- Introduction
- About Us
- Collection of Information
- Our Legal Bases for Using Personal Information
- How We Use and Share Personal Information
- Access & Control of Your Information
- Retention of Personal Information
- Cookies and Similar Technologies
- What Cookies Do We Use and Why?
- How We Use Cookies and Similar Technologies
- Managing Cookies
- Changes to This Policy
- Privacy Tools
- Contact Us
Introduction
This Privacy and Cookie Policy explains how we collect, use, share, disclose or otherwise process personal information we hold about you. Understanding what our audiences prefer allows us to personalize content, show relevant adverts, and generally improve your experience of our products and services.
About Us
lemurreport.com (“we” or “us”) will collect, use, share and disclose or otherwise process your personal information in line with this Policy. The relevant data controller for your data will depend on which product or service you have interacted with or to which title you have subscribed as set out below. We respect the privacy rights of our users and are strongly committed to protecting your privacy. This Privacy Policy applies to this website, any newsletters subscribed to via this website, as well as information collected and provided to us when you enter the website.
Collection of information
Registration, forums, apps and your dealings with us
We collect information about you when you provide it to us; for example, when you fill out our online forms, subscribe to one of our titles, enter a competition being run on our website, respond to our promotions, comment, engage or participate in website discussion.
Information from devices
We also collect information automatically when you interact with our websites or use our apps. This can include information about the device and the device’s general geographic location. This can be to provide services that have copyright restrictions or to deliver content that is relevant to where you are. We may also collect information from cookies placed on your device. See the section on Cookies for more information about our use of cookies. With your consent, we may also collect the specific location of your device or request access to data from other applications to provide certain services you have requested.
Social login
If you log in to our websites or online services through a third party site, such as Facebook, that site may pass information to us, such as user ID, name associated with the ID, email address and location, plus other information permitted under the privacy policy for that website. Our websites and apps may also return information about you to that social networking site regarding your usage, such as which website pages you visited and your use of the social media services on the website.
If you log in with or connect to your account using social media (Facebook, Twitter, etc), the social media service’s use of the shared information will be governed by their privacy policy. If you do not want your personal information shared in this way, please do not participate in social sharing on our website.
Posts, comments and interaction
If you interact, for example by using polls, comments, text messages, video, or email, we may display this content indefinitely in any relevant context, subject to our editorial judgment and your rights as set out in this Policy. This may be anonymized in the case of testimonials or customer service conversations.
If you take part in any reader or listener forums, or send us letters for publication, then you may be identifiable to others publicly and your comments attributed to you.
Public information and posts
Any information about yourself or others that you post on our social media pages, on platforms like Twitter, Facebook and other chat rooms, blogs and forums, will be viewed by other people (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in such public areas, and you acknowledge that this may be collected and used by third parties.
Ad delivery
When you visit our website, advertising networks and other intermediaries select and then display ads on your device.
These companies, generally collect information from your device to help select ads that they believe are more relevant to you. They also use this information to tell advertisers that the ads have been delivered and seen. You can find out more in the Cookies section of this Policy.
Our Legal Bases for Using Personal Information
All organisations need a legal reason to use your personal information. If they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. Below are the most relevant grounds you should be aware of.
With your consent
There are some activities where we process personal information with your consent. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. However, if you opt-out or withdraw consent, we may not be able to provide the product or service you have requested.
To enter into and fulfill a contract
We also process your personal information in order to fulfill a contract we have with you. For example, we would use your information to provide you with access to your digital subscription or other products you have signed up for or to provide a prize to which you are entitled.
For a legitimate interest
We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else.
We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between our legitimate interests and your privacy rights.
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 organizations;
- to build a clearer understanding of who our audiences are in order to better serve them;
- to carry on the business of a commercial organization; and
- to demonstrate that we provide services and products to agreed industry standards.
To comply with legal obligations
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This may include publishing information about prize winners, for example.
To provide products and services and improve the experience
How We Use and Share Personal Information
We will use your information to provide you with products and services and to manage our relationship with you, including allowing you to interact, comment, and generally engage with our content.
We may use your information to monitor, improve and protect our products, content, services, and websites, both online and offline. We may also provide you with help and support where we believe it is required. For example, if you have contacted us and provided your contact information, we may contact you with a relevant reply.
To personalize content and ads
We sometimes make assumptions about your interests based on the way you interact with our website and the information we hold about you.
Knowing these preferences also allows us to understand the products, content, and services our customers like, letting us focus our efforts on developing those areas. We may also use this information to make decisions about what ads to show you.
“Do Not Track” browser settings
If you choose to turn on Do Not Track setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to request that they stop tracking your activity. Currently, our website is not designed to respond to “Do Not Track” signals.
To conduct market research and perform analytics
We may use your information to conduct market research to improve the services we offer and to develop new products and services. You will be able to opt-out of receiving market research surveys by following the instructions in the communication.
You may also be asked if you would like to join our audience panels to help us improve our products and services. We value your participation and you will always have the choice to opt-out of these panels.
To gain audience insights
We may provide our partners with information about the effectiveness and reach of advertising campaigns that they have planned or carried out. This information will not identify you directly without your consent.
For example, we may tell advertisers how many customers their ads can reach based on criteria they select (such as “45-year-old women who live in Toronto”) or how many times an ad was viewed.
If you would prefer not to have your information used for audience insights, please email [email protected].
To detect ad blockers
When you visit our sites we may check (using cookies, code, script or other technical means) to see if you have an ad blocker installed on your device or if your internet browser settings allow adverts or not.
If we detect that your device or internet browser is using an ad blocker, we may ask you to “whitelist”, trust or pause blocking adverts while you visit our websites or apps. You can do this easily in your browser settings or within the ad blocker itself. If you continue to use an ad blocker this may have an impact on the content you are able to see on our website.
Information about your use of ad blockers may be stored or associated with your device (including through the use of cookies) to re-insert advertisements on our websites and to understand how our customers use ad blockers. The advertisements that are re-inserted may include those from ad blockers’ “whitelists” or that promote our own products and services.
To allow third-party advertising
In some instances, targeted advertising may be displayed on our website by third parties using our platforms. These third-party ads may collect and use your personal information, which is outside of our control. This targeting may be caused by cookies already in place on your device. More general information on cookies can be found in the Cookies section of this Policy.
To provide co-branded services and features
We may offer co-branded services or features, such as competitions or other promotions, together with a third party and may share the information you provide with that third party where we have your consent. These co-branded services may be hosted by us or by the third party. In these instances, the third party may also be a data controller for your information. In this case, the third party’s use of your information will be governed by their privacy policy, which you should always read.
To disclose your information as permitted by law
Your information may be disclosed where we are permitted by law to do so, for example where we get police requests or regulatory inquiries. We may also disclose your personal information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
To ensure our services are used appropriately
If you post or send offensive or objectionable content, or otherwise engage in disruptive behavior anywhere on or to our website, we may use your information to stop such behavior. This may involve informing and responding to relevant third parties such as law enforcement agencies about the content and your behavior.
As part of the sale of our business
If we sell part or all of our business, customer information may be one of the transferred business assets. If this happens, your information may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business for the purposes set out in this Policy and to ensure continuity of your selected services.
To ensure that our products and services conform to agreed industry standards
We may share your information with auditors for the purposes of verifying that we comply with relevant standards. For example, we may ask third-party auditors to assess our compliance with information security and Privacy by Design best practice. This may require them to access your information in our systems.
Linked services
Our services may be linked to websites and apps operated by third-party companies and may carry advertisements or offer content developed and maintained by unaffiliated companies. We are not responsible for the privacy practices of these companies, and once you leave our website you should check the applicable privacy policy of the other service.
Access & Control of Your Information
Withdrawing consent for processing
Where we may rely on your consent to process personal information, you have the right to withdraw that consent at any time. Often, this can be managed through the preference center – such as your consent for us to send you communications. Otherwise, please contact us at [email protected] with details of your request. In some instances, we may still have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent we may not be able to provide the product or service you have requested.
Other rights
You may also have the right to object, erase, or restrict our processing of your information – for example, where we process personal data because this is in our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data.
To exercise any of these rights, please contact us at [email protected]. These rights may be restricted by law, for example, we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.
Retention of Personal Information
We will retain your information for as long as necessary for the uses set out in this Policy, or while there is a legitimate reason for doing so. If you ask us to delete your information before that time, we may not be able to do so due to technical, legal, regulatory or contractual constraints.
Cookies and Similar Technologies
Introduction
Most websites you visit will use cookies in order to improve your user experience by enabling that website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’).
Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Cookies make the interaction between you and the website faster and easier. If a website doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the site – for example, when you enter your login details and move to another page it won’t recognize you and it won’t be able to keep you logged in.
Some websites will also use cookies to enable them to target their advertising or marketing messages based for example, on your location and/or browsing habits.
What are Cookies?
A cookie is a text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket.
Our legal bases for cookies and similar technologies
Placing cookies: in order to place cookies, tags and other technologies on your browser or device, we need to have your permission. We do this by providing a clear notice in the form of a cookie banner that tells you what cookies are used for, as well as providing you with useful information about the technologies we use and a link to this Policy. You’ll need to indicate your acceptance of our use of cookies. You are able to opt-out of the use of cookies. For more information, see the section on Managing Cookies.
Using information collected from cookies: where we want to use the information that cookies and similar technologies collect, we either need your consent or a legitimate interest. In practice, it will not always be practical to get opt-in consent as doing so with cookie banners and pop-ups would disrupt your use and enjoyment of our sites and content. This is why we usually rely on our legitimate interests to use the data collected by cookies. To do this we conduct an assessment to make sure the purposes for which we use your data are fair and that your privacy rights are considered. We only rely on legitimate interests where your rights do not override our interests in using the data.
For more information about your rights in relation to legitimate interests, please see the section on Access and Control.
What Cookies Do We Use and Why?
Analytics cookies and similar technologies
These collect information about your use of our websites and apps, and enable us to improve the way they work. For example, analytics cookies show us which are the most frequently visited pages on our website, allowing us to provide the most popular news articles further up the page. They help us record how you interact with our website, such as how you navigate around pages and from page to page, identifying improvements we can make to the customer journey. They also help identify any difficulties you have accessing our services, so we can fix any problems. Additionally, these cookies allow us to see overall patterns of usage at an aggregated level.
We may place cookies and similar technologies on behalf of comScore who help us measure the size and quality of our audiences across platforms. You can learn more and control how comScore uses your information here http://www.scorecardresearch.com/preferences.aspx.
Functional/preference cookies and similar technologies
These cookies collect information about your choices and preferences and allow us to remember things like language, and location, so we can show you relevant content to where you are. They allow us to customize the services you have accessed. We also use these cookies to provide you with services such as video content.
Tracking, advertising cookies and similar technologies
We use these types of technologies to provide advertisements that we think may be more relevant to your interests. This can be done by delivering online ads based on your previous web browsing activity, known as “online behavioral advertising” (OBA). Cookies are placed on your browser which will remember the websites you have visited. Ads based on what you have been looking at are then displayed to you when you visit websites which use the same advertising networks.
For example, you may be doing online research to buy a book, and read several articles about relevant books on various websites. As you browse those sites a cookie from an advertising network would be placed in your browser. It would remember that you had visited several websites related to reading. Then, when you visited another website in the same advertising network, the website could show you an ad related to books and or reading.
We may also use cookies and similar technologies to provide you with ads based on your location, offers you click on, and other similar interactions with our website.
To help us deliver relevant advertising using cookies, we use Google Double Click. You can find out more about Google Double Click here.
We may also use the Google Analytics tool to track overall browsing patterns on the website. For instance, it helps us identify the most popular pages on the website, find out which links are being clicked on, and to give us broad demographics about from where users are accessing the site. We cannot personally identify users with these cookies.
The five Google Analytics cookies are called utma, utmb, utmc, utmv and utmz. They track how often the website is visited, when you enter and leave the site, and which site you visited that lead you to our website. utmz also tracks any keywords you entered into a search engine that lead you to our website, if appropriate.
Web beacons and tracking pixels
These are bits of data that count the number of users who access a website or webpage and can also allow us to see if a cookie has been activated. Web beacons used on web pages or in emails allow us to see how successful an article has been, or whether an email message was successfully delivered and read in a marketing campaign. Web beacons are also used to verify any clicks through to links or advertisements contained in emails. We may use this information to help us identify which emails are more interesting to you and to inform advertisers how many customers have clicked on their ads (the information shared with advertisers is aggregated and does not identify you individually).
Flash cookies
We may, in certain situations, use Adobe Flash Player to deliver special content, such as video clips or animation. To improve your user experience, Local Shared Objects (commonly known as Flash cookies) are used to provide functions such as remembering your settings and preferences. Flash cookies are stored on your device, but they are managed through an interface different from the one provided by your web browser.
Tracking URLs
Tracking URLs are a special web link that allows us to measure when a link is clicked on. They are used to help us measure the effectiveness of campaigns and advertising and the popularity of articles that are read.
Device fingerprinting
We may collect and analyses a device’s browser information to help identify that device, present content correctly, conduct analytics and help prevent and detect fraud.
If you access our services from a mobile device
We may collect a unique device identifier assigned to that device, geo-location data, and other transactional information for that device. We may also use the unique identifier to validate free trials, for example.
How We Use Cookies and Similar Technologies
As well as the uses already identified above, we use cookies and similar technologies to:
Protect our website
Cookies and similar technologies help us identify and prevent threats to our website. They are necessary to protect your information and our business from outside threats.
Allow you to access our services
Cookies and similar technologies permit your connection to our website: our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, other software or hardware information, and your geographic location.
Assess usage of services
We use information about your usage of our website, such as pages you have visited, content you have viewed, search queries you have run, and advertisements you have seen or interacted with to assess how our services are used.
Provide eCommerce functionality
Cookies and similar technologies help us provide functionality that you need to navigate our sites, select products and services and purchase them.
Provide relevant content
The content on our website and in our communications with you may be adjusted depending on what we know about the content, products and services that you may like. This means we can highlight content and articles that we believe will be of interest to you. We provide personalization by using cookies, IP addresses, web beacons, URL tracking and mobile app settings.
Sell third-party advertising
We sell space on our website and apps to advertisers. The ads they display on our website will often contain cookies. Our advertisers may use cookies or similar technologies to provide you with advertisements that they believe are relevant. They may use browsing data obtained to restrict the number of times you see particular ads (frequency capping). You may also see ads from these advertisers on other websites you visit.
Third parties that support our services by serving advertisements or providing other services, such as allowing you to share content or tracking aggregate service usage, may also use cookies and other technologies to collect information relevant to the provision of those services.
We do not control third party cookies or other technologies. Their use is governed by the privacy policies of third parties using such technologies. You should make sure you are aware of how third parties will use cookies by checking the third party’s cookie policy.
We use third-party advertising companies to serve ads when you visit our Web site. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see: http://www.networkadvertising.org/managing/opt_out.asp
To learn more about controlling cookies and similar technologies, please see the section below on Managing Cookies.
Managing Cookies
Below you will find useful information about how to manage the use of cookies on our website. If you have any questions, please contact [email protected].
Our partners
When you visit our website, our partners may set cookies and similar technologies on your browser in order to help us make the site work, analyses site usage, deliver ads and personalize your experience. Where these partners are acting on our behalf, they are called data processors and must only act on our instructions. We will have a contract with them and they must protect your information properly. They’ll use your information in accordance with this Cookie Policy and you’ll be able to opt-out.
Where other partners are placing cookies and similar technologies for their own purposes, they are called data controllers and will use your information for their own purposes.
When you visit our website you’ll see notices about the use of cookies by us and our partners. You’ll be able to learn more about the specific cookies in use and how to control them. By using our website, you understand that cookies and similar technologies are used and acknowledge that by continuing to use the website, you consent to their placement.
In the future, we plan to release improved controls to allow you to choose which partners can collect and use your information.
Most modern browsers are set to accept cookies by default, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser.
Controlling OBA cookies
In addition to being able to control cookies by changing the settings in your browser on your computer, or in your mobile device’s settings, you can also control which companies can set cookies and similar technologies on your devices, by visiting the following links (you’ll need to turn any cookie or ad blockers off for the control pages to show which companies you can opt-out of):
- Internet Advertising Bureau (IAB) Your Online Choices website provides more information about controlling cookies. It also provides an easy way to opt-out of behavioral advertising from each (or all) of the networks represented by the European Interactive Digital Advertising Alliance http://www.youronlinechoices.com/uk/your-ad-choices.
- The Network Advertising Initiative (NAI)control page allows you to control behavioral advertising from each of the ad networks represented by the NAI.
- The Digital Advertising Alliance’s self-regulatory program for online behavioral advertising control page allows you to control behavioral advertising from the ad networks it represents.
- The News Connect website provides more information and an easy way to opt-out.
Importantly, these ad networks set cookies to remember that you have chosen to opt-out. If you clear your cache the opt-outs will not be applied and you would need to opt-out again.
Controlling Flash cookies
You can manage the use of Flash technologies with the Flash management tools available at Adobe’s website, at http://www.adobe.com/devnet/flashplayer/articles/privacy.html.
Controlling web beacons
You can prevent web beacons from tracking your activity, although you won’t be able to decline receiving them in emails. For information about managing your cookie options, please visit http://www.allaboutcookies.org/.
Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available on our website.
What to do if you don’t want cookies to be set
Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that by blocking any or all cookies, you may not have access to certain features, content, or personalization available on our website.
Microsoft Internet Explorer 6.0, 7.0, 8.0
Click on ‘Tools’ at the top of your browser window and select ‘Internet Options’
In the options window navigate to the ‘Privacy’ tab
To enable cookies: Set the slider to ‘Medium’ or below
To disable cookies: Move the slider to the top to block all cookies
Note there are various levels of cookie enablement and disablement in Explorer. For more information on other cookie settings offered in Internet Explorer, refer to the following page from Microsoft: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Google Chrome
Click the wrench icon on the browser toolbar
Select Settings
Click ‘Show advanced settings’
In the “Privacy” section, click the ‘Content settings’ button
To enable cookies in the “Cookies” section, pick ‘Allow local data to be set’, this will enable both first-party and third-party cookies. To allow only first-party cookies pick ‘Block all third-party cookies without exception’
To disable cookies, in the “Cookies” section, pick ‘Block sites from setting any data’
Note there are various levels of cookie enablement and disablement in Chrome. For more information on other cookie settings offered in Chrome, refer to the following page from Google: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
Mozilla Firefox
Click on ‘Tools’ at the browser menu and select ‘Options’
Select the Privacy panel
To enable cookies: Check ‘Accept cookies for sites’
To disable cookies: Uncheck ‘Accept cookies for sites’
Note there are various levels of cookie enablement and disablement in Firefox. For more information, refer to the following page from Mozilla: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
Opera
Click on ‘Setting’ at the browser menu and select ‘Settings’
Select ‘Quick Preferences’
To enable cookies: check “Enable Cookies”
To disable cookies: uncheck “Enable Cookies”
Note there are various levels of cookie enablement and disablement in Opera. For more information on other cookie settings offered in Opera, refer to the following page from Opera Software: http://www.opera.com/browser/tutorials/security/privacy/
Safari on OSX
Click on ‘Safari’ at the menu bar and select the ‘Preferences’ option
Click on ‘Security’
To enable cookies: In the ‘Accept cookies’ section select ‘Only from site you navigate to’
To disable cookies: In the ‘Accept cookies’ section select ‘Never’
Note there are various levels of cookie enablement and disablement in Safari. For more information on other cookie settings offered in Safari, refer to the following page from Apple: http://docs.info.apple.com/article.html?path=Safari/3.0/en/9277.html
All other browsers
Please look for a “help” function in the browser or contact the browser provider.
Changes to This Policy
From time to time, we make changes to our Privacy Policy and Cookie Policy. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal information. Where necessary, we will seek your consent to these changes. We will always display clearly when the privacy policy was last amended on the website.
Contact Us
In addition to any general data protection inquiries you may have, you can use these details to contact our Data Protection Officer.
By email: [email protected]
lemurreport.com Privacy and Cookie Policy
- Introduction
- About Us
- Collection of Information
- Our Legal Bases for Using Personal Information
- How We Use and Share Personal Information
- Access & Control of Your Information
- Retention of Personal Information
- Cookies and Similar Technologies
- What Cookies Do We Use and Why?
- How We Use Cookies and Similar Technologies
- Managing Cookies
- Changes to This Policy
- Privacy Tools
- Contact Us
Introduction
This Privacy and Cookie Policy explains how we collect, use, share, disclose or otherwise process personal information we hold about you. Understanding what our audiences prefer allows us to personalize content, show relevant adverts, and generally improve your experience of our products and services.
About Us
lemurreport.com (“we” or “us”) will collect, use, share and disclose or otherwise process your personal information in line with this Policy. The relevant data controller for your data will depend on which product or service you have interacted with or to which title you have subscribed as set out below. We respect the privacy rights of our users and are strongly committed to protecting your privacy. This Privacy Policy applies to this website, any newsletters subscribed to via this website, as well as information collected and provided to us when you enter the website.
Collection of information
Registration, forums, apps and your dealings with us
We collect information about you when you provide it to us; for example, when you fill out our online forms, subscribe to one of our titles, enter a competition being run on our website, respond to our promotions, comment, engage or participate in website discussion.
Information from devices
We also collect information automatically when you interact with our websites or use our apps. This can include information about the device and the device’s general geographic location. This can be to provide services that have copyright restrictions or to deliver content that is relevant to where you are. We may also collect information from cookies placed on your device. See the section on Cookies for more information about our use of cookies. With your consent, we may also collect the specific location of your device or request access to data from other applications to provide certain services you have requested.
Social login
If you log in to our websites or online services through a third party site, such as Facebook, that site may pass information to us, such as user ID, name associated with the ID, email address and location, plus other information permitted under the privacy policy for that website. Our websites and apps may also return information about you to that social networking site regarding your usage, such as which website pages you visited and your use of the social media services on the website.
If you log in with or connect to your account using social media (Facebook, Twitter, etc), the social media service’s use of the shared information will be governed by their privacy policy. If you do not want your personal information shared in this way, please do not participate in social sharing on our website.
Posts, comments and interaction
If you interact, for example by using polls, comments, text messages, video, or email, we may display this content indefinitely in any relevant context, subject to our editorial judgment and your rights as set out in this Policy. This may be anonymized in the case of testimonials or customer service conversations.
If you take part in any reader or listener forums, or send us letters for publication, then you may be identifiable to others publicly and your comments attributed to you.
Public information and posts
Any information about yourself or others that you post on our social media pages, on platforms like Twitter, Facebook and other chat rooms, blogs and forums, will be viewed by other people (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in such public areas, and you acknowledge that this may be collected and used by third parties.
Ad delivery
When you visit our website, advertising networks and other intermediaries select and then display ads on your device.
These companies, generally collect information from your device to help select ads that they believe are more relevant to you. They also use this information to tell advertisers that the ads have been delivered and seen. You can find out more in the Cookies section of this Policy.
Our Legal Bases for Using Personal Information
All organisations need a legal reason to use your personal information. If they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. Below are the most relevant grounds you should be aware of.
With your consent
There are some activities where we process personal information with your consent. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. However, if you opt-out or withdraw consent, we may not be able to provide the product or service you have requested.
To enter into and fulfill a contract
We also process your personal information in order to fulfill a contract we have with you. For example, we would use your information to provide you with access to your digital subscription or other products you have signed up for or to provide a prize to which you are entitled.
For a legitimate interest
We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else.
We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between our legitimate interests and your privacy rights.
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 organizations;
- to build a clearer understanding of who our audiences are in order to better serve them;
- to carry on the business of a commercial organization; and
- to demonstrate that we provide services and products to agreed industry standards.
To comply with legal obligations
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This may include publishing information about prize winners, for example.
To provide products and services and improve the experience
How We Use and Share Personal Information
We will use your information to provide you with products and services and to manage our relationship with you, including allowing you to interact, comment, and generally engage with our content.
We may use your information to monitor, improve and protect our products, content, services, and websites, both online and offline. We may also provide you with help and support where we believe it is required. For example, if you have contacted us and provided your contact information, we may contact you with a relevant reply.
To personalize content and ads
We sometimes make assumptions about your interests based on the way you interact with our website and the information we hold about you.
Knowing these preferences also allows us to understand the products, content, and services our customers like, letting us focus our efforts on developing those areas. We may also use this information to make decisions about what ads to show you.
“Do Not Track” browser settings
If you choose to turn on Do Not Track setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to request that they stop tracking your activity. Currently, our website is not designed to respond to “Do Not Track” signals.
To conduct market research and perform analytics
We may use your information to conduct market research to improve the services we offer and to develop new products and services. You will be able to opt-out of receiving market research surveys by following the instructions in the communication.
You may also be asked if you would like to join our audience panels to help us improve our products and services. We value your participation and you will always have the choice to opt-out of these panels.
To gain audience insights
We may provide our partners with information about the effectiveness and reach of advertising campaigns that they have planned or carried out. This information will not identify you directly without your consent.
For example, we may tell advertisers how many customers their ads can reach based on criteria they select (such as “45-year-old women who live in Toronto”) or how many times an ad was viewed.
If you would prefer not to have your information used for audience insights, please email [email protected].
To detect ad blockers
When you visit our sites we may check (using cookies, code, script or other technical means) to see if you have an ad blocker installed on your device or if your internet browser settings allow adverts or not.
If we detect that your device or internet browser is using an ad blocker, we may ask you to “whitelist”, trust or pause blocking adverts while you visit our websites or apps. You can do this easily in your browser settings or within the ad blocker itself. If you continue to use an ad blocker this may have an impact on the content you are able to see on our website.
Information about your use of ad blockers may be stored or associated with your device (including through the use of cookies) to re-insert advertisements on our websites and to understand how our customers use ad blockers. The advertisements that are re-inserted may include those from ad blockers’ “whitelists” or that promote our own products and services.
To allow third-party advertising
In some instances, targeted advertising may be displayed on our website by third parties using our platforms. These third-party ads may collect and use your personal information, which is outside of our control. This targeting may be caused by cookies already in place on your device. More general information on cookies can be found in the Cookies section of this Policy.
To provide co-branded services and features
We may offer co-branded services or features, such as competitions or other promotions, together with a third party and may share the information you provide with that third party where we have your consent. These co-branded services may be hosted by us or by the third party. In these instances, the third party may also be a data controller for your information. In this case, the third party’s use of your information will be governed by their privacy policy, which you should always read.
To disclose your information as permitted by law
Your information may be disclosed where we are permitted by law to do so, for example where we get police requests or regulatory inquiries. We may also disclose your personal information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
To ensure our services are used appropriately
If you post or send offensive or objectionable content, or otherwise engage in disruptive behavior anywhere on or to our website, we may use your information to stop such behavior. This may involve informing and responding to relevant third parties such as law enforcement agencies about the content and your behavior.
As part of the sale of our business
If we sell part or all of our business, customer information may be one of the transferred business assets. If this happens, your information may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business for the purposes set out in this Policy and to ensure continuity of your selected services.
To ensure that our products and services conform to agreed industry standards
We may share your information with auditors for the purposes of verifying that we comply with relevant standards. For example, we may ask third-party auditors to assess our compliance with information security and Privacy by Design best practice. This may require them to access your information in our systems.
Linked services
Our services may be linked to websites and apps operated by third-party companies and may carry advertisements or offer content developed and maintained by unaffiliated companies. We are not responsible for the privacy practices of these companies, and once you leave our website you should check the applicable privacy policy of the other service.
Access & Control of Your Information
Withdrawing consent for processing
Where we may rely on your consent to process personal information, you have the right to withdraw that consent at any time. Often, this can be managed through the preference center – such as your consent for us to send you communications. Otherwise, please contact us at [email protected] with details of your request. In some instances, we may still have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent we may not be able to provide the product or service you have requested.
Other rights
You may also have the right to object, erase, or restrict our processing of your information – for example, where we process personal data because this is in our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data.
To exercise any of these rights, please contact us at [email protected]. These rights may be restricted by law, for example, we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.
Retention of Personal Information
We will retain your information for as long as necessary for the uses set out in this Policy, or while there is a legitimate reason for doing so. If you ask us to delete your information before that time, we may not be able to do so due to technical, legal, regulatory or contractual constraints.
Cookies and Similar Technologies
Introduction
Most websites you visit will use cookies in order to improve your user experience by enabling that website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’).
Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Cookies make the interaction between you and the website faster and easier. If a website doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the site – for example, when you enter your login details and move to another page it won’t recognize you and it won’t be able to keep you logged in.
Some websites will also use cookies to enable them to target their advertising or marketing messages based for example, on your location and/or browsing habits.
What are Cookies?
A cookie is a text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket.
Our legal bases for cookies and similar technologies
Placing cookies: in order to place cookies, tags and other technologies on your browser or device, we need to have your permission. We do this by providing a clear notice in the form of a cookie banner that tells you what cookies are used for, as well as providing you with useful information about the technologies we use and a link to this Policy. You’ll need to indicate your acceptance of our use of cookies. You are able to opt-out of the use of cookies. For more information, see the section on Managing Cookies.
Using information collected from cookies: where we want to use the information that cookies and similar technologies collect, we either need your consent or a legitimate interest. In practice, it will not always be practical to get opt-in consent as doing so with cookie banners and pop-ups would disrupt your use and enjoyment of our sites and content. This is why we usually rely on our legitimate interests to use the data collected by cookies. To do this we conduct an assessment to make sure the purposes for which we use your data are fair and that your privacy rights are considered. We only rely on legitimate interests where your rights do not override our interests in using the data.
For more information about your rights in relation to legitimate interests, please see the section on Access and Control.
What Cookies Do We Use and Why?
Analytics cookies and similar technologies
These collect information about your use of our websites and apps, and enable us to improve the way they work. For example, analytics cookies show us which are the most frequently visited pages on our website, allowing us to provide the most popular news articles further up the page. They help us record how you interact with our website, such as how you navigate around pages and from page to page, identifying improvements we can make to the customer journey. They also help identify any difficulties you have accessing our services, so we can fix any problems. Additionally, these cookies allow us to see overall patterns of usage at an aggregated level.
We may place cookies and similar technologies on behalf of comScore who help us measure the size and quality of our audiences across platforms. You can learn more and control how comScore uses your information here http://www.scorecardresearch.com/preferences.aspx.
Functional/preference cookies and similar technologies
These cookies collect information about your choices and preferences and allow us to remember things like language, and location, so we can show you relevant content to where you are. They allow us to customize the services you have accessed. We also use these cookies to provide you with services such as video content.
Tracking, advertising cookies and similar technologies
We use these types of technologies to provide advertisements that we think may be more relevant to your interests. This can be done by delivering online ads based on your previous web browsing activity, known as “online behavioral advertising” (OBA). Cookies are placed on your browser which will remember the websites you have visited. Ads based on what you have been looking at are then displayed to you when you visit websites which use the same advertising networks.
For example, you may be doing online research to buy a book, and read several articles about relevant books on various websites. As you browse those sites a cookie from an advertising network would be placed in your browser. It would remember that you had visited several websites related to reading. Then, when you visited another website in the same advertising network, the website could show you an ad related to books and or reading.
We may also use cookies and similar technologies to provide you with ads based on your location, offers you click on, and other similar interactions with our website.
To help us deliver relevant advertising using cookies, we use Google Double Click. You can find out more about Google Double Click here.
We may also use the Google Analytics tool to track overall browsing patterns on the website. For instance, it helps us identify the most popular pages on the website, find out which links are being clicked on, and to give us broad demographics about from where users are accessing the site. We cannot personally identify users with these cookies.
The five Google Analytics cookies are called utma, utmb, utmc, utmv and utmz. They track how often the website is visited, when you enter and leave the site, and which site you visited that lead you to our website. utmz also tracks any keywords you entered into a search engine that lead you to our website, if appropriate.
Web beacons and tracking pixels
These are bits of data that count the number of users who access a website or webpage and can also allow us to see if a cookie has been activated. Web beacons used on web pages or in emails allow us to see how successful an article has been, or whether an email message was successfully delivered and read in a marketing campaign. Web beacons are also used to verify any clicks through to links or advertisements contained in emails. We may use this information to help us identify which emails are more interesting to you and to inform advertisers how many customers have clicked on their ads (the information shared with advertisers is aggregated and does not identify you individually).
Flash cookies
We may, in certain situations, use Adobe Flash Player to deliver special content, such as video clips or animation. To improve your user experience, Local Shared Objects (commonly known as Flash cookies) are used to provide functions such as remembering your settings and preferences. Flash cookies are stored on your device, but they are managed through an interface different from the one provided by your web browser.
Tracking URLs
Tracking URLs are a special web link that allows us to measure when a link is clicked on. They are used to help us measure the effectiveness of campaigns and advertising and the popularity of articles that are read.
Device fingerprinting
We may collect and analyses a device’s browser information to help identify that device, present content correctly, conduct analytics and help prevent and detect fraud.
If you access our services from a mobile device
We may collect a unique device identifier assigned to that device, geo-location data, and other transactional information for that device. We may also use the unique identifier to validate free trials, for example.
How We Use Cookies and Similar Technologies
As well as the uses already identified above, we use cookies and similar technologies to:
Protect our website
Cookies and similar technologies help us identify and prevent threats to our website. They are necessary to protect your information and our business from outside threats.
Allow you to access our services
Cookies and similar technologies permit your connection to our website: our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, other software or hardware information, and your geographic location.
Assess usage of services
We use information about your usage of our website, such as pages you have visited, content you have viewed, search queries you have run, and advertisements you have seen or interacted with to assess how our services are used.
Provide eCommerce functionality
Cookies and similar technologies help us provide functionality that you need to navigate our sites, select products and services and purchase them.
Provide relevant content
The content on our website and in our communications with you may be adjusted depending on what we know about the content, products and services that you may like. This means we can highlight content and articles that we believe will be of interest to you. We provide personalization by using cookies, IP addresses, web beacons, URL tracking and mobile app settings.
Sell third-party advertising
We sell space on our website and apps to advertisers. The ads they display on our website will often contain cookies. Our advertisers may use cookies or similar technologies to provide you with advertisements that they believe are relevant. They may use browsing data obtained to restrict the number of times you see particular ads (frequency capping). You may also see ads from these advertisers on other websites you visit.
Third parties that support our services by serving advertisements or providing other services, such as allowing you to share content or tracking aggregate service usage, may also use cookies and other technologies to collect information relevant to the provision of those services.
We do not control third party cookies or other technologies. Their use is governed by the privacy policies of third parties using such technologies. You should make sure you are aware of how third parties will use cookies by checking the third party’s cookie policy.
We use third-party advertising companies to serve ads when you visit our Web site. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see: http://www.networkadvertising.org/managing/opt_out.asp
To learn more about controlling cookies and similar technologies, please see the section below on Managing Cookies.
Managing Cookies
Below you will find useful information about how to manage the use of cookies on our website. If you have any questions, please contact [email protected].
Our partners
When you visit our website, our partners may set cookies and similar technologies on your browser in order to help us make the site work, analyses site usage, deliver ads and personalize your experience. Where these partners are acting on our behalf, they are called data processors and must only act on our instructions. We will have a contract with them and they must protect your information properly. They’ll use your information in accordance with this Cookie Policy and you’ll be able to opt-out.
Where other partners are placing cookies and similar technologies for their own purposes, they are called data controllers and will use your information for their own purposes.
When you visit our website you’ll see notices about the use of cookies by us and our partners. You’ll be able to learn more about the specific cookies in use and how to control them. By using our website, you understand that cookies and similar technologies are used and acknowledge that by continuing to use the website, you consent to their placement.
In the future, we plan to release improved controls to allow you to choose which partners can collect and use your information.
Most modern browsers are set to accept cookies by default, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser.
Controlling OBA cookies
In addition to being able to control cookies by changing the settings in your browser on your computer, or in your mobile device’s settings, you can also control which companies can set cookies and similar technologies on your devices, by visiting the following links (you’ll need to turn any cookie or ad blockers off for the control pages to show which companies you can opt-out of):
- Internet Advertising Bureau (IAB) Your Online Choices website provides more information about controlling cookies. It also provides an easy way to opt-out of behavioral advertising from each (or all) of the networks represented by the European Interactive Digital Advertising Alliance http://www.youronlinechoices.com/uk/your-ad-choices.
- The Network Advertising Initiative (NAI)control page allows you to control behavioral advertising from each of the ad networks represented by the NAI.
- The Digital Advertising Alliance’s self-regulatory program for online behavioral advertising control page allows you to control behavioral advertising from the ad networks it represents.
- The News Connect website provides more information and an easy way to opt-out.
Importantly, these ad networks set cookies to remember that you have chosen to opt-out. If you clear your cache the opt-outs will not be applied and you would need to opt-out again.
Controlling Flash cookies
You can manage the use of Flash technologies with the Flash management tools available at Adobe’s website, at http://www.adobe.com/devnet/flashplayer/articles/privacy.html.
Controlling web beacons
You can prevent web beacons from tracking your activity, although you won’t be able to decline receiving them in emails. For information about managing your cookie options, please visit http://www.allaboutcookies.org/.
Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available on our website.
What to do if you don’t want cookies to be set
Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that by blocking any or all cookies, you may not have access to certain features, content, or personalization available on our website.
Microsoft Internet Explorer 6.0, 7.0, 8.0
Click on ‘Tools’ at the top of your browser window and select ‘Internet Options’
In the options window navigate to the ‘Privacy’ tab
To enable cookies: Set the slider to ‘Medium’ or below
To disable cookies: Move the slider to the top to block all cookies
Note there are various levels of cookie enablement and disablement in Explorer. For more information on other cookie settings offered in Internet Explorer, refer to the following page from Microsoft: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Google Chrome
Click the wrench icon on the browser toolbar
Select Settings
Click ‘Show advanced settings’
In the “Privacy” section, click the ‘Content settings’ button
To enable cookies in the “Cookies” section, pick ‘Allow local data to be set’, this will enable both first-party and third-party cookies. To allow only first-party cookies pick ‘Block all third-party cookies without exception’
To disable cookies, in the “Cookies” section, pick ‘Block sites from setting any data’
Note there are various levels of cookie enablement and disablement in Chrome. For more information on other cookie settings offered in Chrome, refer to the following page from Google: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
Mozilla Firefox
Click on ‘Tools’ at the browser menu and select ‘Options’
Select the Privacy panel
To enable cookies: Check ‘Accept cookies for sites’
To disable cookies: Uncheck ‘Accept cookies for sites’
Note there are various levels of cookie enablement and disablement in Firefox. For more information, refer to the following page from Mozilla: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
Opera
Click on ‘Setting’ at the browser menu and select ‘Settings’
Select ‘Quick Preferences’
To enable cookies: check “Enable Cookies”
To disable cookies: uncheck “Enable Cookies”
Note there are various levels of cookie enablement and disablement in Opera. For more information on other cookie settings offered in Opera, refer to the following page from Opera Software: http://www.opera.com/browser/tutorials/security/privacy/
Safari on OSX
Click on ‘Safari’ at the menu bar and select the ‘Preferences’ option
Click on ‘Security’
To enable cookies: In the ‘Accept cookies’ section select ‘Only from site you navigate to’
To disable cookies: In the ‘Accept cookies’ section select ‘Never’
Note there are various levels of cookie enablement and disablement in Safari. For more information on other cookie settings offered in Safari, refer to the following page from Apple: http://docs.info.apple.com/article.html?path=Safari/3.0/en/9277.html
All other browsers
Please look for a “help” function in the browser or contact the browser provider.
Changes to This Policy
From time to time, we make changes to our Privacy Policy and Cookie Policy. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal information. Where necessary, we will seek your consent to these changes. We will always display clearly when the privacy policy was last amended on the website.
Contact Us
In addition to any general data protection inquiries you may have, you can use these details to contact our Data Protection Officer.
By email: [email protected]