WITH YOUR CONSENT
There may be some uses of your information where we need to ask for your consent. You will have the right to withdraw that consent at any time, however, if you withdraw consent, we may not be able to provide the product or service you have requested. We will rely on your consent to:
Deliver Direct Marketing Communications: where required, we will ask your permission if we want to deliver direct marketing to you. If you have an account connected to one of our products, you may be able to change your marketing preferences in a preference centre linked to that account. You will also be able to opt out in the communication itself.
We may send you direct marketing communications via post, telephone, email, SMS, social media, online, in-app and devices connected to the internet, like smart TVs, if we hold a valid direct marketing permission for you where required.
Place cookies and similar technologies: in accordance with the information provided in the “Cookies & Similar Technologies” section and the information provided to you when those technologies are used.
FULFILLING A CONTRACT
We process your personal information to fulfil a contract we have with you. We rely on this legal basis to:
Provide products and services you have asked for and manage our relationship with you: This may include managing requests, payments, access to products and services, allowing you to interact, comment, and participate in online games, contests, live and recorded events and reward programmes. This may also include sending you information and updates relating to the products and services we provide to you.
Take payments, check your identity and conduct credit checks: Information that we hold about you and that you provide to us may be used to take payment for products and services. It may also be used to verify credit details related to payments. Payment details may be retained in order to speed up the renewal process for products and services.
If you apply for credit, then in order to help us make credit decisions about you we may check with credit reference agencies who will record any credit searches on your credit file. We may also disclose details of how you conduct your account with us to these credit reference agencies for related purposes.
FOR A LEGITIMATE INTEREST
We may use your information where there is a legitimate reason to do so, such as where it would help achieve our business objectives or to facilitate a benefit to you or someone else.
Our legitimate interests in processing personal data include:
- to support a free press, including journalistic activities of societal importance;
- to support individual and societal rights to receive information;
- to develop, deliver and maintain relevant and engaging products services and advertising;
- understanding when our audiences engage with us or other organisations;
- to build a clearer understanding of who our audiences are in order to better serve them;
- to carry on the business of a commercial organisation; and
- to demonstrate that we provide services and products to agreed industry standards.
We rely on these legitimate interests to:
Monitor, improve and protect our products, content, services and websites, online and offline: This includes using information about your app download to validate free trials.
Manage complaints: including requests and concerns that you may have about products or services we provide.
Personalise your experience: We sometimes make assumptions about your interests and preferences based on the way you interact with our products and services and the information we hold about you.
Knowing these interests and preferences allows us to understand the products, content and services our customers like, letting us focus our efforts on developing those areas. We may use this information to tailor and personalise your user experience, as well as to make decisions about what direct marketing and advertising to show you.
Content recommendations: We may also use your information to optimise article and content recommendations. Based on the kind of articles and content which prove to be of interest to you.
To build and manage direct marketing campaigns: We use your information to create engaging and relevant marketing campaigns promoting products and services we think you will like from our brands and partners. The use of your information to do this is usually based on a legitimate interest, however, we will ask your permission if we want to deliver direct marketing to you. You will be able to change your marketing preferences in your Preference Centre or in the communications you are sent.
To send product related and similar product and services communications: for certain types of marketing communications, we do not require your consent and we instead rely on our legitimate interest. This is the case for example where we send you postal advertising or where we send you ‘in-life’ communications about products or services that we provide to you. You can opt out of these communications either by visiting your preference centre if you have an account or in the communication itself.
We may send you service-related messages, which are about the service we provide. We do not require your consent for these, and you are not able to opt out.
Prevent fraud, check your identity, and prevent money laundering: We may use your information to check your identity in relation to requests you make. We may also have a legal obligation requiring us to carry out this activity
Facilitate posting, commenting and interaction: If you correspond with any of our titles, radio stations or TV channels, or interact with other customers or audience members or our staff, for example by using polls, comments, text messages, video, email, phone, radio or by post, we may display this content indefinitely in any relevant context, subject to our editorial judgement and your rights as set out in this Policy. This may be anonymised in the case of testimonials or customer service conversations. If you take part in any reader or listener forums, send us letters for publication, or take part in any radio ‘phone-ins’, then you may be identifiable to others publicly and your comments attributed to you.
Deliver relevant advertising: We may use the information we hold about you to help us and our partners make better decisions about what adverts to present to you. We also use the information we collect from you and other sources to create engaging and relevant marketing campaigns promoting products and services we think you will like from our brands and partners.
When you visit our websites, use our apps, or watch content on devices connected to the internet such as smart TVs, advertising networks and other intermediaries that we work with may select and then display adverts on your device. In the case of some of our digital radio stations, when listening online, we and our partners may insert a relevant audio advert for you to listen to.
Audience segmentation and creation: we may use the information we hold about you, including how you engage with our products and services, as well as from other sources, to segment our audiences into groups with particular attributes (likes/dislikes/reading behaviours etc). This helps us personalise your experience and show you more relevant content and adverts.
Cookie matching/syncing: When you visit our sites, we may check your device to see if a cookie ID has been assigned to it. This is a form of identifier that tells us who is visiting our sites. We are then able to compare the cookie ID we have for you with IDs that our advertisers hold to see if we both know who you are. By knowing it is you (or your device), the advertiser can decide if they want to advertise to you and if so, what advertising would be relevant. See the section on Cookies & Similar Technologies for more information.
Data matching: From time to time we may allow our clients to compare their customer database to ours. This is called data matching and allows our partners to see if they can reach their audiences on our platforms. 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 and other information that would be useful to understand if an advertising campaign would be effective.
As part of the data matching process we may allow partners to build target audiences based on pre-defined attributes. These ‘lookalike’ audiences may be similar to our partners’ existing audiences. For example, a sports brand may want to reach ‘sports enthusiasts’ or those who enjoy ‘outdoor pursuits’. They could select audiences who have been identified as having an interest in these areas. To do this, we segment our audiences into groups depending on what we think they like or other behaviours. This helps them find the right audiences and we are able to show you more relevant advertising.
Detect ad blockers: We may collect information from your devices that tells us whether you are using an ad blocker. This is so that we can manage our compliance with the law and also determine if we are able to show you advertising. We may also ask you to suspend or whitelist our sites or platforms so that we can show you adverts. As a predominantly advertising funded business, we do rely on our ability to show you advertising to help ensure we are able to provide you with the products and services you request.
Ensure our services are used appropriately: If you post or send offensive or objectionable content anywhere on or to our websites or apps, or otherwise engage in any disruptive behaviour on any of our platforms, we may use the information that is available to us about you to stop such behaviour. This may involve informing relevant third parties, including your employer, law enforcement or other competent authorities about the content and your behaviour.
Ensure that our products and services conform to agreed industry standards: Some of our products and services are independently monitored and assessed to ensure they meet approved industry standards and for industry reporting purposes.
Provide you with support: We may also provide you with help and support where we believe it is required. For example, if you have provided your contact information, we may contact you when a checkout journey is not completed. We may record phone calls or customer enquiries via online chat for quality, training and management purposes.
Conduct market research and analytics: We may use the information we hold on you about your engagement with our products and services, as well as other information collected from partners and other sources, to understand how our products are used and make improvements or develop other products and services our audiences may like. We may need to contact you about your experience of a product or service we provide you.
Ipsos Iris – market research project: When you visit our website, we may collect certain personal data about you for an online audience measurement project that analyses internet users’ behaviour and profile across different websites, applications and devices in the UK. Ipsos MORI, a specialist research agency will be carrying out this research, in conjunction with UKOM, the UK Online Measurement company and DotMetrics. To contact Ipsos MORI about this specific research, please email: firstname.lastname@example.org
Change of control or sale of our business: 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.
TO COMPLY WITH LEGAL OBLIGATIONS & PROTECT OUR RIGHTS
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This may include publishing information about prize winners, for example.
We may also disclose your information where we are allowed to by law to protect or enforce our rights or the rights of others and for the prevention and detection of crime, such as fraud.
The specific legal basis we use will depend on the activity the information is used for. Please keep in mind that while we will rely on one legal basis, if that is no longer available to us, we may be able to rely on another.