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DMGK Limited

Privacy & Cookies Policy (the “Policy”)

Last Updated: 7 April 2021

You can control cookies on this website via your Cookie Settings. Further details on this can be found under Cookies and other identifiers in Section 14 below. 

1. What is this Policy for?

This Policy explains how we protect and handle any personal information you provide to us, including via our websites, our apps, our social media pages/accounts, email, telephone and in person. It also covers any personal information we receive from third parties and provides you with an overview of your rights. 

By using our products and services, including browsing our websites, registering, logging in or signing up for marketing, you agree that we may use your personal information as outlined in this Policy. There may be occasions when we share responsibility for the processing and protection of your personal data in connection with your use of our products and services as joint controllers with our partners (please see Section 2 Who we are for additional information). In such instances our partners will process your personal data in accordance with their privacy notices.

2. Who we are

DMGK Ltd. is the controller of your personal data for the purposes of data protection law.

DMGK Ltd. will share your personal data with Associated Newspapers Ltd., the processor of your personal data for the purposes of data protection law.

DMGK Ltd. and Associated Newspapers Ltd. share the infrastructure, systems and technology, and work together to understand how users interact with the products and services as well as share insights to improve them.

3. What kinds of information do we collect

We collect the following information:

Information you have provided to us: 

We collect information such as your name, telephone number, address, email address when you create and log into an online account, subscribe to one of our titles, sign up for our marketing communications, , order or register your interest in one of our products, in addition to, where you or your organisation provide us with products or services, the name of your organisation and bank and account details and information relating to a particular transaction.

This information may be collected via your computer browser, an online web form, a data capture form, an app, by email, by telephone, or by post. 

Piano Software Inc. (Piano) provides us with identity, entitlements, and subscriptions management, audience conversion and personalisation services. Piano collects your name, email, password, and newsletter preferences on our behalf. Piano will handle your personal data in accordance with its Privacy Policy and GDPR policy.

This information may be collected via your computer browser, an online web form, a data capture form, an app, by email, by telephone, or by post.

When you visit our website or app, we shall create a unique identifier (“UID”) that allows us to recognise you when you use our website or apps, including if you log in from a different device or platform..

Information from your device:

We collect information from and about the device you are using when you interact with one of our websites, apps or other products/services, including 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 in order to save your preferences against an identifier to refer to on subsequent pages and to display advertising.

Device Settings: Information from your device’s setting (such as access to your GPS location or other 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, allow your device to communicate with our websites and apps, and determine your geographical location.

Cookies: Data from cookies or similar technologies placed on your device which tells us about your use of our websites and/or selected third party websites. Some cookies are also placed by third parties. Please see Section 14 on Cookies and other identifiers below for more information about our use of cookies and other similar technologies.

If you purchase anything or make any other financial transactions on any of our properties, we collect information about your purchase and ask for information, including your name, email address and delivery address. This does not include payment information, such as your credit/debit card number.

Where you have registered or created an account with one of our websites, we may obtain information about you from other companies who have obtained your permission (through their own privacy policies) to share information about you.

If you log-in to our websites through a social media site, such as Facebook, Twitter or Google, you are granting permission to such company to share your user information with us. This will include your name and email address plus any other information you have permitted them to share with third parties. If you remove our website from your Facebook, Twitter or Google account, we shall no longer have access to this information.

We use plugins from social media networks and other platforms on our websites, that may allow you to share content with these networks/platforms or use their services on our websites. For more information, please see Section 7 of this Policy.

When you consent to receiving pop-up browser notifications from one of our websites, we collect the following information:

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.

Before you use “email a friend” or “share this article” buttons please make sure that anyone you wish to email or share with is happy for this to occur and expect to receive the email or article. You may only share the details of another person with us where you have their express permission.

4. Legal bases for processing your data under UK GDPR and EU GDPR

We rely on the following legal bases to process your personal data under the UK General Data Protection Regulation (“UK GDPR”) and the EU General Data Protection Regulation (“EU GDPR”).

Contract: We process some of your data as a necessary part of performing our contractual obligations to you. For example, to provide you with access to your digital subscription.

Consent: Some processing activities will only be done where we have sought your prior consent. If we require your consent, we shall 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 shall be obliged to stop processing your data and delete it unless we can demonstrate that another legal basis applies. 

Legal Obligation: There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. 

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 that 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 interests processing activities include:

5. 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 websites, apps and other products and services, we may process your information, including your name, phone number and email address, for the purpose of providing you with such products and services and managing our relationship with you, which shall include (without limitation):

Legal basis for these processing activities: Consent, Legitimate Interest, Contract

We may also record phone calls or customer enquiries via online chat for quality, training and management purposes.

Legal basis for this processing activity: Legitimate Interest/Contract

In accordance with your preferences and data protection legislation, we may use your information, including your name, email address, and phone number, to send you direct marketing communications and to carry out marketing analysis.

This may include communications by email, post, telephone, SMS or app notifications about our products and services, events and special offers. This also includes browser push notifications where you have consented to receiving these. We may also send you periodic newsletters to inform you about the any changes to our products and services where we have permission to do so.

In relation to email marketing communications, we may send you such communications when we have your consent, or when you are an existing customer who has previously bought or subscribed to a similar product or service from us. You may opt out of email marketing communications when your personal information is first collected. You may also unsubscribe from receiving email marketing at any time by clicking the “unsubscribe” link at the bottom of each email. If you unsubscribe from email marketing, we shall keep your email address to ensure that we do not send you any marketing in future.

Legal basis for processing this data: Consent/Legitimate Interest

We use your information, including your UID, to provide you with a greater personalised experience when you visit or use one of our sites or apps, and for insight and marketing purposes.

We make assumptions and draw inferences about your interests based on the kind of articles and content you click on or read.

We may also use demographic information (such as your age, gender and city) to tailor the advertising we arrange to be shown.

We use this information to segment our audiences into groups with attributes. This helps us show you more relevant content/adverts and helps are advertisers target more effectively.

Our partner, Piano, assists us in understanding user journeys on our website/app (e.g. which pages our users are visiting the most, which pages lead to the greatest audience conversion, session length, etc.), testing the effectiveness of our marketing campaigns, and optimising our website/app based on audience data. Please see Piano’s Privacy Policy and GDPR policy.

Please note you have the right to object to profiling for marketing purposes at any time. If you wish to opt-out of having your personal information profiled for personalisation purposes, you can adjust your account settings or contact us directly. Please see Section 8 (Your rights under the General Data Protection Regulation) for additional information.

Legal basis for this processing activity: Consent/Legitimate Interest

We may use your information to monitor and improve our products, content and services. This may include (without limitation):

Where you have given consent, we check to see if you have a cookie ID or UID when you visit one of our properties. We are then able to compare the cookie ID or UID we have to see if we know who you are. See Section 14 on Cookies for more information.

Legal basis for this processing activity: Consent

We allow partners to reach audiences on our platforms via data matching where they have appropriate permissions. We use your UID to carry out such data matching. This is conducted at an aggregate level or an individual level, depending on how targeted our partners want to reach audiences on our platforms. The data overlap between our audiences and the client is useful to understand if an advertising campaign would be effective.

As part of the matching process, we segment audiences based on predefined attributes. These audiences may be similar to our partners’ existing audiences and are therefore called “lookalike audiences”. For example, a female fashion brand may want to reach “women interested in fashion”. This helps them find the right audiences and we are able to show you more relevant 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 Wi-Fi 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.

Legal basis for this processing activity: Consent

We may use certain information (such as the websites that you visit and advertisements you see or click on and emails you interact with) to help us, advertisers and other promotional partners measure the effectiveness and distributions of their advertisements and promotions as well as the effectiveness of our own services and communications.

Legal basis for this processing activity: Legitimate Interests/Consent

We may use your information to monitor and improve our products, content and services. This may include (without limitation):

Legal basis for this processing activity: Legitimate Interest

Your data will be disclosed where we are obliged to do so by law. We may also disclose your information in order to protect or enforce our rights or the rights of others and for the prevention and detection of crime.

Legal basis for these processing activities: Legitimate Interest / Legal obligation

We may share your personal data with the Audit Bureau of Circulations Ltd so they can verify aggregated statistics about circulation and usage of our products or review our policies, processes and procedures for compliance with relevant standards. You can view their privacy policy by following this link.

Legal basis for processing this data: Legitimate Interest 

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our products and services to others. 

Legal basis for processing this data: Legitimate Interest/Contract

6. If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the services you have requested from us. In this case, we may have to cancel the provision of the relevant services to you, in which case we will notify you.

7. How we may share your information

Sharing with third-party partners

Partners: We may partner with other companies to provide certain customer services. We usually remain the data controller of your information and the other companies only process data under our instructions and cannot use the information for their own purposes. If one of our third-party partners acts as data controller of your personal data (whether or not as a data controller in common with us), we shall let you know before you register for the service.

Legal basis for processing this data: Contract

Service Providers: We may pass your information to our processors – companies that we use to provide services on our behalf. These processors can only use your information in accordance with our instructions and for no other purpose.

Legal basis for processing this data: Contract, Consent, Legitimate Interest

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 shall let you know the precise arrangement at the time you provide your personal information.

Legal basis for processing this data: Consent, Legitimate Interest

Cobranded products / affiliate marketing: We may partner with industry affiliates to bring you special deals on products and packages you may find of interest. These providers may collect marketing permissions for us and share data back with us about your purchases in order for us to measure the effectiveness of our marketing campaigns.

If you decide to use their services, these affiliates will be data controllers of the information you have provided them in order to administer your relationship with them and will handle your information in accordance with their own privacy policies.

Legal basis for processing this data: Legitimate Interest

Functionality: We may share information about you with suppliers that we engage to help us provide our services and/or functionality of our websites and apps. For example, we share data with Google to prevent certain website functions from being abused. Where this happens, your data will be processed in accordance with Google’s Privacy Policy.

Legal basis for processing this data: Consent, Contract, Legitimate Interests

Social media plugins: Some of our websites use social media plugins to help you share content more easily with your friends.

Social Media PluginPrivacy policy
Facebook Share Button Facebook Messenger Share Button Facebook Like Button https://www.facebook.com/policy.php
Twitter Share ButtonTwitter Follow Button https://twitter.com/en/privacy 
Pinterest Share ButtonPinterest Follow Button https://policy.pinterest.com/en-gb/privacy-policy 
Flipboard Share ButtonFlipboard Follow Button https://about.flipboard.com/privacy/ 
Instagram Follow Button https://help.instagram.com/519522125107875 
Snapchat Follow Button https://www.snap.com/en-GB/privacy/privacy-policy 

If you do not click on the respective buttons, no personal data will be collected and stored by the social media company.

If you are logged onto to your Facebook, Twitter, Pinterest, Flipboard, Instagram or Snapchat account, certain user data (including your IP address at the time) may be collected and linked to your social media account information by the respective social media company.

We receive no personal data from the social media companies about which articles you have clicked or seen on our websites. However, we do receive summarised, aggregated statistical reports on the use of these plugins.

Legal basis for processing this data: Legitimate Interest

DMGT group: Associated Newspapers Ltd. is part of the Daily Mail and General Trust plc Group (“DMGT”). Members of DMGT may, use and share, within that group, the information you provide and other information held about you for the purposes set out in this Policy. For more information about the DMGT group please see the DMGT website and the DMGT Privacy Policy.

Legal basis for processing this data: Legitimate Interest

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.

Legal basis for processing this data: Legitimate Interest  

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.

  Legal basis for processing this data: Legitimate Interest 

8.  Details of transfers to third countries and safeguards

Any organisation who has access to your information in the course of providing services on our behalf will be governed by contractual restrictions and/or technical limitations to make sure they protect your information and comply with applicable data protection legislation. 

When transferring your personal data outside the United Kingdom (UK) or the European Economic Area (EEA), we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. Where these organisations are based outside of the UK or the EEA in a jurisdiction that has not been deemed adequate by the EU Commission, we shall, if appropriate, enter into EU Commission approved model clauses with these organisations to ensure appropriate safeguards are in place. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

9. Your rights under the UK GDPR and the EU GDPR 

In certain circumstances, for example if you are a UK or EEA resident, you may exercise the rights available to you (with some exceptions and restrictions) under the UK or the EU data protection laws as follows:

Exercising Your Rights

To exercise your rights under the GDPR, please contact us, or our joint controllers, at the contact details provided below in Section 16, indicating the type of right you would like to exercise and that you are making the request under the GDPR. In case of requests for deletion, please note there may be circumstances where we are legally entitled to retain certain data (see Section 12 Data retention and account deletion).

Alternatively, you can make your request through the technical support option on our Contact Us page.

We may seek to verify the identity of the person submitting the request.

Where you are making a request via a third party, we need to be satisfied that the third party making the request is entitled to act on your behalf and may ask the third party to provide evidence of this entitlement. If we are satisfied that the third party has the appropriate authority, we will respond directly to that third party.

10. Your rights under the CCPA (for California residents only)

This section of the Policy applies solely to visitors, users, and others who are residents of the State of California, describes your California Consumer Privacy Act (“CCPA”) rights and explains how you can exercise those rights.

Under the CCPA you have the right to:

This information is provided in this Policy.

Upon receipt of a valid and verifiable request from you, we shall 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 twice per year. If we provide the information electronically, it will be in a in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance from us.

Exercising Your Rights

To exercise your rights under the CCPA, please contact us, or our joint controllers, at the contact details provided below in Section 16, indicating the type of right you would like to exercise and that you are making the request under the CCPA. In case of requests for deletion, please note there may be circumstances where we are legally entitled to retain certain data (see Section 12 Data retention and account deletion).

Alternatively, you can make your request through the technical support option on our Contact Us page.

In order to process your deletion and/or access request, we are required by law to collect certain information about you to verify your identity. For example, if you have an account with us, you can use your account information to verify. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used for the purposes of verifying your identity under the CCPA, and for security or fraud-prevention purposes.

A consumer may use an authorised agent to submit a request on their behalf if the consumer provides the authorised agent written permission signed by the consumer. We may also require that the consumer verify their identity directly with us and confirm that they have provided the authorised agent permission to act on their behalf.

We shall not discriminate against you because you have exercised your rights under the CCPA. 

11. Your rights under the LGPD

This section describes your rights under the Brazil general data protection law (“LGPD”) and explains how you can exercise those rights. 

This section of the Policy applies to: 

In certain circumstances, for example if you are a Brazil resident, you may exercise the rights available to you (with some exceptions and restrictions) under the LGPD. Please see Section 9 above for details of the rights of information, access, portability, deletion, correction, revoke consent for direct marketing and opt-out of online behavioural advertising. Also, see Section 9 above for details of how to exercise your rights. Please include in your request that you are making your request under the LGPD.

12. 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.

Please see our Terms for more information.

13. Children and 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.

If you are a parent or guardian of a child under 16, please contact us, or our joint controllers, if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. We shall delete or otherwise cease processing your child’s personal information within a reasonable time.

In accordance with industry best practice guidelines, we may retain your information for a reasonable amount of time to make sure that we do not contact you in the future.

14. Cookies and other identifiers

When you use our websites and apps or interact with our emails, we may collect information using cookies or similar technologies. We may also collect information using your email address. For the purposes of this section, we use the word “cookies” for simplicity.

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:

We use these similar technologies on websites, emails and apps, for the same purposes and in much the same way as we use cookies on websites. We shall use “cookies” and “websites” below as shorthand for “cookies and similar technologies” on “websites, emails and in apps”.

What do you use cookies for?

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 site, they fall into the following groups:

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. For example:

These cookies collect information about your choices and preferences, and allow us to remember things like:

We use analytics cookies to gather information about what pages, links and sections of our apps are popular and which ones do not get used so much to help us keep our site 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. 

Our properties may also feature Nielsen proprietary measurement software, which will allow you to contribute to market research, such as Nielsen TV Ratings. To learn more about the information that Nielsen software may collect and your choices with regard to it, please see the Nielsen Digital Measurement Privacy Policy

Do Not Track: Our websites do not respond to “Do Not Track” browser settings.

Managing Cookies: 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 UK GDPR or the EU GDPR.

Cookies can also be controlled using the following instructions:

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 website. 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.

15. Updates to this Policy

We reserve the right to make changes to this Policy. Where changes are made, we shall post the revised Policy here with an updated effective date. Please check regularly for any changes to this Policy.

16. How to contact us

If you have any queries or comments about this Policy or wish to exercise any of your rights under the UK GDPR, the EU GDPR or the CCPA, please contact us by email at: 

Contactus@DMGKltd.co.uk

Alternatively, you can write to us at:

Legal Department – Data Protection & Privacy
DMGK Limited
Northcliffe House
2 Derry Street
London, W8 5TT 
U.K.

Alternatively, you can also write to us at:

Associated Newspapers (Ireland) Limited
3rd Floor, Embassy House
Herbert Park Lane
Ballsbridge
Dublin 4
Republic of Ireland
D04 H6Y0