Reach Group - Privacy Notice

ARCHIVED 2022-06-02, DATE APPROXIMATE · VERSION 20220602_rev01 · COMPARED WITH 20211102_rev01

Full text changes — 20211102_rev01 to 20220602_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+## Reach plc - Privacy Notice
+## Reach Group - Privacy Notice
+**WHO WE ARE**
+We have organised this Privacy Notice based on the different ways you might interact with us and what you might want to know.
+We are the publishing group Reach plc. We, via our various subsidiary companies and brands, publish many national websites, regional websites, and mobile applications ("Sites"), that millions of people enjoy every month. You can see the list of websites and brands we publish [here](https://www.reachplc.com/our-brands).
+Please use the contents list below to navigate to the section of the Privacy Notice which you are interested in. At the end of each section if you want to return to the contents list please click the link: 'Click here to go back to Contents'.
+**ABOUT THIS PRIVACY NOTICE**
+**CONTENTS**
+This is the main Privacy Notice for the Reach Group. It applies to all our Sites, and brands, but some of them may publish additional or alternative notices, in which case those take precedence.
+. **[Who we are and how to contact us]()**
+In summary, depending on your relationship with us, we'll use your personal information:
+. **[About this Privacy Notice]()**
+- As needed to provide our products and services, for example to administer subscriptions, take orders and ad placements and handle customer service queries.
+- To provide a single customer view across our Sites and ensure we understand who our customers are and their preferences and how our products and services are generally perceived.
+- To provide the interactive features of our Sites, such as commenting, discussion forums and competitions.
+- To send you direct marketing communications about products and services that we feel may be of interest.
+- To display digital advertising on our Sites that is tailored to your preferences so the online adverts you see are more relevant to you.
+- To manage our business and to comply with the law.
+. **[When you browse our websites and use our apps]()**
+This Privacy Notice, which covers all of your personal information whether collected online or offline, including by telephone or where you write to us, together with our Cookie Notice and any Site-specific notice, provide detail about our activities and explains your rights and how to exercise them.
+. **[When you create or sign into your online Reach account]()**
+For all our Sites, and brands, either Reach plc or one of its subsidiary companies is the data controller of the personal information that we gather about you. Regardless of which Reach Group company is the controller, you can always contact us with questions or concerns about your privacy by emailing us at dataprotection@reachplc.com
+. **[When we communicate with you by email]()**
+**1\. TYPES OF INFORMATION WE PROCESS AND WHERE IT COMES FROM**
+. **[When you enter a competition or prize draw]()**
+Information that we collect and process about you includes:
+. **[When you complete a survey]()**
+- Personal and contact details you have provided to us, such as your name, email address or postal address, for example when you register on a Site or to receive a newsletter, enter a sales promotion or competition, or at an event, or where you have agreed to receive marketing materials from us or third parties.
+- Information you have provided when you obtain products or services from us or enquire about those products or services.
+- Information included in any communications between us or which you provide in any post on any Site, or any information collected when you participate in any poll or quiz or obtained via social media or which is publicly available.
+- Information about your use of third-party products or services or from third parties who we may use to operate certain aspects of our business.
+- Information obtained if we carry out a credit search at a credit search referencing agency.
+- Information we buy or obtain from third parties, including marketing lists; and
+- We also collect information from cookies on your devices and this includes information about your IP address, MAC address and other identifying information, information about your devices, including your location, from third party advertising networks and how you use our products and services.
+. **[When you subscribe to our print or "e-publishing" titles]()**
+For more information about cookies, please see our [Cookie Notice](https://www.mirror.co.uk/cookie-policy/)
+. **[When you place a classified ad]()**
+**2\. USE OF YOUR INFORMATION**
+. **[When you apply for a job with us]()**
+We want to offer you the best customer experience and products and services which are relevant to you. We may therefore use and permit others to use your personal information as set out below, where we have a legal basis to do so:
+. **[When you work at other organisations that we do business with]()**
+**To provide products and services:**
+. **[Site visits and CCTV at our premises]()**
+- We may use your information to assess your request to receive the products and services we offer, including where necessary conducting identity and credit reference checks and other due-diligence checks.
+- We may use your information to provide and administer the products and services you have elected to receive, including notifying you of changes and updates to our products and services.
+- We may use your information for the management of our business and improving the operation of our business and that of our business partners, to assess our internal processes and carry out financial checks.
+- We may use your personal information to manage and administer competitions and events offered by us and our third-party partners.
+- We may conduct market research to evaluate and improve our products and services generally or develop new offerings.
+- If you log-in to our Sites using social media, (e.g., Facebook, Google+, Twitter or similar social media platforms), you are granting permission to the social media platform to share your user details with us. This will include your name and email address which will then be used to form a user identity.
+- If you send us a picture, or video, for publication you confirm that you have the consent of all the people in the picture or video. If the picture, or video, features a child, or children, you confirm that you are the parent or guardian of the child, or children, and have the legal right to grant consent (or the parent or guardian of the child, or children, has granted such consent).
+- Where you enquire or raise complaints about our products and services, we will use your personal information to investigate and respond to your enquiry or complaint.
+. **[Further data sharing by Reach]()**
+**To understand our customers, how you use our products & services, and tailor your experience:**
+. **[Your rights and how to exercise them]()**
+- We may use your information to provide a single customer view across our Sites and ensure we understand who our customers are and their preferences and how our products and services are generally perceived.
+- We may customise and tailor your experience on our Sites and the products and services we offer to ensure they are more relevant to your interests and preferences.
+- We may use the personal information gathered from our Sites to analyse and determine the level of engagement with our Sites and whether the communications that we send to customers are relevant, e.g., we may analyse your browsing behaviours and whether or not you open the communications that we send you.
+- We may send you direct marketing communications (via email, post, or telephone) about products and services we feel may be of interest to you. You can choose not to receive direct marketing communications from us at any stage. Where you opt-in to the receipt of newsletters and other content via email we may include first and third-party advertisements, some of which may be personalised, based upon our profile of you as a customer. The personal data provided at opt-in for newsletters and accounts may also be used to enhance our profile of you, and further improve the relevance of any content which you receive across our channels and customer touchpoints.
+- Digital advertising helps us to fund the news articles and content published on our Sites and enables us to provide some of our content for free. We and our third-party ad partners may display digital advertising on our Sites that is tailored to your interests and preferences so the online adverts you see are more relevant to you. We work with a number of third-party ad partners to deliver digital advertising on our Sites, and we use cookies and other personal information to personalise the advertising that you see, such as your email address, postcode, and other observed browsing behaviour. We do not share identifiable information about you with our third-party ad partners. Where we share, match, and use data for this purpose it is always pseudonymised beforehand, which means it is converted into a hashed series of numbers and letters to protect your identity.
+- Where we use cookies on our Sites for advertising purposes, we will always ask for prior consent and where you provide your consent the cookie information will be used along with other information we hold about you to display digital advertising that is more relevant to you. It is important to note, however, that where you do not provide your consent for digital adverting you will still see digital advertising on our Sites, but this will not be tailored to your interests and preferences.
+- We will conduct analytics and modelling to identify trends and assess our performance and internal processes. We may disclose the insight we gain through such analysis to other businesses e.g., to demonstrate patterns of use to third-party ad partners and others. However, any information shared is either aggregated, anonymised or pseudonymised.
+. **[Privacy Notice last updated]()**
+**Legal obligations and information security:**
+## **1\. Who we are and how to contact us**
+- Where permitted by applicable laws, where you interact with us, we may monitor, record, and retain all associated correspondence and communications, such as written letters, telephone call recordings, emails, text messages, social media messages, in person meetings and any other communications. We will do this to, (i) comply with our legal and regulatory obligations (ii), prevent, or detect crime (iii), maintain appropriate evidential records (iv), protect the security of our communications systems and (v) for training and quality purposes.
+- We will use your information to monitor and manage data security and the security of our Sites and networks.
+- We will use your personal information to comply with our legal and regulatory obligations and monitor compliance with the same across our business. Where necessary, we will also use your personal information to defend ourselves from any legal claims brought by you in connection with the provision of our products and services.
+- We will also use personal information to manage and administer our business generally.
+We are the Reach group, which is made up of Reach plc and its subsidiaries. Reach plc is the largest national and regional news publisher in the UK with a leading portfolio in Ireland. We create engaging, relevant content which is distributed through newspapers, magazines, and digital platforms - playing a central role in our audiences' daily lives. We are the name behind some of the UK's most influential, iconic, and trusted news brands, such as the Daily Mirror, Daily Express, Daily Star, Daily Record and Sunday People as well as leading celebrity and entertainment magazine OK! We also publish leading regional titles including the Manchester Evening News, Liverpool Echo, Birmingham Mail, Western Mail and Bristol Post. You can see the list of websites and brands we publish [**here**](https://reachadspecs.com/ad-guidelines/site-list).
+**3\. WHO WE SHARE YOUR PERSONAL INFORMATION WITH**
+Our address is:
+We share information as needed with our third-party service providers and partners, to other members of the Reach Group, as part of providing and administering our products and services or operating our business or as set out below.
+One Canada Square, Canary Wharf, London, E14 5AP.
+When you browse our websites or use our mobile applications and when you provide your email address on these (either to log in, or sign up to a newsletter, or similar) we may share it, in hashed, pseudonymised form, with our partner LiveRamp Inc and its group companies, acting as joint controllers. LiveRamp uses this information to create a secure online identification code for the purpose of recognising you for cross-channel advertising. This code is placed in our cookie, does not contain any of your directly identifiable personal data (such as your name or unhashed email address), and will not be used by LiveRamp to identify you. It may be shared with our advertising partners and other third-party advertisers globally for the purpose of enabling interest based content or targeted advertising through Reach sites. These third parties may in turn use this code to link demographic or interest-based information you have provided in your interactions with them to the pseudonymised code. Detailed information on LiveRamp's data processing activities is available in LiveRamp's privacy notice and opt-out here: [https://your-rights.liveramp.uk/home](https://your-rights.liveramp.uk/home). You have the right to withdraw your consent or opt-out to the processing of your personal data at any time using our Cookie Management Platform (via our 'PRIVACY' tab at the bottom left of every page).
+Depending on who you are and how you interact with us, the legal "controller" of your personal data will be one or more of our group companies, like MGN Limited, Local World Limited or Express Newspapers (all at the address above). Your point of contact for anything to do with how the Reach group uses your personal data is the office of our group Data Protection Officer, who you can contact at [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) or by writing to 'The Data Protection Team' at the address above.
+We will disclose your information and co-operate with appropriate bodies and authorities in good faith where we are required to by law, a court order, a regulatory authority, or otherwise, including with the police, trading standards, regulatory authorities, or other relevant authorities. We may share information about you with credit reference agencies.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+We will share information with security consultants and IT security system providers, where necessary, to monitor and manage data security and the security of our Sites and networks, and to develop security threat intelligence data.
+## **2\. About this Privacy Notice**
+We may also share information to facilitate the sale of one or more parts of our business, including if we are approached by a potential buyer or the restructuring of one or more parts of our business and with auditing organisations such as the Audit Bureau of Circulation
+This Privacy Notice tells you about the kinds of information we hold about you, what we do with it, and why.
+**4\. COOKIES**
+As a broad summary, in our business we use information about people:
+We collect information about you automatically when you visit our Sites by using cookies (small text files) and other tracking technology. For more information about cookies, and other tracking technology including how to turn them off, please see our [Cookie Notice](https://www.mirror.co.uk/cookie-policy/).
+- To carry out our work as journalists, by investigating and reporting on stories of relevance to our readers.
+**5\. TRANSFERS OUTSIDE OF UK AND EUROPE**
+- To deliver our features and editorial content.
+We're based in the UK and the Republic of Ireland but sometimes your personal information may be transferred outside of the UK and the European Economic Area. If we do so we'll make sure that suitable safeguards are in place, for example Adequacy Decisions, and approved contractual agreements, including standard contractual clauses, unless certain exceptions apply. We can provide more information about this on request.
+- To provide services such as subscriptions or newsletters that people sign up to, and to operate interactive features like competitions and surveys.
+**6\. WHAT ARE THE LEGAL GROUNDS FOR OUR PROCESSING OF YOUR PERSONAL INFORMATION (INCLUDING WHEN WE SHARE IT WITH OTHERS)?**
+- To help us to understand our readers and target our marketing and advertising that enables us to continue to finance and bring you our feature and editorial content.
+We rely on the following legal bases to use your personal information:
+- To carry out back-office administration and generally run and operate our business, for instance by administering our relationships with suppliers and partner organisations, or handling job applications.
+**A. For the performance of a contract** where it is needed to provide you with our products or services, such as:
+Some specific activities and websites might have their own additional and complementary privacy notices which sit alongside this one. Generally, that will be the case for very specific services such as our commercial job boards or other specialist websites, or where we have a very specific kind of relationship with you (for instance if you are an investor or a member of our group pension scheme). We try to make it obvious where that is the case.
+- Managing products and services you hold with us, or an enquiry about one.
+- Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate).
+- Sharing your personal information with third parties and services providers when you apply for a product or service to help manage your product or service.
+- All stages and activities relevant to managing any product or service including enquiry, application, administration, and management of accounts.
+Data Protection and Journalism
+**B. Where it is in our legitimate interests to do so, such as:**
+The UK
+- Managing your products and services, updating your records.
+- To perform and/or test the performance of, our products, services, and internal processes.
+- For some direct marketing communications, in compliance with The Privacy and Electronic Communications Regulations, subject to appropriate controls and safeguards.
+- To help us to understand your preferences and interests based on the newsletters you sign up to, and to use data provided on sign-up to services and accounts to build a profile of you as a Reach customer, and enable secure, pseudonymised tracking where you have also consented to the use of cookies. We won't share that profile with third parties. We will use that profile information to inform the content we recommend to you, the adverts you see on our sites and - if you have separately consented to it - to help us to target offers and other direct marketing materials which we send to you.
+- To follow guidance and recommended best practice of government and regulatory bodies.
+- For management and audit of our business operations including accounting.
+- To carry out monitoring and to keep records of our communications with you and us.
+- To administer our good governance requirements and those of other members of our Group, such as internal reporting and compliance obligations or administration required for AGM processes.
+- For market research and analysis and developing statistics.
+- To provide insight and analysis of our customers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our businesses.
+- Where we need to share your personal information with people or organisations in order to run our business.
+- To manage the security of our Sites and networks.
+In the UK the Data Protection Act 2018 provides an exemption from data protection laws to prevent unjustified interference with the work of journalists. We are members of the Independent Press Standards Organisation [(IPSO)](https://www.ipso.co.uk/) and therefore subject to the [Editors' Code](https://www.ipso.co.uk/editors-code-of-practice/). If you object to a story we have published that concerns you personally then you can find our complaints policy here \[[UK Complaints](https://www.reachplc.com/complaints-policy)\], which explains how to raise a complaint and how we will handle it.
+**C. To comply with our legal obligations** or where we reasonably believe we are under a legal or regulatory obligation.
+Ireland
+**D. With your consent or explicit consent**
+In Ireland we subscribe to the Code of Practice of the Press Council of Ireland and the Press Ombudsman, which set the benchmark for high professional standards. If you believe that we have got something wrong, or that we have breached the Code of Practice, please let us know at the contact details of the publication concerned.
+- For some direct marketing communications and digital advertising activities
+- For some of our processing of special categories of personal data such as that related to your health.
+The Code of Practice and details of how to lodge a complaint with the Press Ombudsman are available from:
+**7\. HOW LONG DO WE KEEP YOUR DATA FOR?**
+Post: 1, 2 & 3 Westmoreland Street, Dublin 2.
+In general, we keep your personal information for as long as we need it for the purpose for which it was collected, plus a short additional period in case of problems. How long we keep it therefore varies according to the type of information it is and why we have it, and will range from a few days or weeks to, in some cases, several years. We have established a full data retention policy and can provide further information on request.
+Website: [www.pressombudsman.ie](http://www.pressombudsman.ie/)
+**8\. WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LAW?**
+Email: [info@pressombudsman.ie](mailto:info@pressombudsman.ie)
+The law gives you certain rights in respect of the information that we hold about you. Below is a short overview of those rights. The website of the Information Commissioner's Office ([https://www.ico.org.uk](https://www.ico.org.uk/)) has a wealth of useful information in respect of your rights over your personal information. If you wish to exercise your rights, you can write to us by email [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) or by post to Reach plc, One Canada Square, London E14 5AP, for the attention of the legal department.
+Telephone: 1890 208 080
+**Your right to withdraw your consent**
+Fax: 01 6740046
+If we are processing your personal information based on your consent, you have the right to withdraw that consent at any time. You can withdraw this at any time by unsubscribing from services or by contacting us at [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com).
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+**Your right to access the information we hold about you**
+## **3\. When you browse our websites and use our apps**
+With some exceptions designed to protect the rights of others, you have the right to a copy of the personal information that we hold about you, as well as information about what we do with it, who we share it with and how long we will hold it for. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs.
+When you browse our websites or use our apps, we and our advertising partners will receive some information about the device you are using and about what you look at and interact with. We do this for the purpose of choosing which adverts to show you, as well as to make our sites and apps work properly. It also allows us to diagnose problems with them and understand how they are used so we can make them better. Sometimes, we also apply a degree of personalisation in choosing which content to show you (for example, by recommending articles similar to those you've viewed previously).
+**Your right to have inaccurate information about you rectified**
+You can learn more about what we do with this information and why below.
+You have the right to have the information we hold about you corrected if it is factually inaccurate.
+### **3.1. Targeting by Reach**
+**Your right to object to what we do with your data, and to have restrictions placed upon it**
+We combine the information you give to us (for example, sign up information for newsletters and competitions) with the information we receive when you use our websites and apps, and analyse it in order to help us to understand your preferences and interests. We then associate this with a unique identification number. This is then used to tailor the content and advertising that you see on our websites and in our apps, so it is more likely to be of interest to you. We don't share this personalised analysis with anyone outside Reach. In particular, it is not shared with advertisers or with the third-party advertising networks that we work with other than in highly aggregated form so that your personal data cannot be identified.
+Where we process your personal information based on our legitimate interest, you have the right to object to that processing and to have restrictions placed upon it while we consider your objection.
+#### **3.1.1. The data we collect and what we do with it**
+**Your right to have your information erased in some circumstances**
+The data we use for this purpose is as follows:
+You have the right to require us to delete the information that we hold about you if it is no longer necessary for the purpose we collected it for, and there is no other legal basis on which we must, or are allowed to, retain it.
+- The page you view, and associated information such as how long you spend on them.
+**Your right to stop receiving direct marketing from us**
+- Your approximate location, to city or town level.
+You have the right to require us to stop sending you direct marketing material (for example, promotional emails). It can sometimes take a few days to action these requests.
+- Your email address, name and sometimes username and postcode, which we will receive when you sign up for an account on one or more of our websites or apps, when you subscribe to our newsletters, when you enter one of our competitions or when you complete one of our surveys.
+**Your right to complain to the Information Commissioner's Office (ICO)**
+- The newsletters you have subscribed to, the promotions and competitions you have entered and the surveys you have completed.
+You have the right to lodge a complaint about our handling of your personal information with the supervisory authority, which in the UK is the Information Commissioner's Office. But before you do so, please do contact us first to give us an opportunity to put matters right, at [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com). You can contact the ICO on 0303 123 1113.
+We will analyse this information to infer interests, preferences, and demographic characteristics, and associate it with an internal identification number. For example, if our website analytics tell us that you are located in the approximate area of Newcastle-upon-Tyne and you read our online title ChronicleLive (which is focused on local news for that area), and you sign up to receive an email newsletter about football from our national title The Mirror, then we could infer from that you are interested in things related to a local football club or to football generally.
+**9\. CHANGES TO THIS PRIVACY NOTICE**
+We then divide up our identification numbers into groups based on the inferences we draw about them. Those groups are called "audience segments" or "audiences". So, for example, an identifier associated with Newcastle, ChronicleLive and the football newsletter could be allocated to audiences likely to be interested in football, and events near Newcastle-upon-Tyne.
+It's likely that we'll need to update this Privacy Notice from time to time. Any changes to this Privacy Notice will be posted here and such changes will become effective as soon as they are posted. Your continued use of the relevant Site constitutes notice to you of all these changes.
+We then use those "audiences" to do two things: first, to help us to recommend content which is more likely to be interesting (for instance, more articles about football), and second to help us to target advertisements when advertisers buy advertising space from us directly.
+**10\. CONTACT US**
+The advertiser would never see the actual data that we use - it remains with Reach at all times. All we would share with them would be the criteria we used to target their advert, how many times their advert was shown and how many people clicked on it (but not who), so that they know how well the advert did and we know how much to charge them.
+If you have any questions about this Privacy Notice, or if you wish to exercise your rights you can contact us by email at [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com). Alternatively, you can write to The Data Protection Officer, Reach plc, One Canada Square, London E14 5AP.
+#### **3.1.2. Our legal basis**
+_This Privacy Notice was updated on 15th September 2021 to clarify our use of your personal information or reflect changes to it._
+We capture your activity on our websites and in our apps on the basis of your consent, which we ask for through our "cookie banner" and related Consent Management Platform (CMP) - Please see our [Cookie Notice](https://www.mirror.co.uk/cookie-policy/) for further information or the 'cog' icon at the bottom left of every webpage to manage your consents. When using our apps if you want to change the settings, go to the 'My Account' Link at the bottom of the screen which includes 'My Privacy' and takes you to the CMP.
+We combine that information with the other things we know about you (like your newsletter subscriptions) on the basis of our legitimate interest in understanding our readership, both to serve you better and to make us more attractive to advertisers. This helps us to secure a future for news reporting and journalism in the age of social media, especially local news reporting and journalism.
+You do, of course, have an absolute right to object to this. You can always register your objection by contacting [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com).
+#### **3.1.3. How long we keep it for**
+We keep the information about your activity on our websites and in our apps for up to up to three years since last browsing activity, with some anonymised browsing activity retained thereafter.
+#### **3.1.4. Who we share it with and why**
+The data which we use to create the unique identifier and our "audiences" is only shared with the partners who provide us with the technology powering it, most notably Upland Software and Lotame, who host core data management platforms for us. They act as our "processors". This means that they are bound by law and contract to do only what we tell them to do with the data, to keep it safe, and not to share it with anyone else or use it for anything other than providing their service to us.
+#### **3.1.5. Whether we send it abroad**
+Upland Software and Lotame are global businesses and so the data they host for us may be held abroad. We have implemented the required safeguards as necessary (for example, standard agreements approved by the relevant authorities).
+### **3.2. Targeting by third party advertising networks**
+Digital advertising helps us to fund the news articles and content published on our sites and enables us to provide some of our content for free. We and our third-party ad partners may display digital advertising on our sites that is tailored to your interests and preferences so the online adverts you see are more relevant to you. We work with third party ad networks to fill unsold advertising space on our sites and in our apps by auctioning it automatically through a process called "real time bidding". These ad networks bid to show their ad to you when you visit our sites or use our apps. We do not share identifiable information about you with our third-party ad partners.
+The ad networks exchange information through cookies, which allow them to recognise you when you visit any site that they work with (not just Reach sites). Where we use cookies on our sites for advertising purposes, we will always ask for prior consent and where you provide your consent the cookie information will be used along with other information, we hold about you to display digital advertising that is more relevant to you. It is important to note, however, that where you do not provide your consent for digital advertising you will still see digital advertising on our sites, but this will not be tailored to your interests and preferences.
+#### **3.2.1. The data collected and how it is used**
+On your first visit to one of our sites or apps (and on other occasions to allow you to change your mind), you will be presented with a "cookie banner". This asks you if you consent to the use of cookies and related technologies for the purposes of, amongst other things, selecting and delivering ads. If you do, then the ad networks will be able to recognise your device according to a unique identification number.
+We then send out a "bid request" to the advertising networks we work with. What that bid request says is, essentially, "ID number ABC123 has landed on our website, do you want to show this user an advert?" The winner then gets to display their ad.
+The auction process happens automatically, in the second or so between you requesting the page and it loading and displaying. The data used by the ad networks to select the ad to show is held by them, not us, and we never see it.
+An important point to understand is that most of these ad networks will not know who you are in a "real world" sense. They will not know your name, or your email address, or your phone number (we may know those things because you've given them to us in other contexts, but we never share that information with them).
+We say "most" because there are two significant exceptions, which are Facebook and Google. They make their money by providing targeted advertising services based on the things they know about their users, and so if you are signed into your account with them on your device, they will be able to recognise you and associate your browsing history across sites that use their services.
+Additionally, when you browse our websites or use our mobile applications and when you provide your email address on these (either to log in, or sign up to a newsletter, or similar) we may share it, in hashed, pseudonymised form, with our partner LiveRamp Inc and its group companies, acting as joint controllers. LiveRamp uses this information to create a secure online identification code for the purpose of recognising you for cross-channel advertising. This code is placed in our cookie, does not contain any of your identifiable personal data, and will not be used by LiveRamp to identify you. It may be shared with our advertising partners and other third-party advertisers globally for the purpose of enabling interest-based content or targeted advertising through Reach sites. These third parties may in turn use this code to link demographic or interest-based information you have provided in your interactions with them to the pseudonymised code. Detailed information on LiveRamp's data processing activities is available in [LiveRamp's privacy notice and opt-out](https://liveramp.uk/privacy/service-privacy-policy/). You have the right to withdraw your consent or opt-out to the processing of your personal data at any time via our Cookie Management Platform accessed via the 'cog' icon at the bottom left of every webpage.
+#### **3.2.2. Our legal basis**
+The advertising networks undertake this activity on the basis of your consent, which we ask for on their behalf through the 'cookie banner' which appears when you first visit our site. The 'cookie banner' message box will reappear from time to time in case you change your mind, or when something changes (typically every 30 days). Please see our [Cookie Notice](https://www.mirror.co.uk/cookie-policy/) for further information or the 'cog' icon at the bottom left of every webpage to manage your consents. When using our apps if you want to change the settings, go to the 'My Account' Link at the bottom of the screen which includes 'My Privacy' and takes you to the CMP.
+Most of our third-party advertising partners operate within an industry framework and code of practice issued by the [Internet Advertising Bureau (IAB)](https://iabeurope.eu/) called the "Transparency and Consent Framework", which sets out the technical means for your choices to be passed through the ad networks. It also requires that members adhere to IAB policies and standards of behaviour.
+Advertising partners who do not work within the IAB framework are listed separately in the platform which can be viewed in our Consent Management Platform (CMP) - please see our [Cookie Notice](https://www.mirror.co.uk/cookie-policy/) for further information or click on the 'cog' icon at the bottom left of every webpage. In the Consent Management Platform popup go to the 'Partners' page and scroll down - IAB partners are listed first, then you'll see Non-IAB vendors and finally Google partners.
+#### **3.2.3. How long we keep it for**
+We do not ourselves hold a copy of the data gathered by the advertising networks. They will each have their own retention policies which you can find in their privacy notices linked through our 'cookie banner' - these are often short (between 30 and 60 days), because shopping interests change over time.
+#### **3.2.4. Who we share it with and why**
+When we participate in auctions for unsold advertising space, we send bid requests to third party advertising networks. You can find the list of third-party advertising networks who we work with by clicking on the 'cog' icon at the bottom left of every webpage and reviewing our Consent Management Platform.
+#### **3.2.5. Whether we send it abroad**
+The digital advertising networks are global in nature and so, while we are predominantly a UK business, this data will travel across international borders, and in particular many automated advertising transactions will be processed in the USA. Where we are the ones making the transfer (typically, we are not), we have implemented the required safeguards as necessary (for example, standard agreements approved by the relevant authorities).
+### **3.3. Making our sites and apps work properly, diagnosing problems with them, and understanding how they are used so we can make them better**
+We use the information logged by our servers and certain third-party analytics tools (such as Google Analytics, Mpulse and Hotjar) to help us to spot problems with our digital services, such as page errors or slow loading times, as well as understanding usage patterns and watching for security problems. You can find more information below.
+#### **3.3.1. The data we collect and what we do with it**
+We gather data for this purpose in two ways.
+Firstly, our servers record certain information provided by your devices when they request content, consisting mostly of technical information about your device such as language, screen size and the features and functions it supports, but also including the internet or "IP" address from which it is connecting, and the page or data requested. The data is used for system performance, content delivery and security purposes. It is saved together with the dates and times the requests occurred into files stored on our servers called "logs" or "log files".
+Secondly, on your first visit to one of our sites or apps (and every so often again after your first visit), you will be presented with a 'cookie banner' asking you if you consent to the use of cookies and related technologies for our use of analytics. If you do, then several "cookies" (small text files) will be stored on your device containing identification numbers. Those numbers can then be read on your subsequent visits to recognise your device, and our analytics providers will use that information to provide us with various reports and metrics on how our sites are used. Google also uses the data that it gathers as a result for other purposes, which you can read about in [Google's Privacy Policy](https://policies.google.com/privacy).
+#### **3.3.2. Our legal basis**
+We process the personal data captured in our server log files on the basis of our legitimate interest in monitoring our systems, understanding how they are used, fixing problems with them, and for security monitoring and management purposes.
+We process the personal data captured by our analytics providers on the basis of your consent, which we ask for through a "cookie banner" which appears when you first visit our site. That message box will reappear from time to time in case you change your mind (typically every thirty days), and on your first visit after we make a significant change.
+#### **3.3.3. How long we keep it for**
+We keep the information in our server log files for up to 90 days, depending upon the log type and purpose.
+Our analytics providers will keep the information they gather from our sites and apps in line with their own privacy notices, which you can access through our 'cookie banner' and Consent Management Platform (see the 'cog icon' at the bottom left of every webpage) .
+#### **3.3.4. Who we share it with and why**
+We use AWS and CloudFront to help us to analyse our server log files. They act at our direction, as our "processor".
+The information gathered using Google Analytics is held by Google and is made accessible to us by Google through various dashboards and reporting tools.
+The following providers are key to providing additional website analytics or diagnostic capability:
+- Akamai Mpulse ([https://www.akamai.com/legal/privacy-and-policies](https://www.akamai.com/legal/privacy-and-policies))
+- Chartbeat ([https://chartbeat.com/privacy/](https://chartbeat.com/privacy/))
+- Hotjar ([https://www.hotjar.com/privacy/](https://www.hotjar.com/privacy/))
+- Viafoura ([https://viafoura.com/privacy-policy/](https://viafoura.com/privacy-policy/))
+#### **3.3.5.Whether we send it abroad**
+The technology providers we use are global businesses. The data is located in Ireland with some being routed through AWS outside of the UK and EEA. We have implemented the required safeguards as necessary (for example, standard agreements approved by the relevant authorities).
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **4\. When you create or sign into your online Reach account**
+Some elements of our websites and apps require you to create an account in order to use them; for example, the ability to leave comments under articles or to use some of the functions of "InYourArea". We use your email address and the other information that you give to us as part of the account creation process to operate your account and provide those functions. When you are signed in with your Reach account, we will also have the ability to associate your account details with the information we gather through our analytics tools about how you use our sites.
+### **4.1. The data we collect and what we do with it**
+When you create an account we may collect your name and email address.
+For services that provide local information (like InYourArea) we will also collect your postcode and any associated areas of local interest that you want to be updated about.
+Some services may let you upload your own content to our sites, such as comments or pictures. Those things will, by the nature of the service, be generally visible on the site. Your comments may be used in print, online or on the social pages for brands owned and published by Reach plc. We may also record what types of content you have commented on, and associate this with our profile of you. Please do not provide any personal data which you do not want to be published. Comments will be subject to moderation checks before publication.
+We use this information to operate your account and to enable you to log in and use our services; for example, on InYourArea we use your postcode to identify the correct local information to display to you.
+You may also be invited during the account creation process to subscribe to one or more of our newsletters, or to opt in to receive certain special offers and promotions. You can read more about that by navigating to the appropriate section of this Privacy Notice via the ['Contents' list.]()
+Unless you object, we will also associate your online account sign-up data with the other things we know about you, like your page views. You can learn more about that, including how to object, [here.]()
+### **4.2. Our legal basis**
+We process your email address and the other information you give to us in order to provide the relevant function or service of our sites on the legal basis of consent. We associate the data which you provide on sign-up with the profile created from your browsing activity on the basis of our legitimate interest. If you wish to object to this please see section ['Targeting by Reach']().
+Our legal basis for any resulting email marketing is your consent - see [here]() for further information.
+### **4.3. How long we keep it for**
+We will keep your account active for as long as you continue to use it, and for up to 3 years afterwards.
+### **4.4. Who we share it with and why**
+We use a third-party technology provider called LoginRadius \[[LoginRadius](https://www.loginradius.com/)\] to handle the technical aspects of operating your account on our behalf. They host your email address and password. They act as our "processor", meaning that they are bound by law and contract to keep your data safe, and to do only what we tell them to do with it.
+### **4.5. Whether we send it abroad**
+Our user account technology provider LoginRadius is based in California and India, and so your personal data will be processed from those locations as part of their provision of their service to us. We have implemented the required safeguards as necessary (for example, standard agreements approved by the relevant authorities).
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **5\. When we communicate with you by email**
+When you give us your email address we will use that email address to communicate with you for the purpose you provided it; for example, if you sign up for a newsletter then we will use the email address you provide to send you that newsletter. These may include special offers and promotions.
+The links in our emails are unique to your email address, and so if you click on them our servers will attribute that click to your email address and that information will be associated with your unique identifier [(3.1. Targeting by Reach)](). If you choose to allow your email program to load the images in our emails, we will also be able to see that you opened the email. You can find out more about each of these activities below.
+### **5.1.Sending you the newsletters you subscribe for**
+When you subscribe to one of our email newsletters, we will send those newsletters to the email address you provided. If you want us to stop, the easiest way is to click on the "unsubscribe" link which you will find at the bottom of every email. You can find more details below.
+#### **5.1.1. The data we collect and what we do with it**
+We collect your name and email address in order to send you the newsletters you subscribe to. When you sign up for newsletters from our "In Your Area" local information website, we will also collect your postcode in order to provide the correct local information.
+Sometimes, our newsletters will contain advertisements.
+Unless you object, we will also associate your newsletter subscription with the other things we know about you, like your page views. You can learn more about that [here]().
+#### **5.1.2. Our legal basis**
+We use your email address to send you the newsletters you subscribe for on the basis of your consent. You can withdraw that consent at any time. The easiest way to do so is to click on the "unsubscribe" link at the bottom of every newsletter we send.
+We associate your email subscription with the other things we know about you on the basis of our legitimate interests. You can learn more about that [here]().
+#### **5.1.3. How long we keep it for**
+We will keep your email address on the subscription list for the relevant newsletters until you unsubscribe from them. Furthermore, we will stop sending you a newsletter if we see no activity (e.g. no links clicked on) for a period of time, and generally but not exhaustively, after 24 months.
+#### **5.1.4. Who we share it with and why**
+Third party processors provide the technology platforms which we use to administer our email lists and to manage the adverts in our emails. They act as our "processors", meaning that they are bound by law and contract to keep your data safe, and to do only what we tell them to do with it.
+#### **5.1.5. Whether we send it abroad**
+Email administration data is hosted within the EEA. Advert management services data is processed from the UK and EEA.
+### **5.2 Sending you special offers and promotions, with your consent**
+When you give us your email address, we will sometimes also ask you if you would also like to receive promotions and special offers from us. If you agree, then we will send you occasional offers and promotions to the email address that you gave us. You can unsubscribe at any time.
+#### **5.2.1. The data we collect and what we do with it**
+We will use the email address you give to us to send our offers and promotions to you. It will always be clear who the offer or promotion has come from, and we don't sell or give our email lists to anyone else.
+#### **5.2.2 Our legal basis**
+We do this on the basis of your consent. You can withdraw that consent at any time. The easiest way to do that is to click on the "unsubscribe" link which you will find at the bottom of every email.
+#### **5.2.3. How long we keep it for**
+We will keep your email address on the list for promotions and special offers until you unsubscribe from them. We will also stop sending you promotions and special offers if we see no activity (e.g. no links clicked on) in 24 months.
+#### **5.2.4. Who we share it with and why**
+A 3rd party processor provides the technology platform which we use to administer our email lists. So, they will host the data containing your email address on our behalf. They act as our "processor", meaning that they are bound by law and contract to keep your data safe, and to do only what we tell them to do with it.
+#### **5.2.5. Whether we send it abroad**
+The data is hosted and processed within the EEA.
+### **5.3. Tracking technologies used in our emails**
+If you tell your email application to load images we will know when you open one of our emails. When you click on links in our emails, we will know that it was you who clicked on it. We use this information to inform the content of future newsletters (by looking at what's popular), and to understand whether you continue to be interested in receiving them.
+Unless you have previously objected, we will also associate that information with other things we know about you. You can learn more about that [here]().
+#### **5.3.1. The data we collect and what we do with it**
+We track engagement with our emails in two ways.
+Firstly, as for most email newsletters and promotions worldwide, our emails don't attach any pictures they use to the email itself, but instead load them from a remote server on demand. By default, most email programs don't load remote images automatically, but only when you click on the button or link in the program to "show images" (or similar wording). When you do that, the images linked in the email are downloaded from our technology provider's server so they can be displayed in your email program.
+If the images are downloaded, our technology provider can tell us that you opened the email.
+Secondly, the links in our emails to articles and other external content are personalised, such that if you click through to the content using the link in our email, we will know that it was you who clicked it (or at least, someone reading the email we sent to you).
+We do this to help us to understand how you engage with our emails.
+#### **5.3.2. Our legal basis**
+We record the opening of emails on the basis of your consent. You can withdraw your consent at any time either by configuring your email client not to load images, or by unsubscribing from the relevant email.
+We use the personalised URLs for links to external content on the basis of our legitimate interest in understanding how you engage with our emails and which kinds of content are of most interest to you. You can object to this use of your personal data by contacting [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) .
+#### **5.3.3. How long we keep it for**
+The data gathered to understand email opening and interests related to articles and links within the emails is retained for as long as you continue to engage with our emails, and for a period of up to 3 years afterwards.
+#### **5.3.4. Who we share it with and why**
+Third party processors provide the technology platforms which we use to administer our email lists and to manage the adverts in our emails. They act as our "processors", meaning that they are bound by law and contract to keep your data safe, and to do only what we tell them to do with it.
+#### **5.3.5. Whether we send it abroad**
+The data is hosted in the Republic of Ireland, the UK and Denmark.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **6\. When you enter a competition or prize draw**
+From time to time we run competitions and prize draws which require you to provide your name and contact details. We use that information to administer the competition or prize draw and to communicate with you about it (for example if you win a prize).
+We may also use that email address to send you occasional special offers and promotions, if you opted in to receive them. [See here]() for more information on that and how to unsubscribe.
+Unless you have objected, we will also associate the fact that you entered the competition with the other things we know about you, like your page views. You can learn more about that [here]().
+### **6.1 The data we collect and what we do with it**
+When you enter a competition or prize draw we will collect the information you provide to us, such as your name, email address and answers to any questions. We will use that information to run the competition or prize draw. If you happen to win a prize, we may ask you for additional information, such as an address to send the prize to.
+### **6.2 Our legal basis**
+We do this on the basis that it is necessary to fulfil the contract formed with you when you enter the competition or prize draw.
+### **6.3 How long we keep it for**
+We will keep your competition entry for the duration of the competition and for up to 90 days after the closing date.
+### **6.4. Who we share it with and why**
+Information about competition and prize draw entries is only shared with the service providers who provide us with the technology powering our systems and - if you win a prize - with the companies who supply and deliver the prize to you. The technology providers act as our "processors", meaning that they are bound by law and contract to keep your data safe, and to do only what we tell them to do with it.
+### **6.5. Whether we send it abroad**
+Our online form technology provider may process your personal data outside of the UK and EEA. We have implemented safeguards to secure and limit the processing of the data, including standard agreements approved by the relevant authorities.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **7\. When you complete a survey**
+Sometimes we run surveys to help us to understand more about our readership or about public opinion generally. We use your answers to those surveys to produce anonymous statistics which we use to inform our editorial content and, to an extent, our advertising. For example, if a majority of survey respondents express a preference for one TV show over another, then we might write an entertainment piece based on that or factor it in when deciding which adverts appear where.
+Occasionally, those surveys might ask you about things which the law considers to be especially sensitive, such as your voting intentions or your religious beliefs. Where that's the case, we'll ask clearly for your permission first, and we'll always provide a "prefer not to say" or similar option. We don't use that kind of information for advertising purposes.
+### **7.1. The data we collect and what we do with it**
+We will collect your answers to the survey questions and use them to compile anonymous statistics along the lines of "35% of people preferred X over Y". Some surveys may also ask for your email address, for example if we are offering entry into a prize draw for completing it. [Go here]() to learn more about how we use your data for prize draws.
+When you have completed a survey, you may be invited to subscribe to a newsletter or to receive special offers and promotions from us.
+Sometimes we may operate "panels" of people who we send survey questions to periodically. If you join one of those panels then there may be additional kinds of information about you which we will receive, in which case we will provide further information to you before you sign up to the panel.
+### **7.2 Our legal basis**
+We collect and compile your survey answers on the basis of your consent, which we ask for in each survey.
+### **7.3. How long we keep it for**
+We retain your survey responses for however long the survey runs for, and for up to 90 days afterwards. The resulting statistics may be kept longer, but those are always anonymous and don't contain your personal data.
+### **7.4. Who we share it with and why**
+We typically publish the overall results of our surveys, and often share those results with the brands involved (if any), but those results are always anonymous and statistical in nature ("50% of respondents thought X") and don't contain your personal data. Actual survey responses are only shared with the service providers who provide us with the technology powering our systems. They act as our "processors", meaning that they are bound by law and contract to keep your data safe, and to do only what we tell them to do with it.
+### **7.5. Whether we send it abroad**
+Our online form technology providers may process your personal data outside of the UK and EEA. We have implemented safeguards to secure and limit the processing of the data, including standard agreements approved by the relevant authorities.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **8\. When you subscribe to our print or "Digital Edition" titles**
+When you subscribe to one of our print titles, we will collect your name, address other contact details, and payment information. We will use that information to administer your subscription. We do this on the basis that it is necessary in order to provide the subscription to you with the support of our provider. We will retain this information for as long as you maintain your subscription, and for a period thereafter, in case of disputes or problems.
+When you subscribe to our digital edition titles your subscription is also processed via our provider and this information is retained for as long as you maintain your subscription, and for a period thereafter, in case of disputes or problems.
+As part of the subscription process you may be asked if you want to receive other products or services from Reach. Where this is the case you will be asked to consent to each product or service type. Such activities are managed in accordance with the relevant sections elsewhere in this Privacy Notice.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **9\. When you place a classified ad**
+When you place a classified ad in one of our print titles, we will collect your name and contact details, your payment information, and of course the content of your ad. We will use that information to publish and administer your ad, and to communicate with you about it. The content of your ad will be published and therefore accessible to the public. We do this on the basis that it is necessary to fulfil the contract agreed with you when you place your ad.
+We will retain the contact details of private individuals for up to 6 years from the point of last interaction, and trade contact details for as long as we have a business purpose. We do not store personally identifiable payment card information.
+Your ad itself will be retained indefinitely, on the basis of our legitimate interest, in order to maintain our archive and back issues services.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **10\. When you apply for a job with us**
+When you apply for a job with us, we will process the information you or the recruitment agency gives to us in order to consider your application and to communicate with you (or the agency) about it.
+If we offer you a position and you accept it, then we will use your information to liaise with you about start dates, contracts, arranging induction and so on, and we may ask you for additional information to that end. That information will then be handled in accordance with our internal HR policies and Employee Privacy Notice.
+If we don't offer you a position or we do but you don't accept it, then we will keep your application on file for 12 months in case of future queries or issues.
+We process your data on the basis that it is necessary in order to take steps to enter into an employment contract with you. We process information relating to unsuccessful applications or job offers that are not accepted on the basis of our legitimate interest in keeping records of job applications.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **11\. When you work at other organisations that we do business with**
+For all of our customers and other organisations we do business with, we will have the business contact details of the people we work with at those organisations, and we will use them to manage and administer our relationship with that organisation. We do this on the basis of our legitimate interest in managing and administering those relationships.
+If you work at a current or prospective advertising or publishing services client or related agencies, revenue sharing partners (for the sale of your products or services) or are users of Reach software we will also contact you from time to time using your work contact details to promote our services. We will have those contact details either because we have worked with you before, you shared them with us for this purpose, because we or our agencies have looked them up from publicly available information, or because you have attended an event we have hosted. We do this on the basis of our legitimate interest in promoting our advertising and publishing services to businesses. We will always stop contacting you for this purpose if you ask us to. Typically, the best way to do that is to respond to the person contacting you, but you can also make the request to [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com).
+We keep the details of our contacts at organisations we do business with for as long as we continue to have a business relationship, and for a period thereafter for business development purposes and in case of issues or disputes.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **12\. Site visits and CCTV at our premises**
+When you visit a Reach site we will record your name, the date, and in some locations your company name. This information is retained for one week.
+In some circumstances, non-employees may be provided with a site pass. Where this applies, the personal data obtained, including a photograph of you, will be retained for the duration of your visit or contract with Reach and for 7 years thereafter for fraud, security, and financial reporting purposes.
+We use CCTV systems at our premises on the basis of our legitimate interest in protecting the safety and security of our staff and our property.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **13\. Further data sharing by Reach**
+Further to the data sharing described elsewhere in this Privacy Notice, Reach will disclose your information and co-operate with appropriate bodies and authorities in good faith where we are required to by law, a court order, a regulatory authority, or otherwise, including with the police, trading standards, regulatory authorities, other relevant authorities, or credit reference agencies.
+Where permitted by applicable laws, where you interact with us, we may monitor, record, and retain all associated data, correspondence, and communications, such as written letters, telephone call recordings, emails, text messages, social media messages, in person meetings and any other communications. We will do this to, (i) comply with our legal and regulatory obligations (ii), prevent, or detect crime (iii), maintain appropriate evidential records (iv), protect the security of our communications systems and (v) for training and quality purposes. Where necessary, we will also use your personal information to defend ourselves from any legal claims brought by you in connection with the provision of our products and services.
+We will also use personal information to manage and administer our business generally.
+We will share information with security consultants and IT security system providers, where necessary, to monitor and manage data security and the security of our sites and networks, and to develop security threat intelligence data.
+We may also share information to facilitate the sale of one or more parts of our business, including if we are approached by a potential buyer or the restructuring of one or more parts of our business and with auditing organisations such as the Audit Bureau of Circulation.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**
+## **14\. Your rights and how to exercise them**
+The law gives you certain rights over your personal information.
+You can exercise your rights by contacting our group Data Protection Officer's team on [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com). It is helpful to be as specific as possible about what you want us to do or what information you are looking for, because it enables us to respond to you more quickly.
+Depending on your request, we may ask you to prove your identity to us first, in order to make sure that someone isn't impersonating you. For example, if you contact us about your Reach account using a different email address, we may first require you to prove that you control the email address which you used to set up the account. If you want information about a subscription or some other paid service then we may ask you to provide the last four digits of the credit card used to pay for it.
+Most of your rights do have exceptions to them, designed to protect the rights of others or to ensure that we can comply with the law and operate our business in a prudent manner (for example, by keeping certain records). If we decline all or part of your request on the basis of one or more of those exceptions, we will tell you that we are doing so, and we will explain our reasons. We may also reject your request entirely if it is excessive or unfounded.
+### **14.1. Your right to access the information we hold about you**
+You have the right to have access to the information we hold about you. There are a few exceptions to that right, designed to protect the rights of other people.
+### **14.2. Your right to have inaccurate information about you rectified**
+If we hold information about you that is factually inaccurate (for example, we have spelled your name wrong) then you have the right to have it corrected. This right does not extend to matters of opinion; for example, moderation decisions we might make about your comments on our websites.
+### **14.3. Your right to have your information erased in some circumstances**
+You may have the right to have some or all of your information deleted, principally if the information you want deleted is no longer needed or if we don't have a legal basis to continue using it (for example, if we are using it on the basis of your consent and you withdraw your consent).
+### **14.4. Your right to withdraw your consent**
+If we're relying on your consent to do something with your information (for example, to send you newsletters) then you have the right to withdraw that consent at any time.
+For newsletters and other email communications, you can do this by clicking the "unsubscribe" link at the bottom of the message.
+For targeted advertising on our websites, you can access the screen to do this by clicking the "Privacy" tag with the 'cog' icon in the bottom-left of the screen to go to the Consent Management Platform (CMP).
+For targeted advertising in our apps, you will be presented with the CMP on initial download and whenever it is updated thereafter. You can also change your CMP settings by navigating to 'My Account' at the bottom of the app screen and clicking on 'My Privacy'.
+### **14.5. Your right to object to what we do with your data, and to have restrictions placed upon it**
+If we are doing something with your data not on the basis of your consent but on the basis of our "legitimate interest", then you have the right to object to what we are doing, and we must stop unless we can show that there is a compelling and legitimate reason to continue or what we are doing relates to a legal claim. Activities such as fraud prevention will fall into that category.
+In the case of direct marketing and profiling, your right to object is absolute. Regardless of what other mechanisms we may make available, you can always object by unsubscribing from marketing emails and by rejecting the use of cookies on our websites (see the Privacy 'cog' at the bottom left of every webpage). When using our apps if you want to change the settings, go to the 'My Account' Link at the bottom of the screen which includes 'My Privacy' and takes you to the Consent Management Platform (CMP).
+### **14.6. Your right to restrict what we do with your information in some circumstances**
+In certain circumstances, you have the right to restrict our use of your information to simply storing it and using it only for legal claims, protecting the rights of others and matters of important public interest. Those circumstances are: if you dispute the accuracy of information we hold about you; if we do something unlawful with your information but you don't want us to delete it; if we don't need the information anymore but you want us to preserve it in connection with a legal claim; or for the duration of the period in which we are considering a valid objection you have raised under your right to object discussed above.
+### **14.7. Your right to portability**
+You have the right to receive the personal data concerning you which you have provided to a controller in a portable electronic format, or have it transmitted to another controller, where processing is based upon consent and undertaken by automated means.
+### **14.8. How to Complain**
+If you have a complaint or disagree with a decision we have made, we ask that you discuss it with us first by contacting the group Data Protection Officer at [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) or via the address given at the top of this Privacy Notice.
+You also have the right to complain to your data protection supervisory authority.
+In the UK this is the Information Commissioner's Office:
+The ICO's contact information is:
+Information Commissioner's Office Wycliffe House Wilmslow Cheshire SK95AF
+ICO website: [https://ico.org.uk](https://ico.org.uk/)
+Helpline Number: 0303 123 1113
+In the Republic of Ireland, it is the Data Protection Commissioner:
+Fitzwilliam Square South Dublin 2 D02 RD28 Ireland
+[https://www.dataprotection.ie](https://www.dataprotection.ie/)
+The phone number is 01 7650100 / 1800437 737
+If you are based in another EU country, you can find the details of your local supervising authority [here](https://edpb.europa.eu/about-edpb/about-edpb/members_en).
+### **15\. Privacy Notice last updated: 03/05/22**
+We may update this privacy policy from time-to-time by posting a new version on our websites. You should check this page occasionally to ensure you are happy with any changes. Where changes are material, we may also notify you of them by email.
+**[\*\*\* Click here to go back to 'Contents' \*\*\*]()**