Privacy Policy ABOUT US JPIMedia Publishing Limited (“we”, “our”, “us”) respect the privacy of our website users, readers and customers (“you”) and we recognise the need for appropriate protections and management of your personal information. When we, and our service providers, collect and use your personal information and special category data, we are the data controller for the purposes of Data Protection Legislation (defined below). PURPOSE We have prepared this Privacy Notice to assist you in understanding what information we collect about you and how that information is used by us and by third parties. KEY TERMS When we refer to Data Protection Legislation we mean the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”); the Data Protection Act 2018 and any legislation implemented by the UK to give effect to the derogations permitted under the GDPR. personal information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number, email address, etc., and also online identifiers and location data such as IP addresses and mobile device IDs. special category data means personal information revealing your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data; data related to your health or data concerning your sex life or sexual orientation; and criminal convictions or involvement in criminal proceedings. A data controller is someone who decides why personal data is to be collected and how it will be used and treated. CONTACT US If you have any questions regarding the Privacy Notice you can contact us at: No1 Leeds, 26 Whitehall Road, Leeds, LS12 1BE or by email to head.office@jpimedia.co.uk or by telephone on 0131 311 7500. If you are unhappy with how we handle your personal information you can write to us using the contact details noted above; and / or notify the Information Commissioner’s Office (ICO) (please see: https://ico.org.uk/concerns/ for more information). HOW DO WE USE YOUR PERSONAL INFORMATION? INFORMATION WHY WE COLLECT IT LEGAL BASIS RETENTION PERIOD Information you provide to us when you contact us: this may include your name, address, contact details and any other personal information which you choose to provide to us (or which we otherwise obtain as part of that process (such as an IP address)). Enquiries: If you contact us to enquire about any aspect of our business, goods or services, we will collect your personal information in order to respond to your query and we may also use your information where there is another legitimate reason for us to do so. On the basis of our and your legitimate interests. Our interests being that we would like to assist you with any queries you may have and inform you about our goods and services. We will retain this information for no longer than necessary for the uses set out in this Privacy Notice, or while there is a legitimate interest for us doing so. If during our correspondence with you, you enter a contract with us or consent to direct marketing, please see the relevant section of this table for details as to how we will use your personal information. Call recordings: Where you contact us by phone, we may record the conversation in order to allow us to maintain a record of our conversation which we can return to if we need to check any of the queries which we are to respond to you on, for the purposes of training and improving our services, and for security. You will be notified at the beginning of the call if it is being recorded. On the basis of our and your legitimate interests. Our interests being that we wish to improve our services and ensure we respond fully to your queries. We will retain this information for no longer than necessary for the uses set out in this Privacy Notice, or while there is a legitimate interest for us doing so. Recruitment: If you contact us in relation to applying for a job with us, we will collect your personal information in order to assess whether you are suitable for the position you applied for. On the basis of our and your legitimate interests. Our interests being that we would like to consider you for the position you applied for. If your application is unsuccessful, we will delete this information within 12 months of receiving your application. If your application is successful, we will issue you with a further privacy notice in relation to the retention and use of your personal information. Information you provide to us when you enter a contract for our goods or services, for example, subscribing to one of our newspapers, signing up to one of our events: this may include: (a) your name, (b) address, (c) contact details, (d) payment information, (e) the details of the event (if relevant), (f) where and how you signed up for it, and (g) your dietary requirements. Entering a contract: If you enter a contract with us to provide you with any of our goods or services, we will collect your personal information to enable us to provide those goods or services to you (for example to receive payment for the services or to contact you in relation to the event you are attending) and we may also use your information where there is a legitimate reason for us to do so. (i) On the basis that this is necessary to fulfil our contractual obligations to you; and (ii) On the basis of your and our legitimate interests. Our interests being that we would like to assist you with any queries you may have and inform you about our goods and services. We will retain this information for the duration of our contract with you. Once our contract has ended we will retain your personal information for up to six years in accordance with relevant legal and accounting requirements. Where you have signed up to one of our events, we will retain your contact details for a period of two years thereafter. We do this on the basis of it being in our and your legitimate interests to notify you of events which you may wish to attend, or to inform you about our goods and services. If we do not hear from you during this period, we will delete your personal information. Dietary requirements: If you are attending one of our events, we may ask you about your dietary requirements in order for us to provide you with suitable catering. This information could contain special category data, for example, it could relate to your religion. We will only collect and process this information on the basis of your consent. We will delete this information within one month of the event being held. Information provided to us for marketing purposes by third parties: this may include your name and contact details. 118 Data Resource Limited: We have a contract with 118 Data Resource Limited under which it provides us with the contact details of individuals who have indicated that they consent to us contacting them. If we receive your personal information in this manner, we will contact you to ask you for consent to send you further communications (including marketing and other communications). We collect this information on the basis that you have provided 118 Data Resource Limited with your consent for us to do so. We will retain this information until we have contacted you to ask you for consent to send further marketing communications and for up to a maximum of one month. If you do not provide your consent, we will delete your personal information. Where you no longer wish to hear from us, we will retain a minimal amount of your personal information on a “suppression list” to ensure we do not contact you again. If you do provide us with consent, please see below in relation to our use of personal information for the purposes of direct marketing. Information you provide to us when you post information on our websites: this may include your name, contact details and gender. Forums: Where our websites allow you to post on the website, for example via comments sections, we will collect any personal information which you submit via this function. We offer these functions to allow you to engage with our websites and services. On the basis of our and your legitimate interests. Our interests being that we wish to improve our services and allow you to interact and engage with our websites and services. Where you post information or comments to a website, this information will be displayed until we remove the relevant article or webpage where you have posted the information or until you delete it or contact us to ask us to delete it. Use of our websites is subject to separate terms which can be accessed from any of those sites. Information that we collect about you when you sign up to our newsletters or direct marketing services: this may include your name and contact details. Newsletters / marketing communications: Where you sign up to our newsletters or other direct marketing communications, we will collect your personal information in order to be able to send you these newsletters or communications, or where there is another legitimate reason for contacting you. We will only collect this information and contact you in this way when you have provided your consent for us to do so. We will thereafter contact you on the basis of your and our legitimate interests. Our interests being that we would like to inform you about our goods and services. You may withdraw your consent to this type of communication at any time by contacting us or clicking on the unsubscribe button where relevant. We will check whether you wish to continue receiving communications of this nature at least every 12 months. If you respond to opt out, we will delete your information within 1 month of your response. If you do not respond, we will contact you again within two weeks after our first communication to check whether you wish to opt out. If we still do not receive a response, we will delete your personal information within one month of this second attempt to contact you. Where you no longer wish to hear from us, we will retain a minimal amount of your personal information on a “suppression list” to ensure we do not contact you again. Information that we collect about you by way of cookies. This includes your IP address, browser type and operating system. Cookies: We collect this information in order to improve your experience of using our website and to enable us to assess how our websites are used to ensure our services and advertisements are relevant. For further information in relation to cookies, please see the cookies information tool displayed in the footer of each of our websites which you visit. Social Media: We publish content on Social Media platforms. We may place one or more social media platform “tags” on our websites in order to better understand how we may be of best value to you by providing you with the most relevant content available according to what you have chosen to read on our own websites. These tags only record information around activities to help us understand if you are registered or subscribed with us, or visit our websites so that we may use your reading preferences to provide more relevant content and/or offers to you, on social media platforms, e.g. removing subscription offers from your feed if you are a current subscriber. We do not have direct access to your personal data on your social media platforms. Other than cookies which are strictly necessary for the functioning of our website, we will use cookies only on the basis of your prior consent. Please see our cookies information tool which is displayed in the footer of each of our websites to review the types of cookies which you have consented to. On the basis of our and your legitimate interests. Our interests being that we wish to improve our services and allow you to interact and engage with our websites and services. We will use cookies only on the basis of your prior consent. Please see our cookies information tool which is displayed in the footer of each of our websites to review the types of cookies which you have consented to. Please see our cookies information tool for further information. Please see our cookies information tool for further information. UPDATING YOUR PERSONAL INFORMATION Please contact us at data.protection@jpimedia.co.uk as soon as possible after there is any change to your personal details, including your contact details. Where possible, we aim to contact you on a regular basis to ensure the personal details we hold about you are accurate. SHARING YOUR PERSONAL INFORMATION We contract with third party service providers and suppliers to deliver certain services. We have contractual arrangements in place with each of these providers so that they are obliged to protect your personal information. The following third parties may have access to your personal information for the purposes noted below: Software providers: we use a range of software providers in order to administer our business, these providers include the host of our website, the providers of our call recording system, email system, automated email marketing system and customer databases. Service providers: we use a range of service providers in order to effectively operate our business, for example providers of subscription voucher services. Event organisers: where we hold events, we may share your personal information with third party organisers of the event including caterers and venues, for example, we may share your name with the venue for the purposes of administering a guest list. Competition prize providers: where you enter one of our competitions, we may share your information with the third party who is supplying the prize to ensure they are able to provide you with any prize that you may win. Cookies providers: for example, Google Analytics and 1PlusXAG, please see our cookies information tool for further information. JPIMedia Publishing Limited is part of a group structure of companies, and your personal information may require to be transferred to one of our subsidiaries or affiliates in order to ensure the proper functioning of our business; any other person who is authorised to act on your behalf; regulators, government departments, law enforcement authorities, tax authorities, accountants, insurance companies, lawyers and other professional advisers; any relevant dispute resolution body or the courts; and persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in our business. Some of these entities may also be data controllers under the Data Protection Legislation. However in the first instance you should contact us using the contact details above if you have any queries. Except as provided above, we will not share personal information with any other third parties without informing you beforehand, unless required by, or in connection with, law and / or regulatory requirements. We will not sell, trade or lease your personal information to others. EUROPEAN ECONOMIC AREA The information we collect from you may be stored inside the UK, the European Economic Area (“EEA”) or outside the EEA. If you live or work outside of the UK or the EEA, we may need to transfer your personal information outside of the UK or the EEA to correspond with you. Where this applies, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice. We also transfer personal information outside the UK or the EEA where our service providers host, process, or store personal information outside the UK or the EEA. Where this is the case we use contractual arrangements and safeguards to protect this personal information, these safeguards include: The country to which the personal information will be transferred has been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to non-EU countries. Where we use providers based in the US, we may transfer personal information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the EEA and the US. For further details, see European Commission: EU-US Privacy Shield Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA. YOUR RIGHTS You have certain rights under the Data Protection Legislation which can be exercised by contacting us at: data.protection@jpimedia.co.uk, including: the right to access the personal information held about the you by making a subject access request in accordance with the Data Protection Legislation. We may charge a reasonable fee when a request is manifestly unfounded or excessive; the right to have your personal information rectified if it is inaccurate or incomplete; the right to request to have your personal information deleted in certain specific circumstances as set out in the Data Protection Legislation; the right to request to restrict the processing of your personal information in certain specific circumstances as set out in the Data Protection Legislation; the right to ask us not to process your personal information for marketing purposes or for purposes based on our legitimate interests; the right to ask us to not undergo automated decision making; and where you have provided consent, to request to withdraw such consent at any time. Please note that if you choose to exercise your rights to have personal information restricted or deleted, then we may not be able to provide you with our services. Further details about your rights can be found on the ICO’s website at https://ico.org.uk/. UPDATING OUR PRIVACY POLICY We may update or amend this privacy policy from time to time, including in order to make clarifications or modifications to it or to reflect changes to legislation. Any changes to this privacy policy will be posted here and such changes will become effective as soon as they are posted. Website T&Cs Advertising T&Cs Privacy Policy Cookie Settings Competition & Prize Draws Freelancer T&Cs Modern Slavery Statement Covid-19 summary of risk assessment results © JPIMedia Publishing Ltd All Rights Reserved