INTRODUCTION

Your privacy is important to The Irish Examiner and maintaining your trust is paramount to us. We are fully committed to keeping your personal information safe.

This privacy policy is intended to provide you with information about the personal information we collect and how that information is used and shared. 

We collect personal information about you when you access this website or other websites controlled by us or by a company within our group (including but not limited to The Irish Examiner, irishexaminer.com, The Echo, EchoLive.ie, The Irish Times, irishtimes.com, newsdelivery.ie, rewardingtimes.ie, myhome.ie, irishracing.com, top1000.ie, myantiques.ie, breakingnews.ie, recruitIreland.ie, the Laois Nationalist, Kildare Nationalist, Carlow Nationalist, Western People; Waterford News and Star, the Roscommon Herald, and radio stations Beat 102-103 and WLR FM), their websites, or when you use any of our products, applications or services (collectively our “Services”).

This document outlines our approach to compliance with the General Data Protection Regulation (GDPR) and all other relevant data-protection legislation. It also sets forth your privacy rights. Please take a moment to familiarise yourself with our privacy practices.

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.


Changes to this privacy policy
We may update this privacy policy from time to time. If we make any material changes, we will notify you prior to the changes taking effect by posting a notice on our websites.

CONTACTS

Who we are and how to contact us
Throughout this privacy policy, “we” “us” and “ours” refers to The Irish Times DAC and The Irish Times Group. The Irish Times DAC is a registered company with an address at of 24-28 Tara Street, Dublin 2, Ireland. We are the company that controls your data known as the “ data controller” under data protection law. The Irish Times Group means all fully consolidated subsidiaries under the management control of The Irish Times DAC. We can be contacted by email at services@irishtimes.com or by phone at +353-1-675 8000.

Data protection contact
We have appointed an internal data protection lead for you to contact if you have any questions regarding this privacy policy, our privacy practices or if you wish to exercise your data rights. They can be reached by email at dataprotection@examiner.ie or by phone at +353 21 4272722.We value your opinions. Should you have any questions or comments related to this privacy policy, please contact us at dataprotection@examiner.ie.

INFORMATION WE COLLECT AND HOW WE USE IT

We collect and use your personal information for a variety of reasons including:

IF YOU REGISTER, PURCHASE OR SUBSCRIBE TO ONE OF OUR SERVICES
To create an account with us:To purchase or subscribe to some of our Services, you will need to create an account with us.We will use your personal information to carry out our obligations arising from any contract you as our customer have entered into with us, including sending important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service. We may notify you by phone, post, email, SMS text or through other digital media depending on the content of the notification and your preferred contact mechanism.We will also use your personal information to provide you welcome emails to help you get the most out of the service, and reader rewards which may include competitions, events and other offers that are available to our subscribers.  If you cancel your subscription with us, we may use your personal information for direct marketing. We will only do so with your consent. We will generally send you direct marketing by email. We will use your information for a reasonable period of time, not exceeding five months, after your relationship with us has ended. Specifically, we will send you a short series of emails to remind you of the benefits of a subscription with us. You have the right to unsubscribe from receiving such communications from us by following the unsubscribe instructions included at the end of each email communication.  
To pay for the Services you have requested from us : We will collect your payment information to pay for any Services you have requested from us. Credit and debit card information is processed directly by PCI-compliant payment providers who perform payment services on our behalf. Occasionally, our employees receive payment information from customers over the phone. When this occurs, the payment information is entered as instructed into the relevant payment system and all other copies are deleted or destroyed immediately. 
To place an advertisement : We may process your personal information if you opt to place an advertisement. We only process this information to deliver the advertising service you have requested as per the terms and conditions you accept.

TO DELIVER MARKETING, PROMOTION AND TO CONDUCT MARKET RESEARCH 
 To receive marketing communications : We may periodically send promotional emails about features, events, exclusive offers and competitions to the email address you have provided – we will only do so with your consent. We have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing communications tailored to your interests. You may at any time choose not to receive marketing communications from us by following the unsubscribe instructions included at the end of each email communication. 
For competition and promotional purposes : We regularly run competitions or similar promotions. If you choose to enter a competition or promotion, we will use your personal information to administer these promotions and as per the terms and conditions you accept when you enter. In some cases, your competition entry may be shared with the promoter and this will be specified when you enter. If you win a competition, your contact information will be used to notify you as the winner and to award the relevant prize. We will publish your name on our website and indicate the prize you have won. 
To participate in a survey or poll : We conduct surveys and polls that we use to produce original research from our readers. Your participation is entirely voluntary. You may consent to the Irish Examiner contacting you at the email address provided to participate in this research. We do not track individuals but look at the information in the aggregate. Any opinion you express, therefore, is anonymous.From time to time, upon completing a survey or poll, we may ask for your email address for competition, promotional or gifting purposes. Participation is entirely voluntary and this information is processed and stored separately from the information you provide us for the survey or poll. Where you provide this information to us, it will be processed only to administer the competition or promotion.

TO DELIVER OUR CONTENT TO YOU
 To provide you with an email newsletter : We offer a number of email newsletters. We will only send you these newsletters with your explicit consent. We collect and use your information to send you the newsletter(s) you have requested and in some cases to personalise the email we send. You can opt out at any time by unsubscribing at the bottom of each email newsletter communication. 
To share our content : We provide tools that enable users of our services to share or forward our content to a nominated email address. If someone else shares our content with you, we may temporarily collect your email address for the purpose of sharing the requested content. We will only use this information to fulfil the sharing request and this contact information is not retained by us. By providing us with your email address, the third party that initiates the sharing request indicates they have your consent to share our content with you.

TO UNDERSTAND HOW YOU USE OUR SERVICES
To track how you gain access to or read our content : We collect information relating to your use of our services to track how you gain access to or read our content. We use cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services as follows:

• When you sign up for or subscribe to one of our services, we will track and aggregate non-personal information previously collected about you through our services with the personal information provided when you register or subscribe. If we link other data with your personal information we will treat that linked data as personal information for as long as it remains combined. We use this information to evaluate your personal preferences and interests, which under the GDPR may constitute as customer profiling. We do so in pursuit of our legitimate interests which are:
  • To research and improve the Irish Examiner’s products, services, and customer communications.
  • To understand which content you find useful or interesting
  • To develop and maintain relationships with our customers and readers
  • To deliver relevant content to our readers
  • To understand the demographics of our customers and readers
• You have the right to object to this processing, and if you wish to do so please manage your preferences Cookie settings.
  
  
• We log technical information that your browser sends us including: the internet protocol (IP) address; browser type and version; time-zone setting; access time; browser plug-in types and versions; operating system; and platform and device type.
  
  
• We log usage information about the use of our website and services, including: a history of the pages viewed and other actions taken, including the full Uniform Resource Locators (URL) clickstream to, through and from our site; articles, content and products 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 and any phone number used to call our customer service number.
  
  
• Technical information, including: the type of mobile device used; unique mobile identifies, such as the devices IMEI number; mobile network information; the mobile operating system; the type of mobile browser used; and the time-zone setting.
  
  
• Details of our mobile applications used including but not limited to: traffic data; location data; weblogs; and other communication data and the resources accessed
  

We use cookies and similar technologies to facilitate our Services in the retrieving of your user preferences; for the operation of our website; to collect statistical information about our visitors for analytical purposes (we use Google analytics and Comscore); to simplify any sign-in procedures; and to provide social media features.For more information on the use of cookies and similar technologies, please see our Cookie Policy.

 To measure the effectiveness of our email communications : We use such technologies to determine whether you’ve opened an email communication from us or clicked on a link contained in an email. Collecting information in this manner allows us to gather statistics about the usage and effectiveness of our services and products, including our email newsletters and direct marketing communications, in our legitimate interest.

TO SUPPORT OUR ADVERTISING SERVICES
Third-party vendors, including Google, display advertising on our Services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site or other sites. This type of behavioural advertising is targeted towards groups of users in an anonymous and aggregated manner as opposed to you as an individual. Such online advertising helps support the content, products and services we provide.

The third-party vendors (such as advertising networks) use third-party cookies together to inform, optimise and serve ads based on your browsing activities and interests. When you visit our Site, your browser redirects to the third party vendor and information is transmitted from your browser to this third party vendor. 

Advertising networks may use cookies and similar technologies to track you in order to measure the effectiveness of the ads they serve, detect fraudulent traffic, or to create a browsing profile that is used to deliver more relevant ads. These cookies are only set with your consent. For more information on how to manage advertising cookies please visit our Cookie Policy.

EMBEDDED CONTENT 
Sometimes we use image, videos and content from other sites on our site. These third party sites may set cookies when you access such content. We have no control over the information they collect or how they use this information. You should review the privacy policies of these third parties before accessing any such content. 

TO DELIVER RECRUITMENT SERVICES TO YOU
If you apply for a job within The Irish Times Group, you may provide us with certain personal information about yourself. We will use this information for the purpose of processing and responding to your application, to assess your suitability as a potential candidate and for current and future career opportunities.

TO ATTEND ONE OF OUR EVENTS
We host many events throughout the year. These include but are not limited to breakfast briefings, live content events, live lectures, podcast recordings, training, conferences and seminars.

If you register for one of our events, we will collect personal information from you. We will use your information to register for the event, process your payment and provide you with information and services associated with the event. In some cases, we make audio or video recordings of these events and we may record information about you as a consequence. We will always inform you in advance if the event is being recorded so that you can choose not to participate if wish. Registration for our events is voluntary. Once you register, however, we process your personal information as per the terms and conditions of that specific event and on the lawful processing ground of contract.

OTHER
To monitor our premises with CCTV camera surveillance : Our premises at Linn Dubh, Assumption Road, Blackpool, Cork (T23 RCH6), are monitored by CCTV security cameras. We may record personal information about you if you visit our offices or walk in close proximity to our business premises.

CCTV notices are on display outside our building to inform you of our practices and to give you advance notice of any recording. 

We are processing CCTV video surveillance data generally without your consent in pursuit of our legitimate interests to protect the rights, property and safety of The Irish Times DAC and the rights, property and safety of our employees or others.

The CCTV surveillance information we collect may be shared with An Garda Síochána or other third parties where we are required to do so by law. 

To correspond with you : If you correspond with us, we will use your contact information to respond to your enquiry. We process this information in pursuit of our legitimate interests to develop and maintain relationships with our customers and readers.
To manage our everyday business needs : We may use your personal information to manage our every business needs, including for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention in our legitimate interest. Our legitimate interest is the effective management of our business.
To verify your identity : To exercise your data rights, we may need to collect additional personal information from you to verify your identify and to process your request.
When you provide professional services to us : You may provide us with your personal information if you provide professional services to us. We process this information so we can administer, manage and pay for the relevant services you provide and as per the terms and conditions of our contract.

ANONYMOUS INFORMATION WE PROCESS
We process data in a form that does not, on its own, permit direct association with any specific individual and therefore cannot be reasonably used to identify or contact you. Aggregated and anonymous data is considered non-personal information for the purposes of this privacy policy.

THE LEGAL BASIS FOR PROCESSING YOUR INFORMATION

We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.

TO ENTER INTO AND PERFORM A CONTRACT WITH YOU
We use your personal information to carry out our obligations arising from any contracts entered into between you and us or to take the necessary steps at your request prior to entering into a contract with us including:

• To provide you with the subscription, services or products you have requested
• To process your payment information
  
• To authenticate and verify your account
  
• To provide customer and technical support
  
• To administer competitions or similar promotions
  
• To provide our recruitment services to you when requested
  
• To pay for the services you may professional provide to us
  
• To send important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service
  

WITH YOUR CONSENT, WHICH CAN BE WITHDRAWN AT ANY TIME
We will, in certain circumstances, rely on your explicit consent to process your personal information. Where we do, you have the right to withdraw your consent at any time. In most circumstances, your consent can be withdrawn by following the unsubscribe instructions included at the end of each email communication from us, or, with respect to cookies, at this link settings. You can also contact us at dataprotection@examiner.ie and we will be happy to facilitate your request.

TO COMPLY WITH OUR LEGAL OBLIGATIONS
We may be required to process your personal information to comply with certain legal obligations to which we are subject, including:

• Providing information to an Garda Síochána, the Revenue Commissioners or other Government bodies or agencies when required to do so by law
  
• If you have exercised one of your data rights, we will retain a copy of all correspondence to demonstrate our compliance with data-protection legislation
  
• If you have exercised one of your data rights and ask us not to contact you by email at a particular email address, we will need to retain a copy of that email address in order to comply with your no-contact request
  
• To carry out our statutory audit
  

PROCESSING BASED ON OUR LEGITIMATE INTERESTS
We process your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. Our legitimate business interests do not automatically override your interests. You have the right, free of charge, to object to our use of your personal information for our legitimate interests. If you wish to do so contact us at dataprotection@examiner.ie. Please bear in mind that if you do object, this may affect our ability to carry out certain tasks for your benefit.

Where you object to our use of your personal information for our legitimate interests, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so. We will always ensure there is a fair balance between our legitimate interests and your fundamental right and freedoms.

We process personal information for the following legitimate business purposes:

• To manage our everyday business needs and for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention
  
• To understand which content you find useful or interesting
  
• To support our advertising services
  
• To determine the effectiveness of promotional campaigns, email campaigns and advertising
  
• To research and improve the Irish Examiner’s products, services, and customer communications
  
• To ensure content from our site and mobile applications is presented in the most effective manner for you and for your device
  
• To develop and maintain relationships with our customers and readers
  
• To better understand and improve the usability, performance, and effectiveness of our Services
  
• To protect you against fraud and to detect, prevent, investigate security or technical issues to ensure our Services are secure
  
• To protect the rights, property and safety of The Irish Times DAC or the rights, property or safety of our employees or others
  
• To understand the demographics of our customers and readers
  

PROCESSING FOR JOURNALISTIC PURPOSES
As a news publishing organisation, the Irish Examiner processes personal data for the purpose of exercising the right to freedom of expression and information and for journalistic purposes.

This processing is exempt from compliance with certain obligations of the GDPR.

• We may process your personal information for journalistic purposes where you submit content to be published online and in our printed publications
  
• Where you have voluntarily contributed your experience to us and we publish this information
  
• If we publish a letter you have written to the Editor
  

WHEN AND HOW YOUR INFORMATION IS SHARED

WITHIN OUR GROUP
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries and use it in a manner that is consistent with this privacy policy. 

BUNDLE SUBSCRIPTIONS
We may share your personal information with any member of our group if the service you have requested is fulfilled by them. For example, where subscriptions are offered as part of a bundle, if the digital access is provided by a member of our group, we will share your personal information to fulfil the services you have requested.

WITH THIRD PARTIES
We may share your personal information with third parties for a number of reasons as outlined below. We do not sell your personal information to anyone and only share it with third parties who are facilitating the delivery or fulfilment of our services and or are working on our behalf. We contractually require that our suppliers protect such information from unauthorised access, use, and disclosure.

THIRD-PARTY SERVICE PROVIDERS
We may share your personal information with third-party service providers which perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, payment providers, lawyers, providers of security and administration services and other business advisers.

THIRD-PARTY SERVICE PARTNERS
We provide certain services and run promotions in conjunction with third parties and we may share your personal information if the service you have requested is fulfilled by them. These third parties have their own security and privacy policies. You are advised to review these separately.

THIRD-PARTY DATA-CONTROLLERS
We may share your personal information with third parties that may receive and process your personal information as a data controller in their own right. In the context of delivering an order or product to your address, we will share your shipping information with our delivery partners who will use it for the purposes of picking up, delivering and tracking your shipment. Our delivery partners may further use this information to plan delivery routes, to optimise and improve transportation operations and to enhance route and network planning tools such as maps, etc. As such, these third parties act as a data controller in their own right in respect of any shipping information that they hold. You can obtain more information about the delivery partners we use, how they process and treat your personal information and how to exercise your data rights by contacting us at dataprotection@examiner.ie

THIRD-PARTY ADVERTISERS
We disclose non-personally identifiable anonymous information to third-party advertisers to help them reach the kind of audience they want to target. We share summary aggregate reports for our advertisers to measure the effectiveness of the ads they have served. These advertising parties may combine the information we send with other information that you’ve provided to them or that they’ve collected from your use of their services.

INDEPENDENT AUDITORS
We may share your personal data with a third-party auditing organisation (ABC) in accordance with our legitimate interests to verify aggregated statistics about circulation and usage of our products or to review our policies, processes and procedures for compliance with relevant standards.

SOCIAL NETWORKING SITES
Our website and mobile applications use interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to like or share information from our sites through these services, you should review the privacy policy of that service.

DATA STORAGE AND RETENTION

We will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information no longer than is necessary to comply with our business and legal obligations. Where we enter into a legal contract with you, we will hold your personal information for a period of seven years from the date of completion of this contract by reference to the statute of limitation for a legal claim under contract.

CONSEQUENCES OF NOT PROVIDING INFORMATION

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

YOUR DATA RIGHTS

You have several rights under data-protection law in relation to how we use your personal information. You have the right, free of charge, to: 

• Request a copy of the personal information we hold about you in a structured, commonly used and machine readable format
  
• Rectify any inaccurate personal information we hold about you
  
• Withdraw your consent where we have relied upon your consent to process your information
  
• Erase the personal information we hold about you subject to certain exceptions
  
• If technically feasible, have your personal information transmitted to another data controller in a machine readable format at your request
  
• Restrict processing of your personal information in certain circumstances
  
• Object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes
  
• Not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature.
  
• Lodge a complaint with the appropriate data-protection authority if you have concerns about how we process your personal data
  

These rights are in some circumstances limited by data-protection legislation. If you wish to exercise any of these rights please fill out this form, or contact us at dataprotection@examiner.ie. We will take measures to verify your identify which we will do by reference to copies of acceptable identification documentation supplied by you.

We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.

INTERNATIONAL TRANSFERS

We may transfer your personal data outside the European Economic Area (EEA). These countries do not always afford an equivalent level of privacy protection and in such circumstances we take specific steps, in accordance with data protection law to protect your personal information. In particular, for transfers of personal data outside the EEA we rely either on an adequacy decision by the European Commission or on contractual protection approved by the European Commission.