Introduction

This policy explains how we collect, use and disclose information about you. By using information about you, we can provide the product or service you have asked for. The use of information helps us understand what your needs and interests are, provide personalised content and match the most relevant adverts and services for you.

Changes to your data and preferences

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.

The data we collect about you

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.

Identity Data includes name, username or similar identifier, marital status, title, date of birth, gender and photograph.

Contact Data includes billing address, delivery address, email, address, telephone numbers and location details.

Financial Data includes bank account and payment card details and credit references.

Sensitive Data means details about your race or ethnicity, religious or philosophical beliefs, 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.

Technical Data includes internet protocol (IP) address, your login username (never your passwords), browser type and version, time zone setting and location, browser plug-ins types and versions, operating system and platform and other technology on the devices you use to access our websites.

Profile Data includes your username, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communication Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Unless they are properly the subject of editorial material in magazine titles or you consent for a specific purpose, we do not collect any sensitive data about you.

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 will let you know at the time.

Third-party links

Our websites may include links to third-party websites, applications and plug-ins. 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.

Children

We do not as a rule directly offer children under 18 products or services or obtain information about them. Children may sometimes be invited to take part in prize competitions and promotions, in which case we will require parental or legal guardian consent.

Social media

On our social media pages, we host facilities where people can post comments. These posts are uploaded automatically by the poster without our intervention and may contain personal data. It is the poster who is primarily responsible for this material. A ‘report this post’ link is provided and we will respond to complaints using that link.

How your data is collected

We may collect data from and about you in order to run our business.

When you give us information

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.

You will give us personal data when you:

• Purchase advertising from us or other products or services;
• Use our website;
• Comment on our social media channels;
• Subscribe to any of our services or publications;
• Request marketing to be sent to you;
• Enter a competition, promotion or survey;
• Apply for a vacant position with the company.

How we use your personal data

We will only use your personal data when the law allows us to. The law recognises that a business has legitimate interests in using personal data to deliver its services provided it does not interfere unduly with the rights of individuals. We have concluded after careful consideration that our legitimate interests cover most of our collection and use of personal data. Those legitimate interests are as follows:

• To enhance your experience by providing services customised to you personally;
• To monitor and improve our services;
• To consider your application for employment with us.

We may also need to gather data and contact you in order to perform any contract for advertising or other products and services we are about to enter into or have entered into with you. This includes registering you as a customer and managing our relationship with you. We may email you occasionally with information or questions about your registration, your subscription or postings or with system updates.

Sometimes we may need to use your personal data to fulfil a legal obligation, often for your and our benefit, such as fraud prevention. Generally, we do not rely on your consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you (see below).

Marketing

You may receive marketing communications from us by email/post if you have requested information from us or purchased products or services from us, 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.

Third-party marketing

We will not share your personal contact data with any person outside Kennedy Publishing and our subsidiary companies for their own marketing purposes unless you have clearly agreed.

Opting out

You can ask us to stop sending you marketing messages at any time by following the link on the message or by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase.

Change of purpose

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.

Disclosures of your personal data

We may share details of our customers with agents or sub-contractors who help us deliver our services.

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.

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.

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.

International Transfers

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:

• Specific contracts approved by the European Commission which give personal data the same protection it has in Europe (“EU model contracts”).
• 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.

Data security

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. 

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. Full details of this can be found in the company data retention policy which is available upon request to the Company Data Protection Officer.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access 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.

Request correction 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.

Request erasure 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.

Object to processing 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.

Request restriction of processing 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.

Request the transfer 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.

Withdraw consent at any time 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.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Data Protection Officer
Kennedy Publishing Ltd, Unit 15, Greenway Farm, Bath Road, Wick, Bristol, BS30 5RL
E-mail: dataprotection@kennedypublishing.co.uk

If you have a complaint, we would appreciate the chance to deal with your concerns so please contact us in the first instance. You have the right to make a complaint at any time to the Information Commissioners Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk)

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

 Changes to this privacy notice

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.