Privacy Policy

INTRODUCTION

Wycombe Today is a news publisher.

We respect your rights to privacy and we are committed to protecting your personal data in accordance with the law when you are dealing with us.

This privacy notice tells you how we collect and look after your personal data and what your privacy rights are.

1. WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CHANGES TO THIS PRIVACY NOTICE

1. WHO WE ARE

Wycombe Today is a privately owned news publishing organisation.

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

There may be other privacy policies that apply to certain services we provide. Please read these when you register or subscribe for these services.

Data Protection Officer contact details

Email address: [email protected]

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

Changes to your data and preferences

It is important that any personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you have registered for an account with us for some our services, we provide a details page, where you can update your personal information at any time and change your marketing preferences.

2. 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, 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, sex life, 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.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login user-name (but never your passwords), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your user-name, 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 Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share anonymous data such as statistical or demographic data. For example, we may aggregate your Usage Data to calculate the percentage of users reading a particular story, advertisement or other element of the website. However, if we combine or connect anonymous data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Unless they are properly the subject of editorial material in our news 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’ll let you know at the time.

Third-party links

Our websites may include links to third-party websites, applications and plug-ins (such as ‘Facebook recommend’). 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 16 products or services or obtain information about them (except in newsgathering). Children may sometimes be invited to take part in prize competitions and promotions, in which case we will require parental or legal guardian consent.

Data protection in newsgathering

We gather information for the production of our news and other information services (‘editorial information’). The editorial information is intended for publication and may incorporate extensive personal data about individuals, including Sensitive Personal Data.

The free press serves a vital function in an open democratic society and the law recognises its importance by exempting the press from most of the data protection provisions where there is a proper journalistic purpose.

We respect the rights of privacy of people who find themselves in the news and we seek to comply with the relevant data protection principles where we reasonably can.

News and features are published online and also distributed by social media such as Facebook and Twitter. They may be passed for publication by third party publishers in any medium in the UK or around the world. Our website is focused locally in the UK, but of course they can be viewed from anywhere in the world.

After first publication, in print or on the home page of our websites, we will keep copies in publicly accessible paper or searchable online archives. These archives are an important historical record. They are intended to be kept indefinitely. We will not delete, annotate or amend the archives unless the law so requires or there is an inaccuracy or an important update.

We may also record and store unpublished information about individuals and matters of general interest for any length of time with a view to publication in the future, for example background research in developing stories or longer-term information held for the preparation of an obituary. We seek to review this information at least every seven years and discard it if we think it is no longer relevant or accurate.

On our websites and social media pages we may host facilities where people can post comments about news stories and other matters. 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, but we operate user terms and an acceptable use policy which we may enforce against users on receipt of a complaint. A ‘report this post’ link is provided and we will respond to complaints using that link.

3. HOW YOUR PERSONAL DATA IS COLLECTED

Separately from our news gathering activities, we 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. And you will give us personal data when you:

• Purchase from us advertising or other products or services;
• Use our website;
• Register and comment on our news stories;
• Subscribe to any of our services or publications;
• Request marketing to be sent to you.
• Enter a competition, promotion or survey; or
• Take part in an event we have organised.

Behavioural advertising online

As you interact with our website we or third parties posting advertisements to our site may automatically collect Technical Data about your devices and browsing patterns by using cookies and similar technologies. Those third parties may also receive Technical Data about you if you visit other websites employing their cookies and aggregate this data to build Profile Data about you and your interests and preferences in order to target advertisements tailored to your interests. The third party advertising networks posting ads to our sites include Google. Please bear in mind that none of the techniques we use will collect your name, email address, postal address or phone number.

Cookies: It’s your choice

Using cookies means we can show more of the ads that are relevant to you and fewer that are not. Cookies control the number of times you see them and measure how effective the ad campaign has been.

Effective advertising helps us to keep our websites and their news content free for you to use.

You can find out more about behavioural advertising and how to opt out of it selectively at youronlinechoices.com. If you want to opt out of receiving targeted advertising, this does not mean that you will no longer receive advertising when you are using our websites, it just means that the advertising you see will not be customised for you.

You can also set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. But if you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about cookie control and the cookies we use, please see our Cookie Policy.

Marketing messages

We do not send marketing messages.

When we send emails to you (see marketing in section 4 below), they will contain pixels. Our system uses them to collect Technical Data about the opening of the email and your clicking on any links. They also tell us if you go on to purchase products or services promoted in the email so that we can evaluate the success of the promotion. They are not used for targeting ads.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources as set out below:

• When you are online, we may gather Technical Data from cookies used by analytics providers such as Google and StatCounter. (You can opt-out of Google Analytics monitoring your behaviour on our web sites by going to https://tools.google.com/dlpage/gaoptout/);

4. 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 sell advertising space (including targeted advertising as described above) in order to fund our free-to-access news services;
• To market services to you; and
• To monitor and improve our services

We 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

We never send marketing communications by email or text.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We will never share details of our customers except where required by law.

We may make the services of other organisations 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.

If you are attending an event organised by us or an event partner, data may be shared for event administration purposes.

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.

6. 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.

7. 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.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law, for tax and other purposes, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers. We will review our marketing contact lists and delete those contacts where there has been no activity for three years. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. 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. In particular, see our editorial policy in section 2 above.
• 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 accuracy of the data; (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.

If you wish to exercise any of the rights set out above, please contact us at [email protected]. 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. 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.

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.

10. 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.

Wycombe Today, 23rd May 2018.