One Media & Creative UK Ltd

PRIVACY POLICY: HOW WE USE YOUR INFORMATION


One Media & Creative UK Ltd is committed to protecting your privacy. We take great care to ensure your information is kept safe and secure. For the purpose of the data protection law the data controller will be One Media & Creative UK Ltd.


This policy explains how we will collect, store, use and share your personal information.


About us


We are One Media & Creative UK Ltd a specialist published of consumer and contract magazines and websites. Our titles include SO magazine, The Times of Tunbridge Wells, The Times of Tonbridge and TheKnow.guide.com

We are part of the Markerstudy Group of companies and we can be contacted at:

Salomons Estate

Tunbridge Wells

Kent

TN3 0TG



Explanation of some of the terms used

 

Data Controller – means the person or entity which alone or jointly with others determines the purposes and means of the processing of personal data

 

Data Protection Law – the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998/2018.


Markerstudy Group – details of the Markerstudy Group can be found at www.markerstudygroup.com/about

Sensitive Information – this is also known as Special Category Data and includes information revealing, or about a person’s racial or ethnic origin, political opinions or trade union membership, religious or philosophical beliefs, health, sex life or sexual orientation, or genetic data and biometric data for the purpose of uniquely identifying a natural person. Information about criminal convictions is often included in this definition.



Data Controller



For the purposes of the data protection law the data controller for the services we provide to you will be One Media & Creative UK Limited. We are registered with the ICO, registration number Z3256905



Data Protection Officer



We have appointed a Data Protection Officer to oversee our handling of personal information. Our Data Protection Officer can be reached at dataprotection@markerstudy.com.



Who do we collect information about?

We collect information about the following types of individuals:

  • Previous, current and prospective customers.
  • Users of the Markerstudy group websites including theknow.guide.com.
  • Members of Public
  • Correspondents
  • Freelance journalists and photojournalists
  • Competition & Award Entrants
  • Subscribers (Digital & Print)
  • Readers & Advertisers

Children

 

Our websites and our services are not intended for children and we do not intentionally solicit or collect personal information from individuals under the age of 13. If we are notified or otherwise discover that a minor’s personal information has been improperly collected, we will take all commercially reasonable steps to delete that information.



If information about or photographs of, a child under the age of 13 is recorded as part of an article then we will obtain the permission of the child’s guardian to use the information or photographs unless (i) the information is part of a court case or inquest or (ii) we are requested by ICE to name a child aged 13 or under.



When do we collect information about you?

We collect information about you:

  • When you (or a third party) contacts us (by phone, letter, email, through our website or otherwise).
  • When you complete surveys, fill in forms, participate in competitions (whether through our print or online media);
  • When you use our website: to register or subscribe to our services, place an order, participate in discussion boards or other social media functions on our website, leave any query or correspondence on our website, when you report a problem with our website or any other activity undertaken with the Markerstudy group;
  • As part of a news interview
  • As part of awards process
  • Via journalists (employed or freelance) and photojournalists
  • When you contact us to make a complaint.

What information do we collect about you?

The personal information that we collect will depend on your relationship with us.  We will collect different information depending on whether you are a customer, reader, subscriber, website user or third party.

If you provide personal information to us about other individuals you agree: (a) to inform the individual about the content of this Privacy Policy; and (b) to obtain any consent where we indicate that it is required for the processing of that individual’s personal data in accordance with this Privacy Policy.

Please click on the relevant section below for detailed information regarding the types of personal information we are likely to collect and use about you.

We collect and use details on the following:

Personal Information

  • General information such as your name, address, date of birth, car registration, nationality, job, email address and phone number.
  • Financial information such as credit card information
  • Photographs, Mobile and Video Footage
  • Personal Description
  • You and your personal circumstances when appropriate to article
  • We may collect information when you use our website including data that allows us to monitor your preferences and how you use our website. This helps us to organise our website content in order to improve your experience. The information we collect includes:
    • details of transactions you carry out through our website.
    • information that you provide by filling in forms on our website even if those forms are not submitted.
    • technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time).
    • products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  • We may use cookies to collect information about how our website is used. Please see our [cookies policy] for more information about our use of cookies.

Sensitive Personal Information

  • Details about your health, criminal convictions or prosecutions, political opinions, trade union membership, race and ethnicity, religious affiliation and your sex or sexual orientation but only if (i) this information is pertinent to the content of the article or (ii) it is captured due to the type of media used for example, photography or (iii) it is apparent from the content of the article or from your correspondence or on line discussions

How do we collect your information?

We collect personal information from a number of different sources including:

  • Directly from you or from someone else on your behalf;
  • From third parties (including journalists (including freelance), photojournalists, business partners, suppliers, advertising networks, analytics providers, search information providers).
  • Other publically available sources, including, but not limited to, social media;
  • From other companies in the Markerstudy Group;
  • Police, Schools and colleges, Local Government, NHS & Emergency Services;
  • Members of General Public.

What are the purposes for which information about you is used?

We may process your information for a number of different purposes. For each purpose we must have a legal ground for such processing. When the information that we process is classed as sensitive personal information, we must have an additional legal ground for such processing.

Whether you provide us with the information, or we collect information from you or we are provided with information from other sources, we may use this information:

a) News Articles and Advertorials (Including Blogs and online discussion boards )



Legal grounds:

Legitimate interest (see below)



Additional legal ground for sensitive personal information:

Either because you have provided us with your explicit consent (by submitting the information or opinion) or because we have a legitimate interest (see below)

b)Opinions/Letters Page


Legal grounds:

Legitimate interest (see below)



Additional legal ground for sensitive personal information:

Either because you have provided us with your explicit consent (by submitting the information or opinion) or because we have a legitimate interest (see below)

c) Awards Programme/Business Recognition



Legal grounds:

Our having an appropriate business need to use your information to manage the awards /business recognition programme  which does not overly prejudice you

To comply with legal obligations



Additional legal ground for sensitive personal information:

because you have provided us with your explicit consent by entering the awards /business recognition programme

To comply with legal obligations



Competition Entries



Legal grounds:

Our having an appropriate business need to use your information to manage the competitions which does not overly prejudice you


To comply with legal obligations


Additional legal ground for sensitive personal information:


because you have provided us with your explicit consent by entering the competition


To comply with legal obligations



d)    Weekly Newsletter including client offers



Legal grounds:

Legitimate interest or you have given your consent by having a subscription with us



Additional legal ground for sensitive personal information:

because you have provided us with your explicit consent by subscribing and responding to the offer



e)Communicating with you and resolving any complaints that you might have



Legal grounds:

Our having an appropriate business need to use your information to manage and respond to complaints which does not overly prejudice you



Additional legal ground for sensitive personal information:

Either because you have provided us with your explicit consent  or, because the use is necessary in order for us to establish, exercise or defend our legal rights



f)Recover outstanding payments



Legal grounds:

Our having an appropriate business need to use your information in order to recover debts which does not overly prejudice you



Additional legal ground for sensitive personal information:

The use is necessary in order for us to establish, exercise or defend our legal rights



g)    To measure the effectiveness of our advertising



Legal grounds:

Our having an appropriate business need to use your information to ensure our advertising is effective which does not overly prejudice you

h)    To notify you about changes to our services or products



Legal grounds:

Our having an appropriate business need to use your information to keep our customers up to date with changes to our products or services which does not overly prejudice you.



i)      To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes



Legal grounds:

Our having an appropriate business need to use your information to maintain our websites which does not overly prejudice you.



j)To transfer within the Markerstudy Group or to third parties for the purpose of conducting internet analytics.



Legal grounds:

Our having an appropriate business need to use your information to maintain our websites and undertake website analytics which does not overly prejudice you.



k)h) To measure the effectiveness of our advertising



Legal grounds:

Our having an appropriate business need to use your information to ensure our advertising is effective which does not overly prejudice you

l)To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes



Legal grounds:
Our having an appropriate business need to use your information to maintain our websites which does not overly prejudice you.



m)To transfer within the Markerstudy Group or to third parties for the purpose of conducting internet analytics.


Legal grounds:

Our having an appropriate business need to use your information to maintain our websites and undertake website analytics which does not overly prejudice you.



j)Providing improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers); technology may include voice analytics

 

Legal grounds:



we have a legitimate business need to provide secure and quality services



Our legitimate interests in processing personal data include:

  • to support a free press, including journalistic activities of societal importance;
  • to support individual and societal rights to receive information;
  • to develop, deliver and maintain relevant and engaging products services and advertising;
  • understanding when our audiences engage with us or other organisations;
  • to build a clearer understanding of who our audiences are in order to better serve them;
  • to carry on the business of a commercial organisation; and
  • to demonstrate that we provide services and products to agreed industry standards.

Who do we share the information we collect about you with?

Sharing within our Markerstudy Group


We may share your information within the Markerstudy Group for the following reasons:



  • Where you have given your explicit consent, for marketing purposes;
  • To administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • To improve our website, including as part of our efforts to keep our website safe and secure
  • For legal, financial reporting and regulatory purposes.



Sharing with third parties



We may also share your information with selected third parties, in order to offer services to you or to perform any necessary functions on our behalf.  This may include:



  • Third Party Administrators for example a competition administrator;
  • Statutory Bodies;
  • Journalists and Photographers;
  • Printers
  • Advertisers or third parties jointly engaged in a competition or award scheme
  • Archivists and historians



Disclosure of your personal information to a third party outside of the Markerstudy Group will only be made where the third party has agreed to keep your information strictly confidential and shall only be used for the specific purpose for which we provide it to them.



We may also share your information with:



  • Search engine operators who can assist us in the improvement of our website.
  • Prospective buyers, in the event that we sell any business or assets.
  • Regulators and other authorised bodies, whenever we are required to do so by law.
  • We believe that such disclosure is necessary in order to assist in the prevention or detection of any criminal action (including fraud) or is otherwise in the overriding public interest.



What is our approach to sending information overseas?



We do not send your data outside the European Economic Area (EEA) for processing and storage.



How long do we keep personal information for?



We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply with our legal and regulatory obligations.

In particular please note that our publications will be retained to provide a source of evidence and historical reference so any personal information contained in those publications will be stored for the foreseeable future.



Automated decision making 



We do not carry out automated decision making



What marketing activities do we carry out?



We may send you information about our products and services. We may send this information to you directly or via third parties such as search engine operators and marketing companies who may market to you.



If you are an existing customer, we will only contact you with such information about goods and services similar to those which were the subject of a previous arrangement that we had in place with you.



We can contact you to discuss awards schemes/ business recognition programme or in respect of any competitor you have entered



We are committed to only sending you marketing communications that you have clearly expressed an interested in receiving. If you have consented to receiving marketing communications from us, you may opt out at a later date. You also have a right at any time to ask us not to contact you for marketing purposes or disclose your details to other companies.



If you no longer wish to be contacted for marketing purposes, please send an email to:  dataprotection@markerstudy.com or contact us at: Data Protection Officer, 45 Westerham Road, Sevenoaks, Kent TN13 2QB or click the unsubscribe link on any email you receive from us.



Your rights



Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in the “How to Contact Us” section of this Privacy Policy.



Please note that in some cases we may not be able to comply with your request (e.g. we might not be able to delete your data) for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can’t comply with your request, we will tell you why.



Your rights include:



The right to access your personal information



You have the right to access a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests.



If you would like access to such information, please write to us at Data Protection Officer, 45 Westerham Road, Sevenoaks, Kent TN13 2QB. Alternatively, where you have made the request by electronic means, the information will be provided to you by electronic means where possible.



The right to rectification



We take reasonable steps to ensure that the personal information we hold about you is accurate and up to date. However, if you do not believe this is the case, you can ask us to update or amend it.



The right to erasure



In certain circumstances, you may ask us to erase your personal information.



The right to restriction of processing



In certain circumstances, you are entitled to ask us to stop using your personal information.



The right to data portability



In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice.



The right to object to marketing



You can ask us to stop sending you marketing messages at any time.



The right not to be subject to automated decision-making (including profiling)



You have a right not to be subject to a decision based solely on automated means.  Please note that personal information including sensitive personal information may be used in the context of auto-renewal of certain types of policies which involves automated decision making to determine what the cost of renewing the policy will be.  We will ask you when you purchase your policy if you would like to opt in to auto-renewal.  However, even if you opted in at this point, you have the right to opt out at any point.



The right to withdraw consent



For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information.



The right to lodge a complaint with the ICO



You have a right to complain to the Information Commissioner’s Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations.



More information can be found on the ICO’s website at: www.ico.org.uk/concerns.



Making a complaint will not affect any other legal rights or remedies that you have.



How we protect your information



We will treat all of your information in strict confidence and we will endeavour to take all reasonable steps to keep your personal information secure once it has been transferred to our systems.  We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, and data stored on our IT systems, the website(s) and associated databases



Changes to our Privacy Policy



We keep our Privacy Policy under review and it is updated periodically. For example, those changes may be due to government regulation, new technologies, or other developments in data protection laws or privacy generally. You should check our website periodically to view the most up-to-date Privacy Policy.



This Privacy Policy was last updated on: 15th May 2018.



How to Contact Us



Please contact us if you have any questions about our Privacy Policy or information we hold about you by email to dataprotection@markerstudy.com or write to: Data Protection Officer, 45 Westerham Road, Sevenoaks, Kent TN13 2QB.



Other websites



Our website may contain links to other websites.  This Privacy Policy only applies to our own website so when you link to other websites you should read their own privacy policies. If this policy conflicts with any written contract that we have with you then the written contract shall take precedence.



Complaints

If you have a complaint about how we use your information then please contact us at: Data Protection Officer, 45 Westerham Road, Sevenoaks, Kent TN13 2QB.



If you have a complaint about the way in which your data has been processed, you can contact the ICO at: www.ico.org.uk/concerns.

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