p><p>We also disclose personal data where required by law to HM Revenue & Customs, regulators and other authorities in the UK. If we acquire another business or sell the whole or part of our business, the new owner may use your data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.</p> </li> <li class="legal-item content medium"> <div class="up-position" id="international-transfers"></div> <b>International Transfers</b><br /> <p>If we transfer your personal data outside the European Economic Area, we ensure a similar degree of data privacy protection is afforded to it by applying one of the following safeguards where necessary:</p><ul><li>Specific contracts approved by the European Commission which give personal data the same protection it has in Europe (“EU model contracts”).</li><li>We may transfer data to the US if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.</li></ul><p>Although our parent company, Gannett Co, Inc. is based in the US, we do not transfer customer personal data to it. Some of the business data we transfer to 2AdPro at its base in in India may include personal data, and it is the subject of EU model contracts</p> </li> <li class="legal-item content medium"> <div class="up-position" id="data-security"></div> <b>Data Security</b><br /> <p>We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.</p> </li> <li class="legal-item content medium"> <div class="up-position" id="data-retention"></div> <b>Data Retention</b><br /> <p><strong>How long will you use my personal data for?</strong></p><p>We will only retain your personal data for as long as necessary in relation to the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Retention periods will be judged on a case by case basis. By law, for tax and other purposes, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers. And we may need to keep information to evidence a contract or prevent fraud. We will review our marketing contact lists and delete those contacts where there has been no activity for three years. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.</p> </li> <li class="legal-item content medium"> <div class="up-position" id="your-legal-rights"></div> <b>Your Legal Rights</b><br /> <p>Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:</p><p><strong>Request access</strong> to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.</p><p><strong>Request correction</strong> of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.</p><p><strong>Request erasure </strong>of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. In particular, see our editorial policy in section 2 above.</p><p><strong>Object to processing</strong> of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.</p><p><strong>Request restriction of processing </strong>of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.</p><p><strong>Request the transfer</strong> of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.</p><p><strong>Withdraw consent at any time</strong> where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.</p><p>If you wish to exercise any of the rights set out above, please contact us at privacy@newsquest.co.uk or by post to the Data Privacy Manager, Newsquest Media Group, Unit 5, Kings Meadow, Osney Mead, Oxford. OX2 0DP.</p><p><strong>No fee usually required</strong></p><p>You will not normally have to pay a fee, but we may charge a reasonable sum if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.</p><p><strong>What we may need from you</strong></p><p>As a security measure, we may need to request specific information from you to help us confirm your identity. We may also contact you to ask you for further information in relation to your request to speed up our response.</p><p><strong>Time limit to respond</strong></p><p>We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.</p> </li> <li class="legal-item content medium"> <div class="up-position" id="changes-to-this-privacy-notice"></div> <b>Changes to this Privacy Notice</b><br /> <p>We may choose to amend our privacy policy from time to time. We will post the changes here. Where the changes are significant, we may also decide to email all our registered users with the new details. Where required by law, we will seek your consent to make these changes.</p> </li> </ol> </div> <div class="grid wrapper"> <div class="content medium"> <p class="light"> <i>Version: toa_2024.11.12</i> </p> </div> </div> </div> </section> <section class="footer" id="legal"> <div class="grid wrapper"> <div class="col-12 sm-col-12 md-col-6"> <div class="col-12 md-col-9"> <img src="/assets/images/logos/_400xAUTO_fit_center-center_none/Light-Logo.png" class="footer-logo" alt="Newsquest Media Group logo"/> <p>We are a media company with a difference. 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