This
privacy policy is effective as and from Oct 5, 2020
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.
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.
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:
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.
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:
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
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:
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:
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.
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.
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.
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.
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:
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.
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.