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Reach Group – Privacy Notice

 

We have organised this Privacy Notice based on the different ways you might
interact with us and what you might want to know.

Please use the contents list below to navigate to the section of the Privacy
Notice which you are interested in. At the end of each section if you want to
return to the contents list please click the link: ‘Click here to go back to
‘Contents’’

CONTENTS

 1.  Who we are and how to contact us
 2.  About this Privacy Notice
 3.  When you browse our websites and use our apps
 4.  When you create or sign into your online Reach account
 5.  When we communicate with you by email
 6.  When you enter a competition or prize draw
 7.  When you complete a survey
 8.  When you subscribe to our print or “e-publishing” titles
 9.  When you place a classified ad
 10. When you apply for a job with us
 11. When you work at other organisations that we do business with
 12. Site visits and CCTV at our premises
 13. Further data sharing by Reach
 14. Your rights and how to exercise them
 15. Residents of California 
 16. Residents of Nevada
 17. Privacy Notice last updated
     
     
     
     

1.    Who we are and how to contact us

 We are the Reach group, which is made up of Reach plc and its subsidiaries.
Reach plc is the largest national and regional news publisher in the UK with a
leading portfolio in Ireland. We create engaging, relevant content which is
distributed through newspapers, magazines, and digital platforms – playing a
central role in our audiences’ daily lives. We are the name behind some of the
UK’s most influential, iconic, and trusted news brands, such as the Daily
Mirror, Daily Express, Daily Star, Daily Record and Sunday People as well as
leading celebrity and entertainment magazine OK! We also publish leading
regional titles including the Manchester Evening News, Liverpool Echo,
Birmingham Mail, Western Mail and Bristol Post. You can see the list of websites
and brands we publish here.


Our address is:

One Canada Square Canary Wharf London E14 5AP

Depending on who you are and how you interact with us, the legal “controller” of
your personal data will be one or more of our group companies, like MGN Limited,
Local World Limited or Express Newspapers (all at the address above). Your point
of contact for anything to do with how the Reach group uses your personal data
is the office of our group Data Protection Officer, who you can contact by
submitting the relevant form accessible within the  'Your rights and how to
exercise them'  section or by writing to ‘The Data Protection Team’ at the
address above.

Click here to go back to ‘Contents’

2.    About this Privacy Notice

This Privacy Notice tells you about the kinds of information we hold about you,
what we do with it, and why.

As a broad summary, in our business we use information about people:

 * To carry out our work as journalists, by investigating and reporting on
   stories of relevance to our readers.

 * To deliver our features and editorial content.

 * To provide services such as subscriptions or newsletters that people sign up
   to, and to operate interactive features like competitions and surveys.

 * To help us to understand our readers and target our marketing and advertising
   that enables us to continue to finance and bring you our feature and
   editorial content.

 * To carry out back-office administration and generally run and operate our
   business, for instance by administering our relationships with suppliers and
   partner organisations, or handling job applications.

Some specific activities and websites might have their own additional and
complementary privacy notices which sit alongside this one. Generally, that will
be the case for very specific services such as our commercial job boards or
other specialist websites, or where we have a very specific kind of relationship
with you (for instance if you are an investor or a member of our group pension
scheme). We try to make it obvious where that is the case.

Data Protection and Journalism

The UK

In the UK the Data Protection Act 2018 provides an exemption from data
protection laws to prevent unjustified interference with the work of
journalists. We are members of the Independent Press Standards
Organisation (IPSO) and therefore subject to the Editors’ Code. If you object to
a story we have published that concerns you personally then you can find our
complaints policy here [UK Complaints], which explains how to raise a complaint
and how we will handle it.

Ireland

In Ireland we subscribe to the Code of Practice of the Press Council of Ireland
and the Press Ombudsman, which set the benchmark for high professional
standards. If you believe that we have got something wrong, or that we have
breached the Code of Practice, please let us know at the contact details of the
publication concerned.

The Code of Practice and details of how to lodge a complaint with the Press
Ombudsman are available from:

Post: 1, 2 & 3 Westmoreland Street, Dublin 2.

Website: www.pressombudsman.ie

Email: info@pressombudsman.ie

Telephone: 1890 208 080

Fax: 01 6740046

Click here to go back to ‘Contents’

3.    When you browse our websites and use our apps

When you browse our websites or use our apps, we and our advertising partners
will receive some information about the device you are using and about what you
look at and interact with. We do this for the purpose of choosing which adverts
to show you, as well as to make our sites and apps work properly. It also allows
us to diagnose problems with them and understand how they are used so we can
make them better. Sometimes, we also apply a degree of personalisation in
choosing which content to show you (for example, by recommending articles
similar to those you’ve viewed previously).

You can learn more about what we do with this information and why below.

3.1.    Targeting by Reach

We combine the information you give to us (for example, sign up information for
newsletters and competitions) with the information we receive when you use our
websites and apps, and analyse it in order to help us to understand your
preferences and interests. We then associate this with a unique identification
number. This is then used to tailor the content and advertising that you see on
our websites and in our apps, so it is more likely to be of interest to you. We
don’t share this personalised analysis with anyone outside Reach. In particular,
it is not shared with advertisers or with the third-party advertising networks
that we work with other than in highly aggregated form so that your personal
data cannot be identified.

3.1.1   The data we collect and what we do with it

The data we use for this purpose is as follows:

 * The page you view, and associated information such as how long you spend on
   them.

 * Your approximate location, to city or town level.

 * Your email address, name and sometimes username and postcode, which we will
   receive when you sign up for an account on one or more of our websites or
   apps, when you subscribe to our newsletters, when you enter one of our
   competitions or when you complete one of our surveys.

 * The newsletters you have subscribed to, the promotions and competitions you
   have entered and the surveys you have completed.

We will analyse this information to infer interests, preferences, and
demographic characteristics, and associate it with an internal identification
number. For example, if our website analytics tell us that you are located in
the approximate area of Newcastle-upon-Tyne and you read our online title
ChronicleLive (which is focused on local news for that area), and you sign up to
receive an email newsletter about football from our national title The Mirror,
then we could infer from that you are interested in things related to a local
football club or to football generally.

We then divide up our identification numbers into groups based on the inferences
we draw about them. Those groups are called “audience segments” or “audiences”.
So, for example, an identifier associated with Newcastle, ChronicleLive and the
football newsletter could be allocated to audiences likely to be interested in
football, and events near Newcastle-upon-Tyne.

We then use those “audiences” to do two things: first, to help us to recommend
content which is more likely to be interesting (for instance, more articles
about football), and second to help us to target advertisements when advertisers
buy advertising space from us directly.

The advertiser would never see the actual data that we use – it remains with
Reach at all times. All we would share with them would be the criteria we used
to target their advert, how many times their advert was shown and how many
people clicked on it (but not who), so that they know how well the advert did
and we know how much to charge them.

3.1.2    Our legal basis

Your activity on our websites and in our apps can be managed by you using our
“cookie banner” and related Consent Management Platform (CMP). The vast majority
are used on the basis of your consent where you provide it. Some may use our
Legitimate Interest and some are Essential – Please see our Cookie
Notice for further information or the ‘cog’ icon or link at the bottom of every
webpage to manage your consents. When using our apps if you want to change the
settings, go to the ‘My Account’ Link at the bottom of the screen which includes
‘My Privacy’ and takes you to the CMP.

We combine that information with the other things we know about you (like your
newsletter subscriptions) on the basis of our legitimate interest in
understanding our readership, both to serve you better and to make us more
attractive to advertisers. This helps us to secure a future for news reporting
and journalism in the age of social media, especially local news reporting and
journalism.

You do, of course, have an absolute right to object to this. You can always
register your objection by completing the relevant form 14.5. Your right to
object to what we do with your data, and to have restrictions placed upon it. 

3.1.3      How long we keep it for

We keep the information about your activity on our websites and in our apps for
up to up to three years since last browsing activity, with some anonymised
browsing activity retained thereafter.

3.1.4.      Who we share it with and why

The data which we use to create the unique identifier and our “audiences” is
shared with the partners who provide us with the technology powering it, most
notably Upland Software and Lotame, who host core data management platforms for
us. They act as our “processors”. This means that they are bound by law and
contract to do only what we tell them to do with the data, to keep it safe, and
not to share it with anyone else or use it for anything other than providing
their service to us.

3.1.5.      Whether we send it outside the country of collection

Upland Software and Lotame are global businesses and so the data they host for
us may be held outside of the country of collection. We have implemented the
required safeguards as necessary (for example, standard agreements approved by
the relevant authorities).

3.2.   Targeting by third party advertising networks

Digital advertising helps us to fund the news articles and content published on
our sites and enables us to provide some of our content for free. We and our
third-party ad partners may display digital advertising on our sites that is
tailored to your interests and preferences so the online adverts you see are
more relevant to you. We work with third party ad networks to fill unsold
advertising space on our sites and in our apps by auctioning it automatically
through a process called “real time bidding”. These ad networks bid to show
their ad to you when you visit our sites or use our apps.

The ad networks exchange information through cookies, which allow them to
recognise you when you visit any site that they work with (not just Reach
sites). Where we use cookies on our sites for advertising purposes, we ask for
prior consent. The cookie information will be used along with other information
we hold about you to display digital advertising that is more relevant to you.
It is important to note, however, that where you do not provide your consent for
digital advertising you will still see digital advertising on our sites, but
this will not be tailored to your interests and preferences.

Where you provide consent to using your data to create a profile for digital
advertising we may also sell or share limited data types to our partners with
whom we have a legally binding relationship for similar purposes; typically data
on the page content which you have shown an interest in and online identifiers,
not direct identifiers such as your email address. Captify is one such partner.
They may act as an independent controller of your data, and their privacy policy
is shown here: Captify Privacy Policy .


3.2.1      The data collected and how it is used

On your first visit to one of our sites or apps (and on other occasions to allow
you to change your mind), you will be presented with a ”cookie banner”. This
asks you if you consent to the use of cookies and related technologies for the
purposes of, amongst other things, selecting and delivering ads. If you do, then
the ad networks will be able to recognise your device according to a unique
identification number.

We then send out a “bid request” to the advertising networks we work with. What
that bid request says is, essentially, ”ID number ABC123 has landed on our
website, do you want to show this user an advert?” The winner then gets to
display their ad.

The auction process happens automatically, in the second or so between you
requesting the page and it loading and displaying. The data used by the ad
networks to select the ad to show is held by them, not us, and we never see it.

If we sell or share limited data to an ad partner, as described in 3.2, it will
be used for profiling and digital marketing on Reach websites and apps, and
potentially other sites & apps with whom the partner has a relationship, if you
have given permission for that site or app to do so.

An important point to understand is that most of these ad networks will not know
who you are in a “real world” sense. They will not know your name, or your email
address, or your phone number (we may know those things because you’ve given
them to us in other contexts, but we never share that information with them).

We say “most” because there are two significant exceptions, which are Facebook
and Google. They may provide targeted advertising services based on the things
they know about their users, and so if you are signed into your account with
them on your device, they will be able to recognise you and associate your
browsing history across sites that use their services.

Data Matching:

When you browse our websites or use our mobile applications and when you provide
your email address on these (either to log in, or sign up to a newsletter, or
similar) we may share it, in hashed, pseudonymised form, with our partner
LiveRamp Inc and its group companies, acting as joint controllers. LiveRamp uses
this information to create a secure online identification code for the purpose
of recognising you for cross-channel advertising. This code is placed in our
cookie, does not contain any of your identifiable personal data, and will not be
used by LiveRamp to identify you. It may be shared with our advertising partners
and other third-party advertisers globally for the purpose of enabling
interest-based content or targeted advertising through Reach sites. These third
parties may in turn use this code to link demographic or interest-based
information you have provided in your interactions with them to the
pseudonymised code. Detailed information on LiveRamp’s data processing
activities is available in LiveRamp’s privacy notice and opt-out. You have the
right to withdraw your consent or opt-out to the processing of your personal
data at any time via our Cookie Management Platform accessed via the ‘cog’ icon
or link at the bottom of every webpage.


If you accept the use of cookies in our Consent Management Platform, when you
submit your email address to create an account or sign-up to a newsletter we may
share your email address in a hashed form with Amazon Publisher Services (APS).
APS then link the hashed email to a profile which they may already hold related
to that address. The hashed email will be used in a secure, pseudonymised form
within a cookie to flag to APS whenever you visit an APS enabled Reach website
again. APS will use this to determine, in real-time, if any of their business
customers want to market to a profile similar to yours. If this is the case they
may initiate an advert which will appear to you on the Reach website concerned.
You have the right to stop this processing activity at any time via the use of
‘Reject’ on our Cookie Management Platform accessed via the ‘cog’ icon or link
at the bottom of every webpage, or via a form accessible from section 14 of this
Privacy Notice. The APS Privacy Notice can be found at APS PN

3.2.2.      Our legal basis

Where required by applicable law, advertising networks undertake this activity
on the basis of your consent, which we ask for on their behalf through the
‘cookie banner’ which appears when you first visit our site. The ‘cookie banner’
message box will reappear from time to time in case you change your mind, or
when something changes (typically every 30 days). Please see our Cookie
Notice for further information or the ‘cog’ icon or link at the bottom of every
webpage to manage your consents. When using our apps if you want to change the
settings, go to the ‘My Account’ Link at the bottom of the screen which includes
‘My Privacy’ and takes you to the CMP.

Most of our third-party advertising partners operate within an industry
framework and code of practice issued by the Internet Advertising Bureau
(IAB) called the “Transparency and Consent Framework”, which sets out the
technical means for your choices to be passed through the ad networks. It also
requires that members adhere to IAB policies and standards of behaviour.

Advertising partners who do not work within the IAB framework are listed
separately in the platform which can be viewed in our Consent Management
Platform (CMP) – please see our Cookie Notice for further information or click
on the ‘cog’ icon at the bottom left of every webpage. In the Consent Management
Platform popup go to the ‘Partners’ page and scroll down - IAB partners are
listed first, then you'll see Non-IAB vendors and finally Google partners.

3.2.3.      How long we keep it for

We do not ourselves hold a copy of the data gathered by the advertising
networks. They will each have their own retention policies which you can find in
their privacy notices linked through our ‘cookie banner’ – these are often short
(between 30 and 60 days), because shopping interests change over time.

3.2.4.      Who we share it with and why

When we participate in auctions for unsold advertising space, we send bid
requests to third party advertising networks. You can find the list of
third-party advertising networks who we work with by clicking on the ‘cog’ icon
or link at the bottom of every webpage and reviewing our Consent Management
Platform.

3.2.5.      Whether we send it outside the country of collection

The digital advertising networks are global in nature and so, while we are
predominantly a UK business, this data will travel across international borders,
and in particular many automated advertising transactions will be processed in
the USA. Where we are the ones making the transfer (typically, we are not), we
have implemented the required safeguards as necessary (for example, standard
agreements approved by the relevant authorities).

3.3.  Making our sites and apps work properly, diagnosing problems with them,
and understanding how they are used so we can make them better

We use the information logged by our servers and certain third-party analytics
tools (such as Google Analytics, Mpulse and Hotjar) to help us to spot problems
with our digital services, such as page errors or slow loading times, as well as
understanding usage patterns and watching for security problems. You can find
more information below.

3.3.1     The data we collect and what we do with it

We gather data for this purpose in two ways.

Firstly, our servers record certain information provided by your devices when
they request content, consisting mostly of technical information about your
device such as language, screen size and the features and functions it supports,
but also including the internet or “IP” address from which it is connecting, and
the page or data requested. The data is used for system performance, content
delivery and security purposes. It is saved together with the dates and times
the requests occurred into files stored on our servers called “logs” or “log
files”.

Secondly, on your first visit to one of our sites or apps (and every so often
again after your first visit), you will be presented with a ’cookie banner’
asking you if you consent to the use of cookies and related technologies for our
use of analytics. If you do, then several “cookies” (small text files) will be
stored on your device containing identification numbers. Those numbers can then
be read on your subsequent visits to recognise your device, and our analytics
providers will use that information to provide us with various reports and
metrics on how our sites are used. Google also uses the data that it gathers as
a result for other purposes, which you can read about in Google’s Privacy
Policy.


If you wish to opt-out of the use of Google Analytics you can access and
download the Opt-out browser add-on from here: GA Opt-Out.

3.3.2.      Our legal basis

We process the personal data captured in our server log files on the basis of
our legitimate interest in monitoring our systems, understanding how they are
used, fixing problems with them, and for security monitoring and management
purposes.

We process the personal data captured by our analytics providers on the basis of
your consent, which we ask for through a “cookie banner” which appears when you
first visit our site. That message box will reappear from time to time in case
you change your mind (typically every thirty days), and on your first visit
after we make a significant change.

3.3.3.      How long we keep it for

We keep the information in our server log files for up to 90 days, depending
upon the log type and purpose.

Our analytics providers will keep the information they gather from our sites and
apps in line with their own privacy notices, which you can access through our
‘cookie banner’ and Consent Management Platform (see the ‘cog icon’ or link at
the bottom of every webpage).

3.3.4.      Who we share it with and why

We use AWS and CloudFront to help us to analyse our server log files. They act
at our direction, as our “processor”.

The information gathered using Google Analytics is held by Google and is made
accessible to us by Google through various dashboards and reporting tools.

The following providers are key to providing additional website analytics or
diagnostic capability:

 * Akamai Mpulse (https://www.akamai.com/legal/privacy-and-policies)

 * Chartbeat (https://chartbeat.com/privacy/)

 * Hotjar (https://www.hotjar.com/privacy/)

 * Viafoura (https://viafoura.com/privacy-policy/)

3.3.5.      Whether we send it outside the country of colleciton

The technology providers we use are global businesses. The data is located in
Ireland with some being routed through AWS outside of the UK and EEA. We have
implemented the required safeguards as necessary (for example, standard
agreements approved by the relevant authorities).

Click here to go back to ‘Contents’

4.     When you create or sign into your online Reach account

Some elements of our websites and apps require you to create an account in order
to use them; for example, the ability to leave comments under articles or to use
some of the functions of “InYourArea”. We use your email address and the other
information that you give to us as part of the account creation process to
operate your account and provide those functions. When you are signed in with
your Reach account, we will also have the ability to associate your account
details with the information we gather through our analytics tools about how you
use our sites.

4.1.         The data we collect and what we do with it

When you create an account we may collect your name and email address.

For services that provide local information (like InYourArea) we will also
collect your postcode and any associated areas of local interest that you want
to be updated about.

Some services may let you upload your own content to our sites, such as comments
or pictures. Those things will, by the nature of the service, be generally
visible on the site. Your comments may be used in print, online or on the social
pages for brands owned and published by Reach plc. We may also record what types
of content you have commented on, and associate this with our profile of you.
Please do not provide any personal data which you do not want to be published.
Comments will be subject to moderation checks before publication.

We use this information to operate your account and to enable you to log in and
use our services; for example, on InYourArea we use your postcode to identify
the correct local information to display to you.

You may also be invited during the account creation process to subscribe to one
or more of our newsletters, or to opt in to receive certain special offers and
promotions. You can read more about that by navigating to the appropriate
section of this Privacy Notice via via the ‘Contents’ list 


Unless you object, we will also associate your online account with the other
things we know about you, like your page views.  You can learn more about that,
including how to object, here

4.2.         Our legal basis

We process your email address and the other information you give to us in order
to provide the relevant function or service of our sites on the legal basis of
consent. We associate the data which you provide on sign-up with the profile
created from your browsing activity on the basis of our legitimate interest. If
you wish to object to this please see section 'Targeting by Reach'

Our legal basis for any resulting email marketing is your consent – see here for
further information.

4.3.         How long we keep it for

We will keep your account active for as long as you continue to use it, and for
up to 3 years afterwards.

4.4.         Who we share it with and why

We use a third-party technology provider called LoginRadius [LoginRadius] to
handle the technical aspects of operating your account on our behalf. They host
your email address and password. They act as our “processor”, meaning that they
are bound by law and contract to keep your data safe, and to do only what we
tell them to do with it.

4.5.         Whether we send it outside the country of collection

Our user account technology provider LoginRadius is based in California and
India, and so your personal data will be processed from those locations as part
of their provision of their service to us. We have implemented the required
safeguards as necessary (for example, standard agreements approved by the
relevant authorities).

Click here to go back to ‘Contents’

5.    When we communicate with you by email

When you give us your email address we will use that email address to
communicate with you for the purpose you provided it; for example, if you sign
up for a newsletter then we will use the email address you provide to send you
that newsletter. These may include special offers and promotions.

The links in our emails are unique to your email address, and so if you click on
them our servers will attribute that click to your email address and that
information will be associated with your unique identifier (3.1. Targeting by
Reach). If you choose to allow your email program to load the images in our
emails, we will also be able to see that you opened the email. You can find out
more about each of these activities below.


5.1.         Sending you the newsletters you subscribe for


When you subscribe to one of our email newsletters, we will send those
newsletters to the email address you provided. If you want us to stop, the
easiest way is to click on the “unsubscribe” link which you will find at the
bottom of every email. You can find more details below.

In some jurisdictions outside of the EU/UK, and where permitted by applicable
law, we may purchase/rent lists of persons who may be interested in our products
and services. We may contact such persons by email.

5.1.1.      The data we collect and what we do with it

We collect your name and email address in order to send you the newsletters you
subscribe to. When you sign up for newsletters from our “In Your Area” local
information website, we will also collect your postcode in order to provide the
correct local information.

Sometimes, our newsletters will contain advertisements.

Unless you object, we will also associate your newsletter subscription with the
other things we know about you, like your page views. You can learn more about
that  here.


5.1.2.      Our legal basis

We use your email address to send you the newsletters you subscribe for on the
basis of your consent. You can withdraw that consent at any time. The easiest
way to do so is to click on the “unsubscribe” link at the bottom of every
newsletter we send.

We associate your email subscription with the other things we know about you on
the basis of our legitimate interests. You can learn more about that here.


5.1.3.      How long we keep it for

We will keep your email address on the subscription list for the relevant
newsletters until you unsubscribe from them. Furthermore, we will stop sending
you a newsletter if we see no activity (e.g. no links clicked on) for a period
of time, and generally but not exhaustively, after 24 months.

5.1.4.      Who we share it with and why

Processors provide the technology platforms which we use to administer our email
lists and to manage the adverts in our emails. They act as our “processors”,
meaning that they are bound by law and contract to keep your data safe, and to
do only what we tell them to do with it.

5.1.5.      Whether we send it outside the country of collection

Email administration data is hosted within the EEA. Advert management services
data is processed from the UK and EEA.

5.2.         Sending you special offers and promotions, with your consent

When you give us your email address, we will sometimes also ask you if you would
also like to receive promotions and special offers from us. If you agree, then
we will send you occasional offers and promotions to the email address that you
gave us. You can unsubscribe at any time.

5.2.1.      The data we collect and what we do with it

We will use the email address you give to us to send our offers and promotions
to you. It will always be clear who the offer or promotion has come from, and we
don’t sell or give our email lists to anyone else.

5.2.2.      Our legal basis

We do this on the basis of your consent. You can withdraw that consent at any
time. The easiest way to do that is to click on the “unsubscribe” link which you
will find at the bottom of every email.

5.2.3.      How long we keep it for

We will keep your email address on the list for promotions and special offers
until you unsubscribe from them. We will also stop sending you promotions and
special offers if we see no activity (e.g. no links clicked on) in 24 months.

5.2.4.      Who we share it with and why

A processor provides the technology platform which we use to administer our
email lists. So, they will host the data containing your email address on our
behalf. They act as our “processor”, meaning that they are bound by law and
contract to keep your data safe, and to do only what we tell them to do with it.

5.2.5.      Whether we send it outside the country of collection

The data is hosted and processed within the EEA.

5.3.         Tracking technologies used in our emails

If you tell your email application to load images we will know when you open one
of our emails. When you click on links in our emails, we will know that it was
you who clicked on it. We use this information to inform the content of future
newsletters (by looking at what’s popular), and to understand whether you
continue to be interested in receiving them.

Unless you have previously objected, we will also associate that information
with other things we know about you. You can learn more about that here.


5.3.1.      The data we collect and what we do with it

We track engagement with our emails in two ways.

Firstly, as for most email newsletters and promotions worldwide, our emails
don’t attach any pictures they use to the email itself, but instead load them
from a remote server on demand. By default, most email programs don’t load
remote images automatically, but only when you click on the button or link in
the program to “show images” (or similar wording). When you do that, the images
linked in the email are downloaded from our technology provider’s server so they
can be displayed in your email program.

If the images are downloaded, our technology provider can tell us that you
opened the email.

Secondly, the links in our emails to articles and other external content are
personalised, such that if you click through to the content using the link in
our email, we will know that it was you who clicked it (or at least, someone
reading the email we sent to you).

We do this to help us to understand how you engage with our emails.

5.3.2.      Our legal basis

We record the opening of emails on the basis of your consent. You can withdraw
your consent at any time either by configuring your email client not to load
images, or by unsubscribing from the relevant email.

We use the personalised URLs for links to external content on the basis of our
legitimate interest in understanding how you engage with our emails and which
kinds of content are of most interest to you. You can object to this use of your
personal data by completing the relevant form  14.5. Your right to object to
what we do with your data, and to have restrictions placed upon it.


5.3.3.      How long we keep it for

The data gathered to understand email opening and interests related to articles
and links within the emails is retained for as long as you continue to engage
with our emails, and for a period of up to 3 years afterwards.

5.3.4.      Who we share it with and why

Third party processors provide the technology platforms which we use to
administer our email lists and to manage the adverts in our emails. They act as
our “processors”, meaning that they are bound by law and contract to keep your
data safe, and to do only what we tell them to do with it.

5.3.5.      Whether we send it outside the country of collection

The data is hosted in the Republic of Ireland, the UK and Denmark.

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6.      When you enter a competition or prize draw

From time to time we run competitions and prize draws which require you to
provide your name and contact details. We use that information to administer the
competition or prize draw and to communicate with you about it (for example if
you win a prize).

We may also use that email address to send you occasional special offers and
promotions, if you opted in to receive them. See here for more information on
that and how to unsubscribe.


Unless you have objected, we will also associate the fact that you entered the
competition with the other things we know about you, like your page views. You
can learn more about that here. We may also run some competitions or prize draws
for which we utilise your declared responses to build into our profile about
you. When we do so, this will be communicated in the associated text, and you
will be asked to either consent to this use or will be given the option to
‘object’ via a tick box.

6.1.   The data we collect and what we do with it

When you enter a competition or prize draw we will collect the information you
provide to us, such as your name, email address and answers to any questions. We
will use that information to run the competition or prize draw. If you happen to
win a prize, we may ask you for additional information, such as an address to
send the prize to. As highlighted above, we may also retain your responses as
part of a profile about you.

6.2.    Our legal basis

We do this on the basis that it is necessary to fulfil the contract formed with
you when you enter the competition or prize draw. Use of your declared data for
profiling purposes will be based either upon consent (via tick box) or our
legitimate interest, for which you will be given the option to ‘object’.

6.3.    How long we keep it for

We will keep your competition entry for the duration of the competition and for
up to 90 days after the closing date. Data utilised for profiling will be
retained for up to 3 years.


6.4.   Who we share it with and why


Information about competition and prize draw entries is only shared with the
service providers who provide us with the technology powering our systems and –
if you win a prize – with the companies who supply and deliver the prize to you.
The technology providers act as our “processors”, meaning that they are bound by
law and contract to keep your data safe, and to do only what we tell them to do
with it.

6.5.   Whether we send it abroad


Our online form technology provider may process your personal data outside of
the UK and EEA. We have implemented safeguards to secure and limit the
processing of the data, including standard agreements approved by the relevant
authorities.

Click here to go back to ‘Contents’

7.     When you complete a survey.

Sometimes we run surveys to help us to understand more about our readership or
about public opinion generally. We use your answers to those surveys to produce
anonymous statistics which we use to inform our editorial content and, to an
extent, our advertising. For example, if a majority of survey respondents
express a preference for one TV show over another, then we might write an
entertainment piece based on that or factor it in when deciding which adverts
appear where.

We may also run some surveys for which we utilise your declared responses to
build into our profile about you. When we do so, this will be communicated in
the associated text, and you will be asked to either consent to this use or will
be given the option to ‘object’ via a tick box.

Occasionally, those surveys might ask you about things which the law considers
to be especially sensitive, such as your voting intentions or your religious
beliefs. Where that’s the case, we’ll ask clearly for your permission first, and
we’ll always provide a “prefer not to say” or similar option. We don’t use that
kind of information for advertising purposes.

7.1.  The data we collect and what we do with it

We will collect your answers to the survey questions and use them to compile
anonymous statistics along the lines of “35% of people preferred X over Y”. Some
surveys may also ask for your email address, for example if we are offering
entry into a prize draw for completing it. Go here to learn more about how we
use your data for prize draws. As highlighted above, we may also retain your
responses as part of a profile about you.

When you have completed a survey, you may be invited to subscribe to a
newsletter or to receive special offers and promotions from us.

Sometimes we may operate “panels” of people who we send survey questions to
periodically. If you join one of those panels then there may be additional kinds
of information about you which we will receive, in which case we will provide
further information to you before you sign up to the panel.

7.2.  Our legal basis

We collect and compile your survey answers on the basis of your consent, which
we ask for in each survey. Use of your declared data for profiling purposes will
be based either upon consent (via tick box) or our legitimate interest, for
which you will be given the option to ‘object’.

7.3.  How long we keep it for

We retain your survey responses for however long the survey runs for, and for up
to 90 days afterwards. The resulting statistics may be kept longer, but those
are always anonymous and don’t contain your personal data. Data utilised for
profiling will be retained for up to 3 years.

7.4.  Who we share it with and why

We typically publish the overall results of our surveys, and often share those
results with the brands involved (if any), but those results are always
anonymous and statistical in nature (“50% of respondents thought X”) and don’t
contain your personal data. Actual survey responses are only shared with the
service providers who provide us with the technology powering our systems. They
act as our “processors”, meaning that they are bound by law and contract to keep
your data safe, and to do only what we tell them to do with it.

7.5.  Whether we send it outside the country of collection

Our online form technology providers may process your personal data outside of
the UK and EEA. We have implemented safeguards to secure and limit the
processing of the data, including standard agreements approved by the relevant
authorities. 


Click here to go back to ‘Contents’

8.    When you subscribe to our print or “Digital Edition” titles

When you subscribe to one of our print titles, we will collect your name,
address other contact details, and payment information. We will use that
information to administer your subscription. We do this on the basis that it is
necessary in order to provide the subscription to you with the support of our
provider. We will retain this information for as long as you maintain your
subscription, and for a period thereafter, in case of disputes or problems.

When you subscribe to our digital edition titles your subscription is also
processed via our provider and this information is retained for as long as you
maintain your subscription, and for a period thereafter, in case of disputes or
problems.

As part of the subscription process you may be asked if you want to receive
other products or services from Reach. Where this is the case you will be asked
to consent to each product or service type. Such activities are managed in
accordance with the relevant sections elsewhere in this Privacy Notice.

Click here to go back to ‘Contents’

9.    When you place a classified ad

When you place a classified ad in one of our print titles, we will collect your
name and contact details, your payment information, and of course the content of
your ad. We will use that information to publish and administer your ad, and to
communicate with you about it. The content of your ad will be published and
therefore accessible to the public. We do this on the basis that it is necessary
to fulfil the contract agreed with you when you place your ad.

We will retain the contact details of private individuals for up to 6 years from
the point of last interaction, and trade contact details for as long as we have
a business purpose. We do not store personally identifiable payment card
information.

Your ad itself will be retained indefinitely, on the basis of our legitimate
interest, in order to maintain our archive and back issues services.

Click here to go back to ‘Contents’

10.   When you apply for a job with us

When you apply for a job with us, we will process the information you or the
recruitment agency gives to us in order to consider your application and to
communicate with you (or the agency) about it.

If we offer you a position and you accept it, then we will use your information
to liaise with you about start dates, contracts, arranging induction and so on,
and we may ask you for additional information to that end. That information will
then be handled in accordance with our internal HR policies and Employee Privacy
Notice.

If we don’t offer you a position or we do but you don’t accept it, then we will
keep your application on file for 12 months in case of future queries or issues.

We process your data on the basis that it is necessary in order to take steps to
enter into an employment contract with you. We process information relating to
unsuccessful applications or job offers that are not accepted on the basis of
our legitimate interest in keeping records of job applications.

Click here to go back to ‘Contents’

11.    When you work at other organisations that we do business with

For all of our customers and other organisations we do business with, we will
have the business contact details of the people we work with at those
organisations, and we will use them to manage and administer our relationship
with that organisation. We do this on the basis of our legitimate interest in
managing and administering those relationships.

If you work at a current or prospective advertising or publishing services
client or related agencies, revenue sharing partners (for the sale of your
products or services) or are users of Reach software we will also contact you
from time to time using your work contact details to promote our services. We
will have those contact details either because we have worked with you before,
you shared them with us for this purpose, because we or our agencies have looked
them up from publicly available information, or because you have attended an
event we have hosted. We do this on the basis of our legitimate interest in
promoting our advertising and publishing services to businesses. We will always
stop contacting you for this purpose if you ask us to. Typically, the best way
to do that is to respond to the person contacting you, but you can also make the
request by completing the relevant form Your rights and how to exercise them.


We keep the details of our contacts at organisations we do business with for as
long as we continue to have a business relationship, and for a period thereafter
for business development purposes and in case of issues or disputes.

Click here to go back to ‘Contents’

12. Site visits and CCTV at our premises

When you visit a Reach site we will record your name, the date, and in some
locations your company name. This information is retained for one week.

In some circumstances, non-employees may be provided with a site pass. Where
this applies, the personal data obtained, including a photograph of you, will be
retained for the duration of your visit or contract with Reach and for 7 years
thereafter for fraud, security, and financial reporting purposes.

We use CCTV systems at our premises on the basis of our legitimate interest in
protecting the safety and security of our staff and our property.

Click here to go back to ‘Contents’

13. Further data sharing by Reach

Further to the data sharing described elsewhere in this Privacy Notice, Reach
will disclose your information and co-operate with appropriate bodies and
authorities in good faith where we are required to by law, a court order, a
regulatory authority, or otherwise, including with the police, trading
standards, regulatory authorities, other relevant authorities, or credit
reference agencies.

Where permitted by applicable laws, where you interact with us, we may monitor,
record, and retain all associated data, correspondence, and communications, such
as written letters, telephone call recordings, emails, text messages, social
media messages, in person meetings and any other communications. We will do this
to, (i) comply with our legal and regulatory obligations, (ii) prevent, or
detect crime, (iii) maintain appropriate evidential records, (iv) protect the
security of our communications systems and (v) for training and quality
purposes. Where necessary, we will also use your personal information to defend
ourselves from any legal claims brought by you in connection with the provision
of our products and services.

We will also use personal information to manage and administer our business
generally.

We will share information with security consultants and IT security system
providers, where necessary, to monitor and manage data security and the security
of our sites and networks, and to develop security threat intelligence data.

We may also share information to facilitate the sale of one or more parts of our
business, including if we are approached by a potential buyer or the
restructuring of one or more parts of our business and with auditing
organisations such as the Audit Bureau of Circulation.

Click here to go back to ‘Contents’

14. Your rights and how to exercise them

The law gives you certain rights over your personal information.

You can exercise your rights by contacting our group Data Protection Officer’s
team through the use of the relevant forms provided below. It is helpful to be
as specific as possible about what you want us to do or what information you are
looking for, because it enables us to respond to you more quickly.

Depending on your request, we may ask you to prove your identity to us first, in
order to make sure that someone isn’t impersonating you. For example, if you
contact us about your Reach account using a different email address, we may
first require you to prove that you control the email address which you used to
set up the account. If you want information about a subscription or some other
paid service then we may ask you to provide the last four digits of the credit
card used to pay for it.

Most of your rights do have exceptions to them, designed to protect the rights
of others or to ensure that we can comply with the law and operate our business
in a prudent manner (for example, by keeping certain records). If we decline all
or part of your request on the basis of one or more of those exceptions, we will
tell you that we are doing so, and we will explain our reasons. We may also
reject your request entirely if it is excessive or unfounded.

14.1.   Your right to access the information we hold about you

You have the right to have access to the information we hold about you. There
are a few exceptions to that right, designed to protect the rights of other
people.

To exercise this right please use our right of access request form

14.2.   Your right to have inaccurate information about you rectified

If we hold information about you that is factually inaccurate (for example, we
have spelled your name wrong) then you have the right to have it corrected. This
right does not extend to matters of opinion; for example, moderation decisions
we might make about your comments on our websites.

To exercise this right please use our other rights request form.

14.3.    Your right to have your information erased in some circumstances

You may have the right to have some or all of your information deleted,
principally if the information you want deleted is no longer needed or if we
don’t have a legal basis to continue using it (for example, if we are using it
on the basis of your consent and you withdraw your consent).

To exercise this right please use our right to erasure request form.


14.4.     Your right to withdraw your consent

If we’re relying on your consent to do something with your information (for
example, to send you newsletters) then you have the right to withdraw that
consent at any time.

For newsletters and other email communications, you can do this by clicking the
“unsubscribe” link at the bottom of the message.

To withdraw your consent for how we are using your information, please use
our unsubscribe request form.


For targeted advertising on our websites, you can access the screen to do this
by clicking the “Privacy” tag with the ‘cog’ icon or link at the bottom of every
webpage to go to the Consent Management Platform (CMP).

For targeted advertising in our apps, you will be presented with the CMP on
initial download and whenever it is updated thereafter. You can also change your
CMP settings by navigating to ‘My Account’ at the bottom of the app screen and
clicking on ‘My Privacy’.

14.5.  Your right to object to what we do with your data, and to have
restrictions placed upon it

If we are doing something with your data not on the basis of your consent but on
the basis of our “legitimate interest”, then you have the right to object to
what we are doing, and we must stop unless we can show that there is a
compelling and legitimate reason to continue or what we are doing relates to a
legal claim. Activities such as fraud prevention will fall into that category.

In the case of direct marketing and profiling, your right to object is absolute.
Regardless of what other mechanisms we may make available, you can always object
by unsubscribing from marketing emails and by rejecting the use of cookies on
our websites (see the Privacy ‘cog’ or link at the bottom of every webpage).
When using our apps if you want to change the settings, go to the ‘My Account’
Link at the bottom of the screen which includes ‘My Privacy’ and takes you to
the Consent Management Platform (CMP).

To exercise this request please use our other rights request form.


14.6.  Your right to restrict what we do with your information in some
circumstances

In certain circumstances, you have the right to restrict our use of your
information to simply storing it and using it only for legal claims, protecting
the rights of others and matters of important public interest. Those
circumstances are: if you dispute the accuracy of information we hold about you;
if we do something unlawful with your information but you don’t want us to
delete it; if we don’t need the information anymore but you want us to preserve
it in connection with a legal claim; or for the duration of the period in which
we are considering a valid objection you have raised under your right to object
discussed above.

To exercise this right please use our other rights request form.

14.7.      Your right to portability


You have the right to receive the personal data concerning you which you have
provided to a controller in a portable electronic format, or have it transmitted
to another controller, where processing is based upon consent and undertaken by
automated means.

To exercise this right please use our other rights request form.


14.8.      How to Complain

If you have a complaint or disagree with a decision we have made, we ask that
you discuss it with us first by contacting the group Data Protection Officer
using our data protection complaints form or via the address given at the top of
this Privacy Notice.

You also have the right to complain to your data protection supervisory
authority.

In the UK this is the Information Commissioner’s Office:

The ICO’s contact information is:

Information Commissioner’s Office Wycliffe House Wilmslow Cheshire SK95AF

ICO website: https://ico.org.uk

Helpline Number: 0303 123 1113

In the Republic of Ireland, it is the Data Protection Commissioner:

21 Fitzwilliam Square South Dublin 2 D02 RD28 Ireland

https://www.dataprotection.ie

The phone number is 01 7650100 / 1800437 737

If you are based in another EU country, you can find the details of your local
supervising authority here.

Click here to go back to ‘Contents’

15.       Residents of California


Information provided in this section of the notice applies solely to residents
of California and their rights under the California Consumer Privacy Act of 2018
and related regulations (the “CCPA”). This section should be read in conjunction
with the rest of this notice which provides further details on the nature of our
data processing. Terminology and definitions in this section are reflective of
the CCPA.

As the CCPA uses the term “personal information” and not “personal data,” in
this section, for consistency with the CCPA, we are using the term “personal
information,” which has the meaning set forth in the CCPA.

15.1.   Notice of Collection

The table below provides a summary of the categories of your personal
information Reach may have collected, the sources of that data, the reasons for
collection and who we may have disclosed the data to over the last twelve
months. The information gathered in this table may apply to you in different
ways depending on how you have interacted with us.

Business Purpose for Disclosure

Business Purpose for Disclosure

Categories of Recipients of Disclosures

Do we sell this data?

Identifiers
such as name, email address, billing information, username, any provided phone
numbers, such as home, or mobile, online screen name, security questions and
password.

P1, P2, P3, P4, P5, P6, P7

D1, D2, D3, D4, D5, D6, D7, D8

No

Commercial Data
such as records of your purchases and transaction data.

P1, P2, P3, P4, P6, P7

D1, D2, D3, D6, D7, D8

No

Customer Records
such as financial or payment information to process payments and information
about your transactions and purchases with us.

P1, P7

D2, D6, D7, D8

No

Internet & electronic network activity information 
including, but not limited to browsing history, search history, and information
regarding interactions with an internet website, application, or advertisement,
including other usage data related to your use of any of our Services or other
online services. Please see our Cookie Notice for further information.

P1, P2, P3, P4, P5, P6, P7

D1, D2, D3, D4, D5, D6, D7, D8

Yes

Geolocation Data 
such as general location, and, if you provide permission, precise GPS location.

P1, P2, P3, P4, P6, P7

D1, D2, D3, D4, D5, D6, D7, D8

Yes

Sensory Data
such as audio recordings if you call our customer service or volunteer this
information as part of using our services and photographs in connection with
your social media account.

P1, P2, P5, P7

D1, D2, D6, D7, D8

No

Inference Data
including inferences drawn from any of the information identified above to
create a profile reflecting a consumer’s preferences, characteristics, behavior
or attitudes.

P1, P2, P3, P4, P6, P7

D1, D2, D3, D5, D6, D7, D8

No

 

15.2.   Notice of Collection: Key

Purposes

 * P1 - Performing services; including but not limited to customer service and
   related requests, processing orders or other transactions, managing and
   maintaining your account, marketing or advertorial services, analytics.

 * P2 - Analysis and improvement; reviewing our activities to enhance either
   services offered or improve commercial capabilities such as by improving the
   positioning or quality of our adverts and developing of new functionality and
   tools.

 * P3 - Commercial interests; including but not limited to the promotion of
   goods and services and to drive engagement, page views, subscriptions,
   registrations, purchases and similar.

 * P4 - Ephemeral; data processed in a transient manner and not retained by
   Reach.

 * P5 - Editorial; to support the production of editorial content across Reach
   titles.

 * P6 - Repairs; review of assets and management of debugging and other fixes to
   maintain and improve functionality.

 * P7 - Security, fraud and legal compliance; actions deemed necessary to
   protect and defend Reach assets against illegal, malicious and damaging
   activity.

Disclosures

 * D1 - Reach subsidiaries and affiliates; we may disclose information in order
   to deliver services in the ways described in this privacy notice. Marketing
   will only be sent to you where the necessary consent has been provided.

 * D2 - Service partners; we may disclose information where we work in
   partnership to provide you with products or services.

 * D3 - Commercial partners; we may disclose information with third parties to
   provide you with relevant content and advertising on websites and mobile apps
   where we have the necessary permissions to do so. We may also disclose
   information to enable you to receive marketing you have asked to receive.

 * D4 - Social media; we may disclose information with social media networks
   where we have the necessary permission to do so.

 * D5 - Analytics providers; we may disclose information with data analytic
   providers to review, evaluate and improve our services.

 * D6 - Security; we may disclose information where it is necessary to do so in
   order to protect the rights, assets, employees and customers of Reach.

 * D7 - Legal requirements; we may disclose information where necessary to
   comply with our legal obligations or if we believe it is required in relation
   to the investigation or prevention of suspected or actual illegal activity.

 * D8 - Business Development; we may disclose information for the purpose of
   business transfers, mergers, acquisitions, bankruptcy proceedings or similar.
   
   Sale of you data

 * The only data which may be sold is to advertising partners with whom we have
   a contractual agreement to limit usage to those online marketing related
   purposes agreed by you via Reach’s Consent Management Platform (CMP). The
   data types include an online identifier, URLs from Reach pages, a referrer
   identifier, and a truncated IP address.

15.3.   Sources of Personal Information.

In general, we may collect the categories of personal information identified in
the table above from the following categories of sources:

 * Directly from you and your devices.
 * Through your use of our services.
 * From third parties and service providers, including affiliates, commercial
   partners, social media networks, analytic providers, credit reference
   agencies.

15.4.   California Residents' Rights

Under the CCPA, California residents have the following rights (subject to
certain limitations):

 * To opt out of sales. The right to opt-out of our sale of their personal
   information.
 * Deletion. The right to the deletion of their personal information that we
   have collected, subject to certain exceptions.
 * To know/access. The right to know what personal information we have collected
   about them, including the categories of personal information, the categories
   of sources from which the personal information is collected, the business or
   commercial purpose for collecting, selling, or sharing personal information,
   the categories of third parties to whom we disclose personal information, and
   the specific pieces of personal information we have collected about them.
 * Non-discrimination. The right not to be subject to discriminatory treatment
   for exercising their rights under the CCPA.    

15.5.   Do Not Sell My Personal Information

California residents may opt out of the “sale” of their personal information. We
sell, as defined below, information to third parties to provide you with
opportunities that may be of interest to you.

Under the CCPA, a sale may include the disclosure of information such as cookies
and device or browser information to third parties. This enables you to be
served with more relevant and appropriate advertising content. Digital
advertising helps us to fund the news articles and content published on our
sites and enables us to provide some of our content for free.

Depending on what Services you use, we may provide the following categories of
personal information to third parties for these purposes:

 * For online targeted advertising purposes: demographic and statistical
   information, contact and registration information device information and
   identifiers, browser and usage data, geolocation, and social media
   information.

Reach does not knowingly sell the personal information of children under the age
of 16 without the necessary permissions as required by the CCPA.

You have the right under CCPA to opt out of these purposes by selecting the ‘Do
Not Sell My Personal Information’ link on our homepage. You may also submit a
request directly using the contact information provided elsewhere in this notice
within sections 1 and 14. We reserve the right to ask for evidence of your
residency in California before processing your request.

Please note that a ‘Do Not Sell My Personal Information’ request does not cover
information that has previously been disclosed to third parties for these
purposes and does not prevent the ongoing disclosure of data to our service
providers.

15.6.   Personal Information Access and Deletion

California residents wishing to exercise their right to access their personal
information or request that we delete it can do so using our rights requests
form in section 14.

We will take steps to verify your request by (i) sending you an email
confirmation to which you must respond to confirm your request; and (ii)
matching the information provided by you with the information we have in our
records. You must complete all required fields on our webform or otherwise
provide us with such information to verify your request. We will process your
request based upon the personal information in our records that is linked or
reasonably linkable to the information provided in your request. In some cases,
we may request additional information in order to verify your request or where
necessary to process your request. If we are unable to adequately verify a
request, we will notify the requestor.

15.7.   Authorized Agents

Authorized agents may initiate a request on behalf of another individual by
providing evidence of authority from the individual; authorized agents will be
required to provide proof of their authorization and we may also require that
the relevant consumer directly verify their identity and the authority of the
authorized agent.

15.8.   Shine The Light

California residents may request and obtain a list of any third parties that we
have disclosed personal information to over the previous calendar year for the
purposes of sending you direct marketing about the third party’s own products
and services. If you would like to request this information please contact us
using our  rights requests form in section 14.

15.9.   Financial Incentives

At this time, Reach does not offer any financial incentives for the provision of
personal information.

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16.    Nevada Residents

Reach does not currently sell your personal data, as defined by Nevada Law, for
monetary compensation to third parties for their own purposes. Nevada residents,
however, may request that we include their name on a do-not-sell list in the
event Reach were to do so in the future. Please email us
at dataprotection@reachplc.com if you want to place your name on the do not sell
list.

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17.  Privacy Notice last updated: 31/10/2022

We may update this privacy policy from time-to-time by posting a new version on
our websites. You should check this page occasionally to ensure you are happy
with any changes. Where changes are material, we may also notify you of them by
email.

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ABOUT US    

 * At a glance 
 * Our purpose 
 * Our brands
 * Our strategy


INVESTORS

 * Results and reports
 * Share price information
 * Corporate governance
 * Shareholder information


PRIVACY NOTES

 * CCTV Policy
 * Pension Scheme disclosure notices

 * Privacy Notice 
 * Cookie Notice 
 * Commissioning and purchasing terms
 * Sitemap 
 * Modern Slavery Statement 
 * Articles of Affiliates

Copyright (c) 2023 Reach PLC. All rights reserved 


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