Privacy & Cookies Policy (the 'Policy')
Last Updated: 18 November 2019
What this Policy is for:
This Policy explains how we protect and handle any information you provide to us. It also provides you with an overview of the rights you can exercise regarding what we do with your information.
By using our products and services, including browsing our websites, registering or logging in, we may use your information as outlined in this Policy.
Who we are:
MailMedia Inc. is the controller of your personal data for the purposes of data protection law.
1. What kinds of information do we collect:
Information you've provided to us:
We collect information about you when you provide it to us, including when you create an online account. This could be done directly or indirectly via your device.
Information from your device:
We collect information from and about the device you are using when you interact with our website, including links and adverts.
This may include:
Device Type: Information about your operating system, hardware, software, browser type in order to tailor the experience to your device (e.g. screen resolution).
Device Operations: Information about your operations and behaviours performed on your device to tailor the experience based on how you or similar users have interacted with our content.
Unique identifiers: device IDs and advertiser IDs in order to save your preferences against an identifier to refer to on subsequent pages.
Device Settings: Information from your device's setting such as access to your GPS location/Information related to the location of your device so that we know which version of the website to serve you;
Network/connections: Your IP address, so that we can recognise if you have visited us before and allow your device to communicate with our websites and apps.
Browser pop-up notifications
When you consent to receive pop-up browser notifications from one of our websites, we collect the following information: (i) the url of the page you were on when you were subscribed; (ii) your country code; (iii) your device type; (iv) your browser name and version; and (v) the topics of the article you have clicked on or interacted with.
2. Legal Bases for processing your data
Contract: We process some of your data as a necessary part of performing our contractual obligations to you.
Consent: Some processing activities will only be done where we have sought your prior consent. If we require your consent, we will provide you with full details of the information that we would like and the reason we need it. Once given, you have the right to withdraw your consent again at any point and we will be obliged to stop processing your data and delete it unless we can demonstrate that another legal basis applies.
Legitimate Interest: We process some of your data because it is in our Legitimate Interests to do so. Where this is the case, we have considered the impact using your information may have on you and limited our use to only what is strictly necessary. Where we are using this as our basis, we can provide you with an explanation of why the processing is in our interests and you are free to contest this decision if you wish.
Examples of our Legitimate Interest processing activities include:
- supporting a free press and individual and societal rights to receive information;
- developing, delivering and maintaining relevant and engaging products services and advertising; and
- understanding who our audiences are in order to better serve them.
3. How we may use your information
We use personal information for journalistic activities to support a free press and to support individual and societal rights to receive information.
Legal basis for these processing activities: Legitimate Interest
By using our website, we may process your information for the purpose of providing you with such products and services and managing our relationship with you, which shall include (without limitation):
- communicating with you in relation to your account or service, service updates or other non-marketing communications;
- delivering customer services and support;
- maintaining records of our communications with you if you get in contact with us;
Legal basis for these processing activities: Legitimate Interest
Communicating with you
In accordance with your preferences and data protection legislation, we may use your information to send you direct marketing communications. This may include communications by post, telephone, email or SMS about our products and services, events and special offers.
We may also send you periodic newsletters about your chosen services, inform you of promotional offers that you might find interesting, and inform you about the any changes to our products and services where we have permission to do so.
Legal basis for processing this data: Consent / Legitimate Interest
Personalisation / Identifying your interests
We may use your information to provide you with a greater personalised experience when you visit our site.
We provide personalisation by using data you submit to us through your search terms, clicks, cookies, IP addresses, web beacons and other technologies. By doing so, we can provide you with content that we believe is more relevant to your interests.
Legal basis for this processing activity: Consent / Legitimate Interest
When lots of people start searching for something, it provides us with useful information about particular trends at that time. We use that data to populate our “most searched for” ticker at the top of the screen.
Legal basis for this processing activity: Legitimate Interest
Sometimes we allow advertisers to show advertisements directly on our website and apps, which are tailored to you based upon information they have obtained, such as your browsing history on their own websites. Other times we will arrange for our customers to be shown advertisements on other websites or apps. These advertisements are tailored to you with information we have obtained from your browsing on our websites and apps via cookies.
When you are shown an advertisement, our advertising systems do not know who you are or your contact details (such as your name, email address or postal address).
Demographic information from your registration on our websites and apps (such as your age, gender and city) may also be used to segment me you and tailor the advertising we arrange to be shown. Your demographic information is not shared with advertisers.
Legal basis for this processing activity: Consent
Location based services and advertising
Where we provide services that utilise your device's location, such as local weather or news, your location will be determined either from a lookup of your IP address in a 'GeoIP' database which lists information provided by your ISP (usually your closest town or borough)
Sometimes we can collect the precise location directly from the device (such as through GPS or Wifi on mobile devices) but only where you have granted permission for us to access this location information via your device settings. We use such information to provide you with a more tailored, relevant experiences when using our websites/apps.
Where you have granted permission to access your device's location and consented to us to use your data for advertising purposes, this location information may be used to tailor the advertising you receive, including showing you certain advertisements when you are in the vicinity of a particular location.
Legal basis for this processing activity: Consent
Measurement and analytics
We may use certain information (such as the websites that you visit and advertisements you see or click on) to help us, advertisers and other promotional partners measure the effectiveness and distributions of their advertisements and promotions.
Legal basis for this processing activity: Legitimate Interests / Consent
Improving our services and products
We may use your information to monitor and improve our products, content and services. This may include (without limitation):
- developing the design and style of our products and services to make improvements
- carrying out statistical, technical and logistical analysis to inform our strategic development
- blocking disruptive use and ensuring the security of our products and services
If you have registered on our websites or apps, we may analyse the information we hold on you in aggregate with our other customers to improve our advertising systems.
Legal basis for this processing activity: Legitimate Interest
4. How we may share your information
Sharing with third-party partners
Service Providers: We may pass your information to our processors – companies that we use to provide services on our behalf, for example for delivery services and prize fulfilment companies. These processors can only use your information in accordance with our instructions and for no other purpose.
Promotions: Sometimes we bring you promotions in association with other companies. If you enter such promotions, the other company will use the information you submit and we provide to them as a data controller in line with their own privacy policies. We'll let you know the precise arrangement at the time you provide your personal information.
Advertisers: We may provide third party advertisers with reports containing aggregate statistical data about our customers' use of our websites and apps to determine the kinds of people viewing their ads and how they are performing. This aggregated information may include demographic data such as age range and/or geographic location of groups of our customers.
This aggregated data does not include contact details (such as names, addresses or email addresses) that can be used to personally identify you or contact you.
OBA Partners: Third parties collect and use information obtained during your browsing activities in order to deliver tailored advertisements to you. These parties listed in our Cookies Settings tool where we provide you with their details and the ability to opt out of their use. We have no control over the use of your information by these third parties once it has been collected from our sites.
Change of Control: We may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.
5. Details of transfers to third countries and safeguards
Your Personal Data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than in your country.
If you are located in the EEA, we will implement appropriate safeguards to protect your Personal Data as required if we transfer it outside the EEA.
6. How can you exercise your rights under the GDPR
If you are contacting us, or our joint controllers, to exercise any of your rights under the GDPR, you will have to provide valid proof of identification. We are required to respond to your request within 1 month.
- Access: If you wish to exercise your right to access a free copy of your data, you can contact us, or our joint controllers, at the contact details provided below at Section 12.
- Deletion: To ask us to delete your personal data, please contact us, or our joint controllers, at the contact details provided below at Section 12. However, there may be circumstances where we are legally entitled to retain it.
- Rectification: If you wish to update or rectify your data, you can do this directly by accessing your account settings.
- Revoke consent for direct marketing: If you wish to object to the processing of your data for direct marketing you can opt-out by updating your settings or clicking on the 'unsubscribe' link in any marketing email or newsletter you receive from us.
- Opt-out of online behavioural advertising: You are able to control whether we and our partners may use your information for online behavioural advertising related purposes when you visit our websites via our Consent Management Platform that appears when you first visit our sites, or by clicking on the Cookies Settings link in this Policy.
- Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalisation purposes you can adjusting your account settings or contact us directly.
- Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party please contact us, or our joint controllers, at the contact details provided below stating the nature of and reasons for such objection.
- Complain: You also have the right to lodge a complaint about us with our supervisory authority, the Information Commissioner's Office.
Browser pop-up notification opt-out
- Click the 3 dots at the top right
- Select settings > advanced > privacy and security > content settings > notifications.
- Here you'll see the websites allowed and those which are blocked. Just remove all the websites that are in the "allowed" category that you don't want notifications from.
- Choose Safari > Preferences, click Websites, then click Notifications. Find the website in the list, then select Deny.
- Click the menu button and select Options.
- Select the Privacy & Security panel and go down to the Permissions section.
- Click the Settings… button next to Notifications.
- Select the website.
- Click Remove Website.
- Click the three dots button in the top-right of the browser window.
- Click "Settings".
- Click "View advanced settings".
- Under "Notifications", click "Manage"
7. California Consumer Privacy Act ("CCPA")
This section of the Policy applies solely to visitors, users, and others who reside in the State of California and describes your CCPA rights and explains how you can exercise those rights.
Under the CCPA you have the right to:
be informed about the categories and the specific personal information that we may collect, and the purposes for collecting that personal information.
- This information is provided in this Policy;
request a copy of the personal information we have collected about you;
- upon receipt of a valid and verifiable request from you, we will disclose to you both the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting that personal information, the categories of third parties which whom we share that information;
- you have a right to receive the above-requested twice per year
- if we provide the information electronically, it will be in a in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance from us.
- request that we delete any personal information that we have collected from you unless retention of that information is permitted under applicable law
opt-out of the sale of your personal information
- You can opt-out of the sale of your personal information by opening our California Privacy Settings tool and clicking on the "Do Not Sell my Info" button. This will opt-you out of cookie placement and the collection of your data by online advertising service providers.
Exercising Access and Deletion Rights
- To make such a request, please send an email to firstname.lastname@example.org with "CCPA Request" in the subject line.
We and our advertising partners collect personal information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site or use our app. We, and our partners, use this information to tailor and deliver ads to you on our site or app, or to help tailor ads to you when you visit others' sites or use others' apps. To tailor ads that may be more relevant to you, we and/or our partners may share the information we collect with third parties.
If you do not wish for us or our partners to sell your personal information to third parties for advertising purposes, select the applicable control from the "Do Not Sell My Info" link provided. Note that although we will not sell your personal information after you click that button, we will continue to share some personal information with our partners (who will function as our service providers in such instance) to help us perform advertising-related functions such as, but not limited to, measuring the effectiveness of our ads, managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads and/or reducing ad fraud.
If you access this site or app from other devices or browsers, visit the link below from those devices or browsers to ensure your choice applies to the data collected when you use those devices or browsers. If you use different browsers, devices or platforms, you will need to opt out on each browser, device or platform.
Additionally, although clicking the "Do Not Sell My Info" link will opt you out of the sale of your personal information for advertising purposes, it will not opt you out of the use of previously collected and sold personal information (except for personal information sold within 90 days prior to your exercising your right to opt out) or all interest-based advertising.
If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info and http://optout.networkadvertising.org. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
8. Data retention and account deletion
We store your data for no longer than necessary in relation to the purpose under which such data was collected. This is determined on a case by case basis and depends on things such as the nature of the data provided, why it was collected, the legal basis we rely upon to process the data, and our relevant legal or operation retention requirements. For example, if you request to delete your account we still have to retain some data for fraud prevention purposes and financial auditing.
9. Children & young people
Our websites, apps and other products and services are not aimed at children.
We do not intentionally target, or otherwise process information from individuals who are under the age of 16.
We do not create interest segments specifically designed for the purpose of online behavioural advertising to children who are under the age of 16.
You must be at least 16 years of age to use this website.
When you use our websites and apps we may collect information using cookies or similar technologies.
What are cookies and how do they work?
Cookies are small files that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you. This allows websites to tailor what you see on the screen.
Do you use other technologies which are similar to cookies?
Yes, we use the following:
Web beacons: Our websites, apps and emails often contain small invisible images known as 'web beacons' or 'tracking pixels'. These
are used in a way similar to cookies to:
- understand when a particular part of a webpage, email or app is viewed,
- understand how successful an article or an email marketing campaign has been
- verify any clicks through to links or advertisements contained in emails
- Flash cookies: In certain situations we use Adobe Flash Player to deliver video clips. Local Shared Objects (Flash cookies) are used to provide functions such as remembering your settings and preferences.
- Tracking URLs: These are web links that allows us to measure when a link is clicked on. They help us measure the effectiveness of campaigns and advertising and the popularity of articles that are read.
- Device identifiers: We use device identifiers on mobile devices in the same way as cookies are used on web browsers. A device identifier is a unique number on your device which allow us to remember your device.
Cookies and other online tracking technologies are an important part of the internet. They make using websites much smoother and affect lots of the useful features of websites. There are many different uses for cookies, but for within our sites, they fall into the following groups:
(i) Cookies that are needed to provide the service you have asked for (Essential)
Some cookies are essential so you can move around our websites and use their features. Without the use of these cookies parts of our websites would not function.
(ii) Cookies that collect information about your choices and preferences (Functional / Preference)
These cookies collect information about your choices and preferences, and allow us to remember things like:
(iii) Cookies used to understand how people use our products and services (Analytics)
We use analytics cookies to gather information about what pages, links and sections of our apps are popular and which ones don't get used so much to help us keep our sites relevant and up to date. They are also useful to be able to identify trends of how people navigate our sites so we can identify improvements to make to the customer journey
We may combine information collected by analytics cookies with other information that you provide to us. For instance, if you have registered for an account with us, we may combine your contact details other information you provide us with the browsing history from your device collected by analytics cookies (including data collected from before you registered and when you are signed-out).
We may also use this combined information to improve our products and services. For instance, we may analyse this information in aggregate to improve our advertising systems.
(iv) Cookies used to show advertising that is relevant to you (Tracking and Advertising)
Some advertising, known as 'online behavioural advertising' is tailored to you and uses information collected by first party and third party cookies based your web browsing activity. Cookies are placed on your browser to remember the websites you have visited. Advertising based on what you have been looking at is then displayed to you when you visit websites who use the same advertising networks.
To help us deliver relevant advertising using cookies, we use Google products including Google Marketing Platform. You can find out more here.
We also use these cookies in order to:
- know how many advertisements we serve, how many times these are clicked or hovered over with a mouse cursor, how many advertisements we show to a given user and how many customer actions these generate.
- understand which customers reach a sale or other action page on an advertiser's site. This allows us to monitor how many sales or actions we achieve for an advertising client, and therefore, how effective our advertising is.
- protect our advertisers' brands, we often use a technology that scans the page to ascertain that it is safe from profane, sensitive & potentially brand-negative topics, before serving an ad there. This process is called 'ad verification'.
Do Not Track: Our websites do not respond to 'Do Not Track' (DNT) browser settings.
You can change your cookie settings on this website at any time via your Cookie Settings.
Please note that this consent tool is not supported on certain versions of Internet Explorer. Please change your browser in order to exercise your rights under the GDPR.
Cookies can also be controlled using the following instructions:
- Mobile Devices: When using a mobile device, you can opt-out of receiving online behavioural advertising by selecting 'Limit Ad Tracking' in the Settings of your Apple iPhone or iPad, or the 'Opt out of interest-based ads' in the Settings on your Android device. You may also be able to reset your unique identifier used for online behavioural advertising (referred to as an 'Advertising ID') in the Settings on your Apple or Android device.
- OBA Cookies: If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to Your Online Choices.
- Web-Beacons: You can usually prevent the operation of web-beacons by changing your web-browser cookie settings and your ad choices, or for those in emails, by switching off images in your email client or viewing emails using only the 'text' display (rather than 'HTML' display'). See the 'Help' section of your email client for instructions. Please see the All About Cookies website for further information about managing your options.
- Flash Cookies: You can manage the use of Flash technologies with the Flash management tools available at Adobe's website.
- You can also visit the trade body representing these advertising platforms where you can control your third-party online advertising preferences by going to the Network Advertising Initiative.
- Browsers: The links below take you to the help sections for each of the major browsers that will tell you how you can manage your cookies:
Please note that our website, apps and other products and services may not work correctly (or at all) if you change certain preferences. For example, you may not be able to purchase products via our websites. However, you may still be able to place an order via our telephone order line.
Where you use our apps, similar technologies to cookies are used for analytics. It is not presently possible to opt-out of these similar technologies. If you are not happy to be included in our analysis, please do not use our apps.
Please also note that after applying these settings, you will continue to receive advertising, however, it may not be tailored to your likely interests using information collected from cookies and similar technologies on your device.
11. Updates to this Policy
We reserve the right to make changes to this Policy. Where changes are made, we will post the revised Policy here with an updated effective date. Please check regularly for any changes to this Policy.
12. How to get in contact:
Alternatively, you can write to us at:
Mail Media Inc.
51 Astor Place, 9th Floor