The Conversation (0)
Indy100 Staff
Dec 07, 2021
Introduction
What personal information do we collect about you?
What do we use your personal information for?
Our legal basis for using your personal information
How can you access and update your personal information?
How long do we keep your personal information for?
Who do we share your personal information with?
Using children’s personal information
Will my information be sent overseas?
How we may contact you
Your data rights
Information for California residents
Contact details for exercising your rights, asking questions and raising concerns
Introduction
At The Independent we respect your privacy and are committed to protecting your personal information. This privacy policy is for visitors to our websites, apps and other digital platforms. It sets out how we collect, use, disclose, and protect personal data that we hold about you. It also gives information on how to exercise your legal rights. In this policy ‘we’ and ‘our’ means Independent Digital News and Media Limited.
When you provide us with your personal data you allow us to improve your experience of our products and services as well as helping to support our quality journalism. The majority of The Independent’s articles are free to read, so we rely on targeted advertising to fund our journalism.
Personal information is any information that can identify you and can include:
· Your name, email address, and year of birth, home address (if you’ve asked us to send something to your home address).
· Information about your device (your computer, mobile, tablet etc). For example your unique device ID, advertising ID, type of browser, and IP address. An IP address is a
numerical code which identifies your device. It can provide information about the country, region or city where you are based.
· How you browse our websites, such as the pages you visit and links you click on.
· Details of products or services you buy, for example a subscription to The Independent.
· Debit or credit card details if you buy a product or service (these are collected via a secure third party payment provider and are not held on our systems).
When we refer to “personal information” in this policy, we are referencing “personal data” as defined under UK and EU data protection law, as well as “personal information” as it is defined under California law.
What personal information do we collect about you?
We collect your personal information in one of the following ways, in line with the relevant data protection laws:
1. Information you give us e.g. when you register for an account, comment on an article, purchase a product or service or download one of our apps on your mobile device.
2. Information from your devices when you visit our website or app through the use of cookies and similar technologies e.g. device type and ID, advertising ID and IP address.
3. Information we generate about you e.g. we give you a unique ID to remember you when you’re logged in.
4. Information we receive about you from other organisations, including social media logins.
More information about this is set out below.
What do we use your personal information for?
1) Personal information you provide directly to us.
When you register for an account to read Premium articles.
If you want to receive a select number of Premium articles a week you will need to register for an account. We will ask for your first name, email address, password and year of birth. Readers under the age of 18 should not register for an account.
When you comment on our website
If you plan to comment on our website, you will need to register for an account and provide us with a commenting name. When you comment publicly on an article on our site, we would recommend you don’t share any sensitive personal information. We are not responsible for the information you choose to post online. Please see a link to our Community Guidelines on commenting here.
When you take out a subscription or attend an event
If you are subscribing to one of our paid-for products, in addition to your name, email address, password and year of birth, you will also need to provide your billing address and payment card information. Your payment details are not held on our systems. Instead they are handled by a secure, trusted third party provider.
We may also collect this information if you attend one of our paid-for ticketed events.
If you attend one of our virtual events, we will share your full name, prefix and email address with the platform hosting the event. We may share your company name but only if you choose to provide this.
When you contact Customer Services with a query
If you contact our Customer Services team by email, we receive your name, email address and details of your query. If you telephone us, we receive your telephone number and name. Please do not provide sensitive information unless you're happy for us to use it in response to your query.
When you sign a petition
When you click on a link to sign a petition relating to an Independent Campaign, you will be taken to a third party site. We are not responsible for the data you share with the third party, and we do not receive any of the information. Please check the third party’s privacy policy for more information on how they use your data.
You may be given the opportunity to opt in for further communications about the petition you have signed, other petitions you may be interested in or to receive emails from us related to updates or events at The Independent. We will only process your information in this way where you have given us your permission.
When you purchase products and services from third parties
We may also collect information about third party products and services which you purchase after visiting our website. For example, when you use a voucher code or click on a link to an affiliate site. However when you click on one of these affiliate links we don’t receive any personal data about you, and we cannot link back the purchases to you specifically. Instead we receive aggregated, anonymous information such as which products have been bought by our readers and how many of them.
2) Information from your devices
Cookies and other online identifiers
We collect data about our website’s visitors using technology such as cookies, device IDs, IP addresses and general location or country. This can include information about the type of device you are using, such as a laptop, computer, mobile phone or tablet, and your online browsing history. If you would like to know more about our use of cookies and how to manage them, please read our Cookie Policy.
When you use our website and enter your email address on our website (either to log in, or to sign up for a newsletter, or similar), we may share information that we collect from you with trusted partners. This may include your IP address, information about your browser or operating system or your email (only ever in secure ‘hashed’, pseudonymous form). Our partners use this information to create an online identification code to be able to recognise you on your devices. This code may be shared with advertising companies to enable interest-based and targeted advertising, that is more relevant to you. This code does not contain any of your directly identifiable personal data and will not be used to re-identify you. We and the below partners process your data to create this code as joint controllers under data protection law.
Detailed information on our partners’ data processing activities is available in their privacy policies by clicking below.
To opt-out of your data being used by LiveRamp in this way, please visit https://liveramp.com/opt_out/
To opt out of your data being used by The Trade Desk in this way, please visit https://www.transparentadvertising.eu/
Please see our Cookie Policy for more information.
We are signed up to the latest version of IAB Europe’s Transparency and Consent Framework (TCF) version 2.2 and comply with its specifications and policies. What this means is that we treat the personal information that we and our partners collect through cookies in a transparent and data privacy compliant way.
Market research, user testing panel and surveys
From time to time we may ask you to participate in reader surveys, to help us improve our website and offering. Usually these will be anonymous, however if you choose to be contacted for future market research, we will ask for your name and contact information so we can get in touch with you. We will keep your personal data for only as long as we need it, after which we will delete it.
We use a third party survey provider for running our surveys, and we keep your data in the third party platform for three months to enable us to analyse your responses, after which we aggregate your responses and delete your personal data so it can no longer identify you.
We may ask if you want to choose to sign up to be a part of our user testing panel, to help us improve and develop our offering. If you agree to be contacted as part of our user testing panel we ask you to provide your first name and the initial of your surname, as well as your email address.
We may ask you to attend face-to-face Zoom interviews with us or a partner that we have commissioned on our behalf. However, participation is voluntary and you are free to decline the invitations at any time. We may also send you links to short surveys and your responses to these surveys will be anonymous. If you agree to be a part of the panel, we will re-contact you after a year to ask if you wish to continue to be a part of the panel and give you a chance to opt out.
We may use the feedback you provide in our surveys or as part of our user testing panel, as quotes on our website, or in internal and external presentations in connection with the research study and our publications. However where we do this we will ensure that the quote is anonymous – unless you give us your permission to use your name, photograph or screenshots of you during any Zoom interviews.
3) Information we generate about you.
When you register for an Independent account, take out a subscription for The Independent or sign up for one of our newsletters, we assign you a unique ID number. We use your unique ID to recognise you when you are logged in. We also use it to ensure we remember your preferences such as which newsletter you have signed up to.
For readers who have not registered or subscribed, and are browsing our site anonymously, we assign you a unique ID number based on your device which remembers your browsing behaviour. This ID cannot identify you unless you then register or subscribe, after which we will link your anonymous browsing behaviour to your ID. This is so we can offer you a more personalised and engaging experience when you register or subscribe.
We also assign you a unique ID number which remembers your browsing behaviour. This includes how long you spend on an article, what types of articles you read (e.g. travel, politics, sports and so on) and how many, as well as how often you visit our website or app. This is so we can personalise the site and our communications to you and also deliver tailored advertising that is more relevant to your interests.
We provide each reader with a cookie ID for analytics purposes, so we can recognise when you come back on to our site using one of your devices such as your laptop or mobile phone. We do this so we know how many individuals come back to our site.
4) Data we receive about you from other organisations.
Sometimes we obtain additional information about you from data management and consumer insight providers, such as Eyeota.
The data these companies may hold about you is collected from publicly available records, such as the electoral roll, or from other sources where you have agreed for your information to be shared with third parties.
We may then match you with the data that they hold in their database to find out demographic or household information about you. This ensures that the advertising you see is relevant if you consent to this.
Social media
We can also access limited information from social media activity such as when you ‘like’ the website, share content or follow us on Twitter or Facebook. When you sign in to our website using Google, we collect your name and email address. If you sign up for one of our newsletters on Facebook, we receive your email address so we can send you the newsletter you’ve asked for. We may also receive demographic information from social media sites such as Facebook, including aggregated information on age and gender. However this cannot be linked back to you individually. This is used to tailor the advertising we show you if you’ve agreed to receive personalised advertising.
Our legal basis for using your personal information
We use personal data collected through our sites and apps only when we have a valid reason and the legal grounds to do so. The legal grounds may be one of the following:
Consent.
If you have given us consent to send you specific newsletters, you can unsubscribe from these at any time. You can do this by clicking ‘unsubscribe’ at the bottom of each email (and additionally at the top of emails if you use Yahoo or Gmail), or by logging into your account and managing your email preferences.
We only conduct market research and send you surveys if you have consented to this.
We will send you push notifications from our apps, and/or send you browser notifications when you are visiting our app or website, only where you have consented.
We will only use your personal data for advertising and marketing if we have your specific consent to do so. This includes informing you about our products, services or promotional offers that you might find interesting, as well as personalising our content and services.
We may tailor advertising you see on our website based on the type of articles you read, so it is more relevant to your interests. We do this by allocating your ID to relevant interest groups or segments based on your reading behaviour. For example, if you have read three
articles about travel or commented on a travel article in the last 30 days, or if you have visited a travel website prior to coming onto our website we may place your ID into the travel segment, and you will subsequently be shown more travel-related advertising. If your reading behaviour is similar to that shown for our travel audience, we may include your ID in our ‘lookalike’ travel segment for some campaigns.
We will never use any sensitive data (also known as special category data) for this purpose. Please read our Cookie Policy for more information about this.
We may personalise advertising to you based on the information that you provide us when you register for an account. For example, we may aggregate your age (based on year of birth that you provide us when you register) into groups e.g. 24-35 year olds, if an advertiser would like to target their ad campaigns to this demographic. As well as using your online browsing behaviour and your demographic information to personalise the advertising you receive, we may also use this aggregated information for reporting and analytics purposes. For example, to see how well a particular ad campaign has performed.
If you do not consent to personalised advertising via our consent management platform, you may still receive ads, but they may be less relevant to you.
We occasionally work with advertising partners to securely match the email addresses of our registered reader database with their customer databases, using our data matching service provider. This is so we can show ads to readers we and our partners have in common. All data is encrypted before it is matched, and neither party can directly identify an individual, nor see or access the other party's data. The data match service provider does not have access to any raw, unencrypted data.
Generally, this will be conducted at an aggregate audience level to provide insights, rather than individual level information, although your information may be used to generate these insights. These insights might include the overlap between our audiences and the client’s, and other information that would be useful to understand for an advertising campaign to be effective.
For readers in California, Colorado, Connecticut, Utah and Virginia, if you click the “Do not share/sell my personal information” button, which is in the website footer at the bottom of the home page, we will not recontact you about that choice for at least 12 months.
Legitimate interests.
Legitimate Interests are ways in which we use personal data that you would reasonably expect. These include:
· Sending you service messages about your subscription or account registration, for example if you have clicked a password reset link. This could be by email, overlay on the website or push notification (if you’ve consented to receiving app push or web browser notifications).
· Granting you access to a subscription.
· Dealing with any query or complaint you submit to our Customer Services team. Only provide sensitive data when relevant (such as information about your health, race or religion) if you are happy to consent to our using it to manage your enquiry.
· Dealing with, and responding to you about queries in the comment section and other user generated content facilities.
· Logging and using information about any service errors or interruptions that you have experienced in order to help us create fixes and to make technical improvements to our website.
· Security and fraud prevention.
· Verifying your identity and remembering you (for example when you return to the website and have already logged in).
· Enabling you to share our content with others using social media or email.
· Administering competitions and informing you if you have been successful in any competitions or promotions.
· Keeping you updated about our products and services, in line with your communication preferences.
· Monitoring the number of Premium articles you read as a registered user on The Independent website. This is so we can request users subscribe once they have read the maximum number of Premium articles over a given period of time.
· Monitoring the number of articles you read on The Independent app. This is so that we can request users subscribe once they have read the maximum number of articles on the app.
· Analysing what articles you have read so we can improve our content and make recommendations to you.
· Improving the design and style of the website.
· Responding to your feedback on our products, services and website and app functionality
· Ensuring that we are paid the correct amount of commission by our advertising partners if you buy a product or service from our website.
· Allowing us to measure advertising campaigns, ensure readers do not see the same advertisements too many times, and ensure advertisements are served in appropriate environments for our clients.
Performance of a contract.
When you buy a subscription or another product or service from us, we will need to use your details in order to provide the item to you. For example, in order to deliver a product to your home, you will need to give us your name and address.
Compliance with our legal obligations.
In some cases, we may have a legal or regulatory obligation to use or keep your personal data.
How can you access and update your personal information?
If you are a registered user or subscriber, you can update your personal information by signing in to your account page. In all other cases, please contact Customer Services.
You can also ask for a copy of the personal information we may hold about you, or for your data to be deleted via the above Customer Services form.
If you wish to contact us by telephone, our number is 0203 615 2990.
How long do we keep your personal information for?
We will keep your information only for as long as it is relevant and useful for the purpose for which it was originally collected.
If your account appears to have not been used for two years, we will try and contact you to check whether it is still in use and/or we will delete it. Please note that any comments associated with your account will also be deleted.
If you do not read the newsletters that you have subscribed to, we will suppress your name from the relevant list after six months.
If you purchase a subscription, we will retain your data for at least 12 months after your subscription ends in case there are any outstanding billing or other customer service issues.
A record of a customer service query is retained for at least three years from the date it was submitted to us.
We retain cookie data and corresponding third party data for 13 months from when it was collected from your device. For more information about cookies, please read our Cookie Policy.
We may need to retain your data for a longer period if there is a legal claim or if we are required to so by any regulation. We may also retain your personal information to ensure we do not contact you if you have asked us not to.
We are fully committed to keeping your personal information safe and we take measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction. However, as you will appreciate, no data transmission or storage system can be guaranteed as 100% secure.
Who do we share your personal information with?
Sharing with the Group’s companies
We may disclose your personal information to our sister companies: Independent Digital News and Media LLC and Evening Standard Limited.
Voucher code partner
We offer our readers voucher codes in collaboration with Savings United GmbH. We and Savings United are both responsible for any personal data you provide or that we collect while you visit www.independent.co.uk/vouchercodes. We must both comply with data protection laws. If you have any questions or concerns about how your data is being used in relation to Voucher Codes, in the first instance please email: contact@savings-united.com.
Advertising partners
Advertisers and advertising agencies sometimes require data to select and serve relevant advertisements to you based on your onsite behaviour e.g. whether you’ve clicked on an ad and are re-targeted with another ad from the same advertiser. We may also provide them with audience demographics about an audience who viewed or interacted with a campaign.
For more information on what personal data we collect and how we use it, please refer to the sections above ‘What personal information do we collect about you?’ and ‘What do we use your personal information for?’.
Government or regulatory bodies only if required by law
We reserve the right to disclose your personal information to comply with applicable laws and government or regulatory bodies' lawful requests for information.
Our service providers
Your personal details may be shared with third party organisations we have contracted to provide services to us which include processing data. For example, to send you the emails you have signed up for, to process your payment information when you buy a product or service, or for other purposes as described in this policy. Only companies who can provide
adequate safeguards will be used to ensure your data is stored and handled securely. And we have contracts in place with these providers to make sure that they only use information in ways we have instructed them to, and to protect your data and comply with applicable law.
Transfer as part of the sale of our business
We may transfer, sell or assign any of the information described in this Privacy Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.
Agencies and authorities because of a legal requirement
We may also have to release information because of a legal requirement on us or pursuant to a court order.
Using children’s personal information
We do not aim our services to children under the age of 13. We do not allow children under 18 to register an account with us.
Will my data be sent overseas?
As you will know, the internet does not recognise national boundaries. Services on the web are accessible globally so collection and transmission of personal data is not always confined to one country.
You should be aware that by using the website and those of our partners or any website we link through to, your personal data may be processed in or transferred to other countries, the USA for example, and you agree to your personal data being transferred or processed in this way.
Your personal data will only be stored or transferred within the UK, EEA, US or other countries using Standard Contractual Clauses, or other safeguards that have been approved by the relevant regulatory body.
If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the UK or the EEA.
How we may contact you
We will contact you in accordance with your preferences. From time to time we may contact you by email or browser or app push notification to give you service information. For example, if your subscription is changing, or your payment method has expired. You will not be able to opt-out from receiving these service messages unless you no longer wish to use the services.
If we have your permission we may also send you newsletters or emails about our events, subscription benefits or new launches and website developments.
You can manage your preferences and subscriptions to newsletters and emails by signing into to your Independent account. You can also unsubscribe at any time by clicking the link in the footer of the email (or also at the top of emails if you use Yahoo or Gmail). When you unsubscribe from marketing emails, we will add your email to a list to make sure we don’t send you any marketing information going forward. For more help on managing your account, visit our help centre.
Occasionally we may ask you if you would like to participate in market research or respond to you if you have made a complaint or have logged a query.
Your data rights:
Right of access – you can ask for a copy of the data that we hold about you.
Right of rectification – you can ask us to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – you can ask for us to restrict the way we use your data.
Right of portability – you can ask for us to transfer the data we hold about you to another company.
Right to object – you can object to us using your data where we are relying on a legitimate interest to use it.
Right to withdraw your consent – you can withdraw your consent at any time.
Please note that these rights are not absolute and certain may exemptions apply. For more information about these rights, please visit the ICO’s website at: https://ico.org.uk/for-the-public/.
We will respond to your requests within one calendar month as per our statutory obligations.
We may ask for proof of identity to be able to proceed with your request in order to meet our data protection obligations. We do not usually charge for making a request, but we may charge a fee in accordance with the relevant laws in certain circumstances.
Please note the Independent is a media organisation and publisher. This means we may be subject to certain exemptions under data protection law when we process personal data for the purposes of journalism. These exemptions apply to some of the ways the Independent uses personal data. This privacy policy does not cover personal data that the Independent processes for the purposes of journalism.
FOR CALIFORNIA RESIDENTS
Categories of personal information (PI) collected, along with examples of PI and the purpose of collecting PI are set out below:
Identifiers
Examples: e.g. name, contact information including email address, postal address, phone number, online identifiers, IP address.
You provide this directly to us when registering or taking out a subscription. We also obtain this from partners, service providers or public sources.
Purpose: To register or subscribe to the Independent, to manage your account; respond to your inquiries or requests and communicate with you; to send you email newsletters and push notifications if you choose to receive these; running our events; providing customer services; verifying customer information; administering competitions, customisation of ads to make the advertising on our sites more relevant.
Internet or other electronic network activity information
Examples: Browsing history, search history, geolocation data and information regarding your interaction with website, app, or advertisement – through use of cookies or similar technologies.
Purpose: Personalising our site and advertising to make it more relevant to you, marketing and promoting products and services, tailoring our communications to you, improving our understanding of readers to ensure the best content and services
Personal Characteristics
Examples: In some circumstances, we may collect PI that is considered protected under U.S. law, such as age and gender. We abide by the legal requirements imposed under applicable law in regard to such information. You either provide this to us or we infer it from information we hold about you.
Purpose: We use this to serve you advertising campaigns that are more tailored to you and for third parties to be able to measure the effectiveness of their ads. We also ask for year of birth information as we do not want children under the age of 18 to register for an account.
Commercial Information
Examples: Records of purchase history and transactions.
Purpose: Fulfilment of orders, answering customer service queries.
Professional or employment-related information
Examples: e.g. job title; industry; company – either directly from you if you choose to provide it or from publicly available sources or service providers or partners
Purpose: To enable us to work and communicate with our industry partners, recruitment.
Inferences from personal information collected
Examples: Inferences drawn from any of the personal information listed above to create a profile or summary about you, reflecting your preferences, characteristics, behaviours.
Purpose: Personalising advertising to make it more relevant to you, marketing and promoting products and services, tailoring our communications to you.
Categories of third parties we may disclose personal information to:
· Service providers who assist us in operating our business and delivering our services
· Advertising and marketing partners
· Legal authorities or regulators when required by law or to protect our legal rights
· We may disclose your personal information to our sister companies: Independent Digital News and Media LLC and Evening Standard Limited.
California Shine the Light Law
Subject to certain limitations, California residents may ask us to provide them with:
(1) A list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and
(2) The identity of those third parties. To make this request, California residents may contact us at Customer Services. For such requests, indicate “CA Shine the Light Request” in the subject field of your request.
Your rights under the California Consumer Privacy Act as amended (CCPA)
Right to know – you can ask (up to twice in a 12-month period) for the personal data we may hold about you for the past 12 months.
You can also request:
(1) The categories and/or specific pieces of personal information we have collected about you
(2) The categories of sources for that personal information
(3) The purposes for which we use that information
(4) The categories of third parties we disclose your information to, and
(5) The categories of information that we sell or disclose to third parties.
Right to delete – you can ask us to delete the personal data we collect about you (with some exceptions, such as if we are legally required to keep the information).
Right to opt-out of the sale or sharing – you have the right to opt-out of the sale or sharing of personal data we may hold about you. You can exercise this right at any time by pressing the “Do not Sell or Share My Information” link in the footer of every page on our site.
If you click the “Do not Sell or Share My Information” link, we will not recontact you about that choice for at least 12 months.
Right to correct your personal information – you can ask us to correct inaccurate personal data that we may hold about you.
Right to limit the use and disclosure of sensitive personal information collected about you – you can ask us to only use your sensitive personal information for purposes such as providing you with the services you have requested. We do not collect sensitive personal information unless you provide this to us.
Right to non-discrimination for exercising your rights – we will not discriminate against you for exercising any of your privacy rights.
We may ask for proof of identity for verification purposes, such as your name, e-mail, phone number and/or account information. We will review the information provided and may request additional information via e-mail or other means to ensure we are interacting with the correct person. To help us respond appropriately, please specify that you are making a request under the California Consumer Privacy Act or CCPA.
You may also use an authorized agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify your identity, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
We endeavour to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Please note that some of these rights are not absolute and exemptions may apply in certain circumstances.
Exercising your rights, asking questions and raising concerns:
If you have any queries or comments about this privacy policy, or you would like to make a request, please contact us using our online form available here: Customer Services.
If you’re unhappy with how we’ve handled your data or your request, please get in touch with us in the first instance using our online form: Customer Services. You may also get in touch with our Data Protection Officer. Their contact details are in the table below. If you’re still not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO) whose contact information is also provided in the table below.
Supervisory Authority contact details
Contact Name: Information Commissioner's Office
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Contact Info: 0303 123 1113; https://ico.org.uk/concerns/
Data Protection Officer (DPO)
Contact name: Nicola Mckilligan-Regan
Address: Alphabeta Building, 14-18 Finsbury Square, London, United Kingdom, EC2A 1AH
Contact info: dpo@standard.co.uk
If you are based in the EEA please contact our EU Representative:
EU Representative
Contact name: IDNML EU Representative
Address: IDNML EU REP c/o Kazient Privacy Experts, 77 Lower Camden Street, Dublin, Ireland, D02 XE80
Contact info: idnml.eurep@kazient.eu
Changes to this privacy policy
We may make changes to this policy at any time, and where necessary we will inform you of these changes via email. We will display the date the policy was last updated on this page.