=================================================================== --- 20251101_rev01 +++ 20260811_rev01 @@ -1,25 +1,25 @@ ## Reach Group - Privacy Notice We have organised this Privacy Notice based on the different ways you might interact with us and what you might want to know. 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'' -Last update: 16 October 2025 +Last update: 31 July 2026 ## CONTENTS 1. **[Who we are and how to contact us]()** 2. **[About this Privacy Notice]()** 3. **[When you browse our websites and use our apps]()** 4. **[When you create or sign into your online news or other Reach account]()** 5. **[When you buy a product or service from us]()** 6. **[When you opt to receive newsletters or marketing communications]()** 7. **[When you enter a competition or prize draw]()** 8. **[When you complete a survey]()** -9. **[When you subscribe to our print, online or "e-publishing" titles, or place a classified ad]()** +9. **[When you subscribe to our print, online or Premium subscription sites, or place a classified ad]()** 10. **[When you visit or interact with us on social media]()** 11. **[When you apply for a job with us or work at other organisations we do business with]()** 12. **[Further ways we may receive, use and share your data]()** 13. **[How we keep your data secure, why we may keep it and countries we may transfer it to]()** 14. **[How we ensure we protect children's privacy]()** 15. **[UK and EU residents: your rights and how to exercise them]()** @@ -40,13 +40,13 @@ 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 by submitting the relevant form accessible within the 'Your rights and how to exercise them' section by emailing [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) or by writing to 'The Data Protection Team' at the address above. If you are a Spanish speaker see section 16.3.3 on how to exercise your rights. Alternatively, if you are from the US you may also contact us at: - By email: [privacyofficer@reachplc.com](mailto:privacyofficer@reachplc.com) -- By mail: Privacy Officer, Reach Plc, 19th Floor, 200 Liberty Street, New York, NY 10281 +- By mail: Privacy Officer, Reach Plc, 14 Wall Street, FL 20, New York, NY, 10005 **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** ## 2\. About this Privacy Notice This Privacy Notice tells you about the kinds of information we hold about you, what we do with it, and why. @@ -89,14 +89,18 @@ Fax: 01 6740046 **Our use of Artificial Intelligence** We are increasingly using Artificial Intelligence (AI) tools, to help us enhance our content and streamline our processes. -Meeting the data protection requirements of our consumers is at the forefront of our AI decision making, and we ensure we review and assess any personal data which may be involved in light of data protection requirements and evolving guidance. This includes conducting assessments, ensuring the accuracy of data sets used and human review of outputs. For more information on AI see our AI Notice on each website footer. +Meeting the data protection requirements of our consumers is at the forefront of our AI decision making, and we ensure we review and assess any personal data which may be involved in light of data protection requirements and evolving guidance. This includes conducting assessments, ensuring the accuracy of data sets used and human review of outputs. For more information on our use of AI see our AI Notice on each website footer. +We also use AI tools to systematically archive, tag, and structure our published historic journalism. This includes training internal archival models to transform our library into a structured knowledge base. This knowledge base is used exclusively by Reach journalists as a reference source to support their ongoing research and reporting activities intended for publication. + +Beyond our internal operations, we also partner with global technology providers to license our content for the development, fine-tuning, evaluation, and ongoing improvement of artificial intelligence models. When we share content for these purposes, we implement strict contractual safeguards to protect personal data from misuse and ensure the original context of our journalism is respected. For specific details on these partnerships, please see **Section 12.13 Artificial Intelligence Partners.** + **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** ## 3\. When you browse our websites and use our apps When you browse our websites or use our apps, we may collect technical and/or behavioural information about your use of our websites or other content online, and the device(s) you use to access the services. For example, this information may include details about how you browse our website and the devices and technology you use to browse our website. This may also include unique online identifiers such as device ID, device type, IP address and approximate location at the time of browsing. This may also include video viewing data and may link to your activity on other sites and allow us to recognise you or your device. We may use this to build a more detailed profile of you and your interests. We may also provide you with location-based services (for example, advertising and other personalised content), where we collect geo-location data. @@ -107,23 +111,23 @@ [3.1 Targeting by Reach]() [3.2 Targeting by third party advertising networks]() [3.3 Making our sites and apps work properly and understanding how they are used]() -[3.4 Website Notifications (Pop ups)]() +[3.4 Website notifications and in-app messaging]() **3.1 Targeting by Reach** 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 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. **3.1.1 The data we collect and what we do with it** The data we use for this purpose is as follows: -- The page you view, and associated information such as how long you spend on them. +- The page you view, and associated information such as how long you spend on them and other engagement data such as articles read, visit frequency, and paywall interactions. - Your approximate location, to city or town level. - 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 or marketing, when you enter one of our competitions or when you complete one of our surveys. - The newsletters and marketing you have subscribed to, the promotions and competitions you have entered and the surveys you have completed. 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. @@ -190,16 +194,34 @@ From time to time we may allow our clients to compare their customer database to ours using partner platforms such as InfoSum. This is called data matching and allows our partners to see if they can reach their audiences on our platforms and to understand if an advertising campaign would be effective. Generally this will be conducted at an aggregate audience level to provide insights, rather than individual level information, although your information may be used to generate these insights. For example, this could involve matching your hashed, pseudonymised email data with the same data held by our advertising clients. This then enables the advertiser to understand if you use their products and visit our sites, then to use this data to target bespoke advertising messages. Alternatively, we may allow advertising partners to build target audiences based on predefined attributes. These 'lookalike' audiences may be similar to our partners' existing audiences. For example, a sports brand may want to reach 'football enthusiasts'. They could select audiences who have been identified as having an interest in these areas. To do this, we segment our audiences into groups depending on what we think they like or other behaviours. This helps them find the right audiences and we are able to show you more relevant advertising. -The way we match your data could also involve working with partners such as Tradedesk and their group companies, acting as joint controllers. These partners use 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 them to identify you. With your consent 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. Information on the Trade Desk's use and how they work with partners can be found here [EUID Privacy Notice](https://www.transparentadvertising.eu/privacy). Alternatively to withdraw consent and object to targeted advertising based on the Trade Desk EUID activity click [here](https://www.transparentadvertising.eu/). We also work with partners such as LiveRamp Inc, acting as our processor. Detailed information on LiveRamp's data processing activities is available in [LiveRamp's Privacy Notice](https://liveramp.uk/privacy/service-privacy-policy/) and opt-out [here](https://optout.liveramp.com/opt_out). +The way we match your data could also involve working with partners such as Tradedesk and their group companies, acting as joint controllers. These partners use 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 them to identify you. With your consent 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. Information on the Trade Desk's use and how they work with partners can be found here [EUID Privacy Notice](https://www.transparentadvertising.eu/privacy). Alternatively to withdraw consent and object to targeted advertising based on the Trade Desk EUID activity click [here](https://www.transparentadvertising.eu/). +We also work with partners such as LiveRamp Inc, acting as our processor, who will use your hashed, pseudonymised email data to create an ID which helps us recognise you across the web without sharing your actual identity. This cookie lives in your browser. If we receive your consent, via the CMP, we will then use this data to target you. Detailed information on LiveRamp's data processing activities is available in [LiveRamp's Privacy Notice](https://liveramp.uk/privacy/service-privacy-policy/) and opt-out [here](https://optout.liveramp.com/opt_out). + If you accept the use of cookies in our Consent Management Platform, when you submit your email address to create an account or sign-up to a newsletter or marketing we may share your email address in a hashed form with Amazon Publisher Services (APS). APS then links the hashed email to a profile which they may already hold related to that address. The hashed email will be used in a secure, pseudonymised form within a cookie to flag to APS whenever you visit an APS enabled Reach website again. APS will use this to determine, in real-time, if any of their business customers want to market to a profile similar to yours. If this is the case they may initiate an advert which will appear to you on the Reach website concerned. The APS Privacy Notice can be found at [APS PN](https://aps.amazon.com/aps/privacy-policy/). Alternatively to withdraw consent and object to targeted advertising based on APS activity click [here](https://www.amazon.com/gp/help/customer/display.html). You can also visit [www.youradchoices.org](https://www.youradchoices.org/) to have more information about how to manage your ad preferences. +We also partner with Roqad, an identity resolution organisation and data aggregator. When you provide your consent via the Consent Management Platform, Roqad implements a pixel across our websites and applications to collect online identifiers, including cookies, mobile advertising identifiers, and hashed email addresses. This information is processed purely to construct their identity graph and facilitate cross device recognition. You can learn more about their data processing practices or exercise your right to opt out directly by visiting the [Roqad Privacy Notice](https://www.roq.ad/privacy-policy-roqad) and [opt out form](https://roq.ad/opt-out). + +Additionally, we may use advanced matching techniques offered by social media providers that allow us to directly share personal data such as email, in a hashed, pseudonymous form, to be matched with their data. If you provide your consent via the CMP this may then be used to more accurately target you. For more information see [12.4 Social media platforms](). + +To opt out of your email being processed in this way, email [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com), stating 'opt out of hashed email'. + +**Accommodation and Travel Services (Stay22)** We work with [Stay22](https://www.stay22.com/) to provide location-specific accommodation and travel booking maps on our sites. When you interact with a Stay22 map or link, and provide your consent via the CMP, Stay22 may collect data including your IP address, browser type, device identifiers, geographic location, and details regarding travel queries or bookings you make. This data is used to provide relevant accommodation options and facilitate affiliate tracking. To understand how Stay22 handles your data, please review the [Stay22 Privacy Policy](https://www.stay22.com/privacy). + +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 or link at the bottom of every webpage. + +**AI Answer Engine** + +On some or our sites we work with a third party, Taboola, to provide AI-generated summaries and article links sourced from Reach titles. These may also contain ads. Taboola uses [pixels](https://www.taboola.com/marketing-hub/pixel/), [cookies and first party data](https://www.taboola.com/marketing-hub/cookie/) to track user behaviour, such as page views, clicks, device types and IP addresses which helps personalise prompts and enables ads alongside AI generated answers. Information on Taboola's data processing activities is available in [Taboola Privacy Notice](https://policies.taboola.com/privacy-policy/). + +You have complete control over this data. To download, access, or permanently delete your interaction history, please visit the **Taboola Data Subject Portal** at [https://accessrequest.taboola.com/](https://accessrequest.taboola.com/). Since these features rely on digital identifiers instead of your name, you must use the same device and browser for access that you used for your searches. + **Withdrawing consent** 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 or link at the bottom of every webpage. For example, we will only match your hashed, pseudonymised email with an advertiser in the Infosum platform, if you have consented to your data being used by our adtech provider Lotame. We will also only work with partners such as LiveRamp, as described above, if you have accepted cookies in our Consent Management Platform. Alternatively, if you would like to stop your email being used in this way please email dataprotection@reachplc.com, stating 'opt out of hashed email'. @@ -232,13 +254,13 @@ 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 three 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". +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, the page or data requested and tracking interactions (articles read/tabs opened). 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. We also work with the analytics provider Amplitude, who collect measurement data on our behalf, as our processor. They collect this data for us, using their cookie, and only process your personal data with your consent. If you do not consent they will only provide us with anonymised data. Thirdly, Google also uses the data that it gathers as a result for other purposes, which you can read about in the [Google Privacy Policy](https://policies.google.com/privacy). If you wish to opt-out of the use of Google Analytics you can access and download the Opt-out browser add-on from here: [GA Opt-Out](https://tools.google.com/dlpage/gaoptout). To withdraw your consent for how we are using your information, please see [15.4 Your right to withdraw consent.]() @@ -273,13 +295,13 @@ - Google Analytics ([https://policies.google.com/privacy)](https://policies.google.com/privacy) **3.3.5 Whether we send it outside the country of collection** 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 and frameworks approved by the relevant authorities). -**3.4 Website Notifications (Pop ups)** +**3.4 Website notifications and in-app messaging** We provide news and updates about our sites via push notification messages or 'pop-ups'. This is a free service. Our legal basis is consent, as the notifications are only sent to you if you have clicked on a button to allow it (you may have accidentally selected to receive notifications). When you consent to receiving pop-up browser notifications from one of our websites, we collect the following information: - the URL of the page you were on when you were subscribed; @@ -292,36 +314,41 @@ We have no control over your subscription to notifications as it is controlled by your browser and device. We do not store any recognisable data about you or your device in connection with the push notification service. If you wish to unsubscribe from receiving notifications please follow the instructions here: [Airship](https://support.airship.com/hc/en-us/articles/4446152158619-How-to-opt-out-from-the-web-notification) and [One Signal](https://documentation.onesignal.com/v9.0/docs/unsubscribe-from-notifications). If you need additional assistance in relation to push notifications, please contact the team at [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) - with the Subject heading: Push Notifications +**3.4.2 In-App Engagement & Messaging** + +We also use in-app messaging to provide information about our features and premium services based on your engagement with the app. We use service providers (such as OneSignal) to deliver messages within our app. These may include educational prompts about our features or offers for our premium services. To provide a relevant experience, we track certain interactions, such as the number of articles you read or specific sections of the app you visit. You can manage your preferences for these tools via our Consent Management Platform (Privacy Settings) in the app menu. + **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** ## 4\. When you create or sign into your online news or other 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". This section covers the following: - [4.1 Online News account]() -- [4.2 Specialist Accounts including Funeral Notices, Bookanad, Marketplacelive, and Family Notices sites]() +- [4.2 Community Forums]() +- [4.3 Specialist Accounts including Funeral Notices, Bookanad, Marketplacelive, and Family Notices sites]() **4.1 Online News account** 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. **4.1.1 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. If you subscribe to a paid version of our sites such as **Premium** subscription offering or **Privacy Plus** we will collect your payment details, in order for us to fulfil your subscription. For more information on subscriptions see [9\. When you subscribe to our print or "Digital Edition" titles.]() +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. If you subscribe to a paid version of our sites such as **Premium** subscription offering or **Privacy Plus** we will collect your payment details, in order for us to fulfil your subscription. For more information on subscriptions see [9\. When you subscribe to our print, online or "digital edition" titles.]() Some of our sites allow you to log-in to your account quickly by using your existing social media accounts, such as Facebook, X (f/k/a Twitter), Apple or Google. When you choose this option, you are granting permission to such company to share your user information with us. This will include your name and email address plus any other information you have permitted them to share with third parties, and your account will be linked to your social media account. You can ask us to delete your personal data or de-link your account from your social media account by emailing [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com). -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 and may be attributed to user names. 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. +Some services may let you upload your own content to our sites, such as comments or pictures. These contributions are, by the nature of the service, generally visible on the site to other users and the general public and may be attributed to your username. Your comments may also be used in print, online or on the social pages for brands owned and published by Reach plc. We may record the types of content you have commented on, and associate this with our profile of you to better understand your interests. 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 marketing offers and promotions. You can read more about that by navigating to the appropriate section of this Privacy Notice via the 'Contents' list. [Click here to go back to 'Contents'](). 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](). @@ -335,23 +362,31 @@ **4.1.3 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. **4.1.4 Who we share it with and why** -We use a technology provider called [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. +We use a technology provider called [LoginRadius](https://www.loginradius.com/) to handle the technical aspects of operating your account on our behalf, including the secure hosting of your email address and password. Additionally, we work with [Viafoura](https://viafoura.com/) to provide the community engagement platform and related diagnostic and analytics capabilities.These partners act as our "processors," meaning they are bound by contract to keep your data safe and use it only as we instruct. **4.1.5 Whether we send it outside the country of collection** 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 and frameworks, approved by the relevant authorities). -**4.2 Specialist Site Accounts** +**4.2 Onsite Community Forums** +When you participate in our Forums, we collect User-Generated Content (UGC). This includes posts, replies,'likes' and forum-specific metadata (timestamp of posts). If you link your profile, your display name and profile picture will be public. + +We share your data with OpenWeb acting as our processor to host this service. **OpenWeb** may use their AI Driven moderation to moderate forum content to ensure community safety. + +If you have a complaint regarding one of your posts, wish to appeal a decision, or to exercise one of your data protection rights email [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com). + +**4.3 Specialist Site Accounts** + This section covers when you create an account and use our services on the Funeral Notices, Bookanad, Marketplacelive, and Family Notices sites. -**4.2.1 The data we collect and what we do with it** +**4.3.1 The data we collect and what we do with it** In order to use many of our website features you will have to create an account, for example, if you wish to post a funeral notice, upload a tribute to a notice, post an announcement, place an advertisement, or place a notice. When you create an account we will collect, at a minimum, your name and email address. In some circumstances, we may also collect your address and your telephone number. We use personal data as part of the account creation process, and to ensure ongoing operation of your account, and access to the services available on our websites. We use all this personal data to (i) operate your account and to enable you to log in and use our services, (ii) manage and administer your notice, announcement, and/or advertisement, and (iii) provide you with some of the features and functionalities that are reserved for account holders. @@ -364,37 +399,37 @@ When you post a notice and/or an announcement and, as part of this post, provide personal data that relates to a living third party, you are responsible for making sure that you have obtained the appropriate permissions for sharing their personal data. For example, uploading a photograph or a video to a notice that contains the image of another person(s). Some of our services may allow you to upload your own content to our websites, for example any comments, pictures, or videos uploaded as part of an advertisement or a notice. Such content, by the nature of our service, will be visible on the website to other users and the general public. When creating a new notice or announcement, or interacting with an existing one, please do not provide any personal data which you do not want to be published and accessible by the general public. The "controller" for advertising activities on some of our websites is Proweb. See 4.2.7. -**4.2.2 Funeral Notices Pay-to-use services** +**4.3.2 Funeral Notices Pay-to-use services** Once you have created an account on Funeral Notices, our products/services will be made available for purchase. When you purchase a product/service, either online, via our website, or offline, via our call centre, we will use the personal data that you have provided during the account creation process to administer the sale of the product/service you have selected. We may also collect additional personal data in order to enable the sale, including the processing of payment information provided by you during the checkout process. -**4.2.3 Funeral Notices Free-to-use services** +**4.3.3 Funeral Notices Free-to-use services** Some of our Funeral Notice services are made available for free, and may allow you to upload your own content to our websites, for example any comments, pictures, or videos uploaded as part of a tribute. Such content, by the nature of our service, will be visible on the website to other users and the general public. Once you have created an account, some of our products/services may enable the disclosure of information typically viewed as sensitive, for example providing information about your religious beliefs when dedicating a prayer or a religious notice to a loved one. When uploading information to our websites, please do not provide any personal data which you do not want to be published. It is also important to note that all comments on active notices will be subject to moderation checks before publication. When you request either of the above Funeral Notices services and, as part of this service, provide information concerning a living third party, you are responsible for making sure that you have obtained the appropriate permissions for sharing this information. For example, uploading a photograph or a video to a tribute that contains the image of a large number of individuals. -**4.2.4 Notices placed by Funeral Directors** +**4.3.4 Notices placed by Funeral Directors** We offer Funeral Directors across the UK the option to use our service, and to post funeral notices for publication on the relevant area of our website. If you instruct your Funeral Director to post an online funeral notice on our website, then the information that you provide your Funeral Director will be posted on our website. Please note that when collecting information to inform their funeral notice, Funeral Directors will do so as "data controllers". This means that they are responsible for how they handle and use the personal data that they collect from you. -**4.2.5 Our legal basis** +**4.3.5 Our legal basis** We process your email address and the other personal data provided during the account creation process so that we may fulfil the contractual obligations owed for the sale of a product/provision of a service, e.g., the posting of an online and/or in-print advertisement and/or notice. This includes the processing of any payment information that is required to facilitate the sale of such products/services. We process your email address and the other personal data you provide during the account creation process on the basis of your consent for us to provide and operate an account on your behalf. We process any personal data that you upload to our websites to deliver notices on the basis of our legitimate interest in operating an online obituary service. Please note that, when uploading content, you are in complete control of what you post. @@ -402,13 +437,13 @@ We process your payment information in order to fulfil contractual obligations owed for the sale of a product/provision of a service, e.g., the posting of an online and/or print funeral notice. We process any sensitive information you provide regarding your religious beliefs on the condition that, by making a post on a generally accessible website, you have manifestly made the information public. The posting of a funeral notice, by a Funeral Director, is always performed based on the instructions that are provided to individual Funeral Directors by the families of the deceased, and in accordance with the performance of the contract that you have entered into with the Funeral Director. -**4.2.6 How long we keep it for** +**4.3.6 How long we keep it for** As a general principle, we will only retain your personal data for as long as it is necessary. More information on particular retention periods is provided below. **Website data** Our analytics providers will keep the information they gather from our websites 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) @@ -422,13 +457,13 @@ If you have made a purchase, we will keep a record of your transactions for a period of 7 years post-transaction. **Funeral Notice data** All funeral notices, posted by Funeral Directors and the general public, will remain accessible on our website indefinitely, so that the passing of a loved one may remain remembered forever. This will include any tributes posted on a funeral notice, and all other related services, for example remembrances. -**4.2.7 Sharing your personal data with third parties** +**4.3.7 Sharing your personal data with third parties** We will only share your personal data with a third party if there is an appropriate contract in place that binds that third party to act in accordance with our instructions. Further information regarding the third parties that we share your personal data with is detailed below. **Proweb**. We use a third-party provider called Proweb to handle the technical aspects of operating an account on our behalf, managing bookings made through Bookanad, and administering our email lists. In order to provide us with this service, they will process the personal data that you provide when you create an account and place a booking, in addition to other information that is captured from your use of our website. @@ -446,19 +481,19 @@ **Payment processors**. We use third party payment processors to handle payments made through our websites. These third party payment processors may act as both a "data controller", meaning that they define why and how to process the payment information you provide, and a "data processor", meaning that they act in accordance with our specific instructions when processing your transactional data. **Ancestry**. Ancestry is a sponsor of our Funeral Notices website. A link to their website can be found on the sponsorship icon visible on all funeral notices. Please note that by clicking on the ancestry sponsorship area of the funeral notice page, you will be taken to Ancestry's own website, where an automatic search will be performed on the name of the deceased. This search will be performed based on the URL that you have visited Ancestry from. We do not share any of your personal data with Ancestry; however, if you register for an Ancestry account, after following a link within a notice, Ancestry will be able to identify that you came from our website. **AddThis (Oracle)**. We have installed a tool called AddThis, provided by Oracle, on various pages of our websites. This tool provides you with the ability to share a notice on social media platforms of your choice. When you interact with the AddThis tool, and decide to share a notice on social media, AddThis will collect some personal data from your interaction. AddThis collects your personal data as a "data controller", meaning that they will use it for their own purposes. Further information on how AddThis uses personal data can be found in their [Privacy Policy](https://www.oracle.com/uk/legal/privacy/addthis-privacy-policy.html). -**4.2.8 Working at an organisation that we do business with** +**4.3.8 Working at an organisation 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. 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. -**4.2.9 Advertising as a company that we do business with** +**4.3.9 Advertising as a company that we do business with** When you place an ad, e.g. as a funeral director, we will collect your name and contact details, your postcode, 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 7 years from the point of last interaction, and trade contact details for as long as we have a business purpose. Your ad itself will be retained indefinitely, on the basis of our legitimate interest, in order to maintain our archive and back issues services. @@ -495,13 +530,13 @@ - When you join our Loyalty programme we will use the relevant personal data that will allow us to give you rewards, for more details about personal data please see the [Yotpo privacy policy.](https://www.yotpo.com/privacy-policy/) **5.2 Our legal basis** The regulations on data protection outline various reasons for which a company may gather and process your personal data, including: -Consent: In specific instances, we may collect and process your data with your explicit consent. This can happen, for example, when you willingly opt into marketing communications or create an account with us. When gathering your personal data, we will always communicate clearly which data is essential for a particular service. +Consent: In specific instances, we may collect and process your data with consent. This can happen, for example, when you willingly opt into marketing communications or create an account with us. When gathering your personal data, we will always communicate clearly which data is essential for a particular service. Contractual Obligations: Under certain circumstances, we may require your personal data to fulfil our contractual obligations. For instance, when you place an order for delivery, we will collect your address, billing/delivery, mobile and name to ensure the successful delivery of your purchase, sharing these details with a courier as needed. Legal Compliance: If mandated by law, we may be compelled to collect and process your data. For instance, we might share information about individuals involved in fraudulent or criminal activities impacting us or our sellers with law enforcement. Legitimate Interest: In specific scenarios, we may require your data to pursue our legitimate interests in a manner that is reasonably expected in the course of operating our business, and that does not significantly affect your rights, freedom, or interests. For example: @@ -512,13 +547,13 @@ - Combining the shopping history of numerous customers helps us identify trends, meet demand, and develop new products/services. - Your address details may be used to send you direct marketing information by post, informing you about products and services that we believe may interest you. - We may reach out to you for market research and to enhance our services. - With your explicit consent, or if you shop with us and do not opt out of receiving our emails ('soft opt-in'), we may use your personal data, preferences, and transaction details to keep you informed through email, text, telephone, and our contact centres about relevant products and services, including tailored special offers, discounts, promotions, events, competitions, etc. You can opt out of this at any time. - When you come to our eCommerce site via one of our social media websites, we will receive information, such as your name, email and ID (via an API) that will help us detect how you have come on to our site. This helps us to understand how our advertisements are performing on different social media platforms. - We will share your personal data in the fulfilment of our Loyalty Programme. -- Sharing the information you provide and other information held about you within our Group companies, for the purposes of this Privacy Notice. For more information see section [12.9 How we work with Group Companies]() +- Sharing the information you provide and other information held about you within our Group companies, for the purposes of this Privacy Notice. For more information see section [12.16 How we work with Group Companies]() **5.3 How long we keep it for** Reach will retain your personal data in accordance with the law and relevant regulations and will store the data for as long as is necessary to fulfil the purpose for which it was collected. The period for which we keep your personal data will be determined by the purpose for which we are using the data, and our legal and regulatory obligations. **5.4 Who we share it with and why** @@ -555,21 +590,34 @@ From time to time we may transfer your personal data to service providers based outside of the UK and EEA for the purposes described in this Privacy Notice. In particular, we do this in regard to our email and SMS service providers, managing our marketing activities and for the processing of orders, subscriptions and payments. Where these transfers take place, your personal data will continue to be subject to safeguards set out in the law and we have mechanisms in place to ensure your data receives equivalence in protection to that within the UK and EEA. An example safeguard is standard agreements that have been approved by the relevant authorities. For more information see section 13: [How we keep your data secure, why we may keep it and countries we may transfer it to](). **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** ## 6\. When you opt to receive newsletters or other marketing communications -We use the information you provide us with, such as email, address, or phone number, to communicate with you for the purpose you provided it, either based on your consent or where we have legitimate grounds to do so. For example, if you sign up for a newsletter or other marketing communication then we will use the email address you provide to send you that newsletter or marketing, and we may also send you text messages if you have opted in to receive these. These may include special offers and promotions. Alternatively, If you have bought a product from us, from one of our ecommerce sites \[see [5\. When you buy a product from our ecommerce sites]()\], we may send you emails about similar products and services, from the brand you purchased the product from, provided you didn't opt out when we collected your data. +We use the information you provide us with, such as email, address, or phone number, to communicate with you for the purpose you provided it, either based on your consent or where we have legitimate grounds to do so. For example, if you sign up for a newsletter or other marketing communication then we will use the email address you provide to send you that newsletter or marketing, and we may also send you text messages if you have opted in to receive these. These may include information on new products, services, 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](). 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. Our emails may include pixels which enable us to serve non-personalised ads within the newsletter content, via companies such as Passendo and Open Web, acting as our processors. You can find out more about each of these activities below. You can update your marketing preferences at any time. If you would like to unsubscribe (or opt-out) of receiving these emails please click the links on the emails you receive, text STOP to opt out of text messages, or contact dataprotection@reachplc.com. +Alternatively, If you have bought a product from us (or in the process of doing so) from one of our ecommerce sites \[see [5\. When you buy a product from our ecommerce sites]()\], or a Premium subscription \[see [9\. When you subscribe to our print, online or "Premium subscription" sites, or place a classified ad]()\], we may send you emails about similar products and services, from the brand you purchased the product from, provided you didn't opt out when we collected your data. +**Tracking Technologies and Partner Adverts** + +Our newsletters include advertisements served via our partner, Passendo. These advertisements are non-personalised and served purely based on the context of the newsletter topic. + +To manage our email delivery effectively, we utilise limited tracking technologies: + +- **Unique Click Identifiers:** The links in our emails are unique to your email address. If you select a link, our servers attribute that click to your identifier to understand content popularity and to ensure our communications remain relevant. +- **Essential Technical Pixels:** If your email program loads images, a technical request is made to our servers. We use this strictly to verify email deliverability and maintain list hygiene, such as identifying inactive mailboxes. We do not use this to build an ongoing behavioral profile of your reading habits. + +Once you click a link and arrive at our website, our Cookie Management Platform (CMP) will immediately present you with choices to manage your broader website tracking options. + +You can unsubscribe or change your marketing preferences at any time by clicking the links on the emails you receive or by contacting [dataprotection@reachplc.com](https://www.mirror.co.uk/privacy-notice/dataprotection@reachplc.com). + **Working with Partner Companies** -When you give us your email address for marketing purposes, we may convert it into a hashed, pseudonymous form, and subsequently share it with selected partners who use this information to create an online identification code, for the purpose of recognising you on your device.This code does not contain any of your identifiable personal data and cannot be used to re-identify you. +When you provide your email address, we may convert it into a hashed, pseudonymous form, and subsequently share it with selected partners who use this information to create an online identification code to recognise you on your device.This code does not contain any of your identifiable personal data and cannot be used to re-identify you. -We convert your email based on legitimate interest and you can opt out of your email being shared in this way by emailing [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com), and stating 'opt out of hashed email'. For more information on how these partners may subsequently use this code to serve you targeted advertising, with your consent, please see section [Data Matching](). +We convert your email based on legitimate interest and you can opt out of your email being shared in this way by emailing [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com), and stating 'opt out of hashed email'. With your consent via the CMP, we may subsequently share this identifier with ad partner like LiveRamp to serve you ads on our sites. For more information on how these partners may subsequently use this code to serve you targeted advertising, with your consent, please see section [Data Matching](). In addition, we may work with a partner company to send our communications to you. For example, you may have consented to an email from Reach via the Substack platform. For these emails Substack are the controllers of your data, and you will have agreed to their [Privacy Notice](https://substack.com/privacy) when you signed up. You can opt out of receiving their newsletters at any time via the email you receive or by emailing privacy@substackinc.com. **6.1 Sending you the newsletters and marketing you subscribe for** We will use the email address you give to us to send newsletters or our marketing offers and promotions to you. @@ -609,31 +657,30 @@ **6.1.6 Whether we send it abroad** The data is hosted and processed within the EEA. **6.2 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 or marketing (by looking at what's popular), and to understand whether you continue to be interested in receiving them. +We use limited tracking technologies within our email newsletters to check emails have been opened and deliver contextual advertising. -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 in [Targeting by Reach](). - **6.2.1 The data we collect and what we do with it** -We track engagement with our emails in two ways. +We monitor interaction with our email campaigns in the following ways to ensure deliverability and improve our content: -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. +- **Internal Open-Rate Tracking (Pixels):** Our emails load images from our secure remote servers on demand. If your email program or device is set to automatically load images, or if you choose to display them, this request notifies our servers that the email has been opened or read. We use this performance data strictly for internal analytics (such as tracking overall open rates and determining which headlines perform best). +- **Unique Click Identifiers:** The links to articles within our newsletters are unique. If you click a link, our servers attribute that interaction to your email identifier so we know which stories caught your interest. +- **Contextual Advertisements:** Our newsletters include advertisements served via our partner, Passendo. These advertisements are entirely non-personalised and are served based purely on the context of the newsletter topic rather than your individual reading history. +- **On-Site Integration:** Once you click a link and land on our website, our Cookie Management Platform (CMP) initialises. Any further tracking, such as cross-site tracking or behavioural profiling for targeted advertising, takes place exclusively on our website and is subject entirely to the choices you select on our website cookie banner. -If the images are downloaded, our technology provider can tell us that you opened the email. +You can unsubscribe or change your marketing preferences at any time via the links in our emails or by contacting [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com). -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). This is because we use web beacons in our emails to track the success of our marketing campaigns. Our web beacons don't store any information on your computer but, by communicating with our cookies on your computer, they can help us to understand how you engage with our emails. - **6.2.2 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. +**Email Open & Click Tracking:** We measure the basic performance and deliverability of our newsletters based on our legitimate interest. You can control or restrict open tracking at any time by configuring your email client or device to block the automatic loading of remote images. -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 completing the relevant form [Your right to object to what we do with your data, and to have restrictions placed upon it](). +**On-Site Website Cookies:** Any subsequent data processing or targeted advertising that occurs after you click a link and land on our web platform is strictly based on the consent you grant or refuse via our website's CMP banner. **6.2.3 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. **6.2.4 Who we share it with and why** @@ -677,13 +724,13 @@ **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** ## 8\. When you complete a survey Sometimes we run surveys to help us to understand more about our readership or about public opinion generally. They can also help us better understand the underlying motivations behind the trends we are seeing, response to new content ideas and formats we are developing and how we can improve the service we currently offer. -These surveys could be in the form of online surveys, polls, video projects, diary studies and discussion groups, and we record the responses (answers) of those who take part. +These surveys could be in the form of online surveys, polls, video projects, diary studies and discussion groups, and we may record the responses (answers) of those who take part. If you take part, 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. We may also run some surveys for which we utilise your declared responses to build into our profile about you. When we do so, this will be communicated in the associated text, and you will be asked to either consent to this use or will be given the option to 'object' via a tick box. 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. @@ -703,13 +750,13 @@ 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. **8.2 Our legal basis** -We collect and compile your survey answers on the basis of your consent, which we ask for in each survey. Use of your declared data for profiling purposes will be based either upon consent (via tick box) or our legitimate interest, for which you will be given the option to 'object'. +We collect and compile your survey answers on the basis of your consent. Use of your declared data for profiling purposes will be based either upon consent (via tick box) or our legitimate interest, for which you will be given the option to 'object'. **8.3 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. If you participated in our research panel we may keep your data for up to a year, for the purposes of insight and tracking responses over time. The resulting statistics may be kept longer, but those are always anonymous and don't contain your personal data. Data utilised for profiling will be retained for up to 3 years. @@ -725,15 +772,15 @@ **8.5 Whether we send it outside the country of collection** 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 and frameworks approved by the relevant authorities. **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** -## 9\. When you subscribe to our print, online or "e-publishing" titles, or place a Classified Ad +## 9\. When you subscribe to our print, online or Premium subscription sites, or place a classified ad -**9.1 When you subscribe to our print, online or "e-publishing" titles**. +**9.1 When you subscribe to our print, online or "digital edition" 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. @@ -747,14 +794,18 @@ A number of our websites also offer a **Premium** subscription which allows readers to support local journalism with limited adverts and exclusive subscriber-only content. When you sign up for one of the **Premium** subscriptions we may send your details to our third party provider Piano. They will use your details to process your payment and deliver the content you have subscribed to. Please see a link to their privacy notice for more information on how they process personal data. [https://piano.io/gb/privacy-policy/](https://piano.io/gb/privacy-policy/) For more information on both of these subscriptions, and how they work together, see our [T&Cs](https://www.mirror.co.uk/terms-conditions/) -In order to be able to offer you this service on our website, we will collect online identifiers such as device type, IP address, language settings, approximate location at the time of browsing, and your logged in user id. This will be used to enable us to verify you as a paid subscriber, to technically run the service, and for security and anti-fraud purposes. +In order to be able to offer you this service on our website, we will collect online identifiers such as device type, IP address, language settings, approximate location at the time of browsing, your logged in user id, user status, and engagement history. This will be used to enable us to verify you as a paid subscriber, to technically run the service, and for security and anti-fraud purposes. It may also determine the content we may provide to you. We may also collect your reason for leaving to improve our services and, where you have permitted us to do so, to offer you relevant alternatives. +If you are a **Premium** subscriber, we will use your email to send you service messages. These may also include surveys to understand how you use our **Premium** services and how we can continue to improve the platform and content offerings plus collecting feedback during the cancellation process to improve our services. For more information see [8\. When you complete a survey](). + +We may also send you promotional communications including renewal offers, exclusive discounts and other communications about our products and services. You can opt out of these when you sign up to a subscription and in every communication you receive. + **9.2 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. @@ -813,17 +864,22 @@ - [12.3 Behavioural remarketing services]() - [12.4 Social media platforms]() - [12.5 WhatsApp Instant messaging platform]() - [12.6 Chatbots and other onsite data collection]() - [12.7 Discount codes, vouchers and cashback accounts]() - [12.8 Affiliate Sites, such as Mirror Bingo and Mirror Switch & Save]() -- [12.9 How we work with Group Companies]() +- [12.9 When you register for an event]() - [12.10 Transfer as part of the sale of our business]() - [12.11 Award or charitable donation; nomination, voting and judging]() +- [12.12 Business Directory and B2B Marketing Services]() +- [12.13 Artificial Intelligence Partners]() +- [12.14 Internal AI Archiving]() +- [12.15 Launchpad and Independent Creator Networks]() +- [12.16 How we work with Group Companies]() -**12.1 Further data sharing by Reach** +**[12.1 Further data sharing by Reach](https://www.mirror.co.uk/privacy-notice/12furtherdata)** We may pass your information to our processors - companies that we use to provide services on our behalf, for example for home delivery services, event management, prize fulfilment agencies, sending gifts and coupons, market research or other purposes mentioned in this Privacy Notice such as analytics, direct marketing or online advertising. These processors can only use your information in accordance with our instructions and for no other purpose. In addition, 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, including the Information Commissioner's Office, 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. @@ -837,27 +893,29 @@ When we share information with third parties, we only permit them to process this data for specified purposes. We do not share more information with them than is necessary for the relevant purpose and we require them to treat this information with at least the same protection we do. **12.2 Links to other websites and third-party affiliates** Our websites may include links to third-party websites, plug-ins, and applications. We work with companies like Skimlinks and AWin who have relationships with retailers and other publishers, to enable you to click a link on our site and go directly to their site. We do not drop cookies through our affiliate links. Instead we use a type of link that redirects users into the affiliates network. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and, when you leave our website, we encourage you to read the Privacy Notice of every website you visit. Please note that some of our third party/affiliate websites may have Reach branding, although they may not be operated by Reach. For more information on how Skimlinks and AWin use your data see here: [Skimlinks](https://www.skimlinks.com/privacy-policy/) and [Awin](https://www.awin.com/gb/privacy). +Similarly, we embed maps and affiliate booking tools provided by Stay22. When you use these features to search for or book hotels, rentals, or travel arrangements, your personal data is collected directly by Stay22's affiliate network ecosystem, allowing them to track conversions and transactions generated from our platforms.For more information on how Stay22 use your data see here: [**Stay22**](https://www.stay22.com/privacy) + We may monetise some of these links through the use of third-party affiliate programmes. These affiliate links help pay the costs of producing our websites and ensure that the content is free to you. However, it doesn't mean that we are in any way indebted to Amazon or any other company. Nor do they or any other company have any influence over editorial coverage, how we rate products, or whether they get a positive review. Notwithstanding such affiliate programmes, we are not responsible for the content or privacy policies of these websites or for third-party advertisers, nor for the way in which they use the information they collect about you. See more [Information on Affiliate Links](https://www.reachplc.com/affiliates). **12.3 Behavioural remarketing services** After you have visited our site, we may use remarketing services provided by companies such as Facebook and Google and Bing, to show you advertising on third-party websites, based on your browsing patterns and interactions. For this purpose, visitors are grouped by certain actions on our services, for example, by duration of visit. This enables us to understand your preferences and to show you personalised advertising even if you are currently on another website within the network. **12.4 Social media platforms** We may also share de-identified information with social media platforms for advertising and analysis purposes. For example, we may share a hashed, non-identifiable version of your email with, for example, Facebook or Google, with the aim of showing you advertising on those platforms, or to exclude you from seeing our advertising on those platforms. -Combined with the use of their respective pixels/advanced matching and Conversions/Events APIs (a secure server-to-server interface that allows us to share specific actions you take on our website directly with Meta and TikTok), this enables us to better understand how you interact with our website, measure the impact of our advertising and website conversions, deliver relevant advertising that may be of interest to you and protect your privacy. +Combined with the use of their respective pixels/advanced matching and Conversions/Events APIs (a secure server-to-server interface that allows us to share specific actions you take on our website directly with platforms such as Meta and TikTok), this enables us to better understand how you interact with our website, measure the impact of our advertising and website conversions, deliver relevant advertising that may be of interest to you and protect your privacy. Processing your data in this way enables us to deliver relevant advertising that may be of interest to you and protect your privacy. It also enables us to measure the impact of our advertising and website conversions, improve targeted advertising, improve marketing attribution and improve conversion tracking. -To opt out of your email being shared in this way by email [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com), and stating 'opt out of hashed email'. 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 or link at the bottom of every webpage. +To opt out of your email being processed in this way, email [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com), stating 'opt out of hashed email'. 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 or link at the bottom of every webpage. **12.5 WhatsApp Instant messaging platform** When you sign up to one of our Whats App communities to receive the latest updates, exclusives and comments straight to your phone. As part of this process you are allowing WhatsApp to receive and share data with us, including your phone number. The use of your data will be in accordance with this Privacy Notice, and also WhatsApp Privacy Notice [here](https://www.whatsapp.com/legal/privacy-policy-eea). You can exit the Community you joined at any time by going to the Communities tab of your Whatsapp account, and following these instructions: [How to exit a community](https://faq.whatsapp.com/1312647189536807/). @@ -909,44 +967,22 @@ - [Bike insurance](https://insurance.mirrorswitchandsave.co.uk/bike/index.php) - [Breakdown insurance](https://insurance.mirrorswitchandsave.co.uk/breakdown/index.php) - [Bicycle insurance](https://insurance.mirrorswitchandsave.co.uk/bicycle-quote/index.php) When you navigate to these web pages, please note that our partner Quotezone will be the data controller for the personal data that you provide, and Reach will be the data processor. For more information about how your Affiliate data will be used, please see the Quotezone Privacy Notice [here](https://www.quotezone.co.uk/about/privacy-policy). -**12.9 How we work with Group Companies** +**12.9 When you register for an event** -Reach receives information from, and shares information with, other companies within the Reach Group to help operate, provide, improve, understand, customise, support, and market our services and their offerings. This includes: +We use Ticket Tailor to process registrations and issue tickets for our events. We process this data to perform our contract with you. You can read Ticket Tailor's privacy policy [https://www.tickettailor.com/legal/privacy-policy](https://www.tickettailor.com/legal/privacy-policy) -- helping improve infrastructure and delivery systems; -- understanding how our services or theirs are used; -- promoting safety, security and integrity across the Reach Group e.g. securing systems and fighting spam, threats, abuse, or infringement activities; -- performing analytics and analysis of how you interact with the group's products and services, to facilitate business efficiencies, to help us better understand our audiences and deliver relevant content, develop products and services that would be relevant to you; and -- sharing information to deliver more relevant advertising from across the Reach Group network. +When you register for an event, on any of the websites we may add your information to our mailing lists. If the event has sponsors, we might also share information, including personal data, with those sponsors. This will be in accordance with the privacy laws in the country in which you reside. For example, in the EU/UK, you may have actively given specific consent for marketing from Reach brands, and separately for your data to be shared with a 'named sponsor'. -We also share information to fulfil the service to you for example: +You can unsubscribe from our communications at any time, by following the unsubscribe instructions on the correspondence you receive, or by emailing [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) You can also withdraw consent (opt-out) of your data being shared by emailing [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) stating 'Opt-out of Sharing' and providing your email and the brand details as above. -- When you decide to place an advertisement on Marketplace Live, through our Bookanad website, the information that you have provided will be shared with Marketplace Live, so that the publication and administration of your advertisement may be effectively managed. -- When you elect to place a notice on the InYourArea website, through our Bookanad website, the information that you have provided when creating an account, and a notice, will be shared with InYourArea so that they may manage and administer your online post. +Please note the use of your personal information by sponsors, will be subject to their own privacy policy and practices, for which we are not responsible. -**Audience Analytics and Understanding** - -When you consent to our cookies via our CMP, we may use your information (cookie identifiers and usage data) to help us better understand our audiences. This may include linking engagement data across our websites and apps for the following purposes; - -- Content improvement, to analyse what content is popular with our audiences so we can prioritise content that matters to our readers. -- Performance analysis, to assess how our platforms are performing, including traffic levels and audience engagement. -- Analytics and insights, to ingest the data into our analytics platforms (Engine), which allow our teams to ask questions and gain insights that support better decision making. - -**Advertising Relevance and Effectiveness** - -Another key way we share data across our websites and apps, is for advertising and targeting purposes. When you consent to cookies via our CMP, we may use your information from your online behaviour across our group sites to deliver adverts that are relevant to your interests and to help measure the effectiveness of our advertising campaigns. For example: - -- When you go onto one of our sites we can track your behaviour on those sites, or any of our other sites across our Group companies, and use this to target advertising or email content to you. For example, if you use our ecommerce site yimbly.com, we can see if you later visited one of our other sites and you may see advertising for the products you looked at based on this. If you would prefer to opt out, you can do so via the consent management pop-up. -- This also applies if you open an email from us and this takes you online as we can use the information from your online behaviour to later target marketing to you. So for example if you subscribe to marketing emails on one of our regional news sites and we see you have looked at sporting content on our other sites we may provide you with sport related content in your marketing emails from the regional news site. You can unsubscribe from emails at any time. -- We may also upload emails (in hashed, pseudonymous form) straight to the advertising data system and this enables us to identify the same non-identifiable user across devices. So we know, for example, that the person who looks at Reach lifestyle content on their phone and then Reach fashion content on their desktop, is in fact the same non-identified person. You can unsubscribe from emails at any time. -- We may also use the other data you have provided to us, combined with your online behaviour, to personalise your email campaigns. For example, if you signed up an account when browsing 'football' content on our news sites, we may classify you as a 'football intender'. Later when you go online we may see you are also interested in content on films and classify you as a 'football and films intender'. As a result you may see advertising content related to football and films, when you visit our sites. - **12.10 Transfer as part of the sale of our business** If we sell part or all of our business, personal information may be one of the transferred business assets. If this happens, your information may be disclosed to any successors of our business for them to use for the purpose set out in this Privacy Notice. **12.11 Award or charitable donation; nomination, voting and judging** @@ -984,14 +1020,123 @@ We may also contact nominators and/or nominees/ identified nominees to research their story prior to the winners being contacted. If you are selected as a winner of an award or charitable donation, we will use the personal data provided by the nominators to contact the winners. Winners will be contacted and asked to confirm that they are happy to be winners of the relevant award or charitable donation and for their personal information to be used for this purpose. The personal data may also be used to communicate & run an event, for publication in Reach print and on-line titles, and for use on social media platforms. +**12.12 Business Directory and B2B Marketing Services** + +We may receive personal information about you from third-party sources to help us maintain the accuracy of our records and grow our business. This includes professional and business contact information from providers such as Cognism Limited. The data provided typically includes your name, job title, business email address, and professional social media profile (e.g., LinkedIn URL). + +We work in partnership with Market Location. In certain circumstances, we may share business contact information with them to ensure our records are accurate and up-to-date. Market Location may also use this information for their own professional services and directory products. You can find more information about how Market Location handles your data, including your rights to object to their processing, by visiting their [Privacy Policy](https://marketlocation.co.uk/privacy-policy/). + +**12.13 Artificial Intelligence Partners** + +We partner with select artificial intelligence (AI) developers and technology platforms to enhance our services and support the broader digital media ecosystems as follows: + +- We share our content (including articles, archives, and multimedia) with AI providers such as Amazon Web Services, acting as our Processor, to enhance our models and enable us to improve our service to our readers. This may include categorising our content, such as articles and images, so these can be easily identified and accessed for future use. +- We enter into commercial licensing agreements with major technology providers, including Google, to license our published content archives. This allows our journalism to be displayed within AI-generated summaries and responses. Under these agreements, our content may undergo pre-processing and be utilised by the AI provider for the training, fine-tuning, evaluation, and ongoing improvement of their artificial intelligence models. + +**What data is included?** This licensed content consists entirely of our public journalism and archives, which may include personal data embedded within reporting, such as names, public profiles, quotes, or specific details mentioned in our published stories. + +**What data is excluded?** We strictly prohibit our AI partners from accessing or using your private user data. Your account credentials, email address, payment details, billing history, or private interactions with our platforms are never shared, sold, or licensed for AI training or model improvement purposes. + +**12.14 Internal AI Archiving** + +We use Artificial Intelligence to assist with the digital archiving and tagging of our historical publications. This processing involves training and fine tuning internal archival models on our past content to build a searchable knowledge base. We partner with Amazon Web Services (AWS) to host the cloud infrastructure and power these analytical tools. This system functions as a reference utility for Reach journalists to support standard journalistic research, fact checking, and reporting. + +**What data is included?** This activity utilises our public editorial archives. It may include personal data natively embedded within historical news reporting, such as names, quotes, public profiles, or specific factual details published within past stories. + +**What data is excluded?** No private user account data, registration details, marketing preferences, billing histories, or private reader interactions are ever injected into our archival training models or knowledge base systems. + **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** +**12.15 Launchpad and Independent Creator Networks** + +Launchpad is an online publishing platform operated by Reach. This service is designed to enable independent creators to build, distribute, and monetise their digital content. When you use this platform, Reach and the specific creator you choose to engage with act as joint data controllers for your information. Reach provides the underlying technological infrastructure and manages all advertising operations. This section applies to all subscribers, account holders, and site visitors across the United Kingdom, the European Union, and the United States. + +**The data we collect and what we do with it** + +We collect the minimum amount of personal data necessary to maintain your account, serve content, and manage advertising preferences. When you create an account or subscribe to a publication, we collect your email address, your username, and your basic account preferences. We use this information to authenticate your login sessions, manage your subscriptions, and deliver the specific creator blogs you have requested. We also collect technical infrastructure data, such as your internet protocol address and browser type, to ensure platform security, prevent fraudulent account creation, and ensure content renders correctly on your device. + +**Free and Paid Subscriptions** + +We offer tiered access models for our communities and newsletters, including both free and paid newsletter subscriptions. In order to provide, technically operate, and verify these subscription services on our website, we collect online identifiers including your device type, IP address, language settings, approximate location at the time of browsing, your logged-in user ID, user status, and engagement history. + +We use this data to verify your subscription status, ensure platform security, prevent fraud, and determine what tailored content is delivered to you. If you choose to cancel a subscription, we may also collect your reason for leaving to improve our platform, and where permitted, offer you relevant alternative communities. + +**Newsletter Communications** + +When you sign up to receive updates from a creator, your email address is used to send you newsletters, content recommendations, and interesting articles from across our network, in line with the consent you have provided. The advertisements inside our newsletters are strictly contextual. This means the promotions you see are selected automatically based entirely on the topic, category, or theme of the specific newsletter edition you are reading. We do not use tracking pixels to monitor your email behaviour or build an advertising profile about your interests for email delivery. + +You have total control over these communications. You can unsubscribe at any time by clicking the unsubscribe link contained within the footer of any email we send you. + +**Service and Promotional Messages for Paid Subscribers** + +If you are a subscriber to a free or paid newsletter/community tier, we will use your email address to send you essential service messages. These include transactional receipts, renewal reminders, operational updates, and automated surveys or feedback requests during a cancellation process to help us improve our offerings. + +Where permitted by law or your preferences, we may also send you promotional communications about your subscription, such as exclusive discounts, renewal offers, and relevant updates across the network. You have total control over these and can easily opt out at the point of sign-up or via the opt-out link contained in any promotional email you receive. + +**Creator Blogs and Personalised Advertising** + +Independent creators have the ability to place behavioural advertisements within the content of their own on site blogs. Behavioural advertising uses tracking technologies to understand your interests based on your browsing activity across the internet, allowing advertisers to display more relevant adverts to you. + +We only serve personalised advertisements with your consent via our CMP. When you visit creator blogs or access your user account dashboard, you can use our Consent Management interface to customise your tracking preferences. Through this panel, you can also review the specific list of approved ad tech vendors, grant or deny consent for behavioural tracking, or object to data processing at any moment. + +**Data Sharing within the Creator Network and Third-Party Processors** + +To provide our subscription model, we must share specific information across our ecosystem. When you subscribe to an independent creator, that individual creator is granted access to your email address solely to distribute their newsletter and manage their community. All independent creators on Launchpad are contractually bound to process your data in strict compliance with applicable global privacy laws. They are legally forbidden from downloading your email address for external marketing purposes, sharing it with unauthorised third parties, or selling your data. + +When you sign up for one of the free or paid subscription tiers, we use a third-party provider, Piano, to run the infrastructure. They will use your details to process your payments, manage account access, and deliver the content you have subscribed to. Please see the [Piano Privacy Notice](https://piano.io/gb/privacy-policy/) for more information on how they process personal data. + +**Data Transfer and Retention** + +As an international media company, we may store or process your information in data centres located outside your home country, including the United Kingdom, the European Union, and the United States. We implement strict legal safeguards, including standard contractual clauses approved by regulatory authorities, to ensure your data receives an identical level of protection regardless of geographic location. + +We retain your personal data in accordance with the law and relevant regulations and will store the data for as long as is necessary to fulfil the purpose for which it was collected. The period for which we keep your personal data will be determined by the purpose for which we are using the data, and our legal and regulatory obligations. + +**Your Rights and how to access them** + +Depending on your location, you possess legal rights regarding your personal data. You have the right to request access to the information we hold about you, request the correction of inaccurate data, or seek the complete erasure of your personal records from our system. You also have the right to restrict or object to certain types of data processing, including behavioural tracking. To exercise any of these rights, please contact [dataprotection@reachplc.com](mailto:dataprotection@reachplc.com) + +**[\*\*\* Click here to go back to 'Contents' \*\*\*]()** + +**12.16 How we work with Group Companies** + +Reach receives information from, and shares information with, other companies within the Reach Group to help operate, provide, improve, understand, customise, support, and market our services and their offerings. This includes: + +- helping improve infrastructure and delivery systems; +- understanding how our services or theirs are used; +- promoting safety, security and integrity across the Reach Group e.g. securing systems and fighting spam, threats, abuse, or infringement activities; +- performing analytics and analysis of how you interact with the group's products and services, to facilitate business efficiencies, to help us better understand our audiences and deliver relevant content, develop products and services that would be relevant to you; and +- sharing information to deliver more relevant advertising from across the Reach Group network. + +We also share information to fulfil the service to you for example: + +- When you decide to place an advertisement on Marketplace Live, through our Bookanad website, the information that you have provided will be shared with Marketplace Live, so that the publication and administration of your advertisement may be effectively managed. +- When you elect to place a notice on the InYourArea website, through our Bookanad website, the information that you have provided when creating an account, and a notice, will be shared with InYourArea so that they may manage and administer your online post. + +**Audience Analytics and Understanding** + +When you consent to our cookies via our CMP, we may use your information (cookie identifiers and usage data) to help us better understand our audiences. This may include linking engagement data across our websites and apps for the following purposes; + +- Content improvement, to analyse what content is popular with our audiences so we can prioritise content that matters to our readers. +- Performance analysis, to assess how our platforms are performing, including traffic levels and audience engagement. +- Analytics and insights, to ingest the data into our analytics platforms (Engine), which allow our teams to ask questions and gain insights that support better decision making. + +**Advertising Relevance and Effectiveness** + +Another key way we share data across our websites and apps, is for advertising and targeting purposes. When you consent to cookies via our CMP, we may use your information from your online behaviour across our group sites to deliver adverts that are relevant to your interests and to help measure the effectiveness of our advertising campaigns. For example: + +- When you go onto one of our sites we can track your behaviour on those sites, or any of our other sites across our Group companies, and use this to target advertising or email content to you. For example, if you use our ecommerce site yimbly.com, we can see if you later visited one of our other sites and you may see advertising for the products you looked at based on this. If you would prefer to opt out, you can do so via the consent management pop-up. +- This also applies if you open an email from us and this takes you online as we can use the information from your online behaviour to later target marketing to you. So for example if you subscribe to marketing emails on one of our regional news sites and we see you have looked at sporting content on our other sites we may provide you with sport related content in your marketing emails from the regional news site. You can unsubscribe from emails at any time. +- We may also upload emails (in hashed, pseudonymous form) straight to the advertising data system and this enables us to identify the same non-identifiable user across devices. So we know, for example, that the person who looks at Reach lifestyle content on their phone and then Reach fashion content on their desktop, is in fact the same non-identified person. You can unsubscribe from emails at any time. +- We may also use the other data you have provided to us, combined with your online behaviour, to personalise your email campaigns. For example, if you signed up an account when browsing 'football' content on our news sites, we may classify you as a 'football intender'. Later when you go online we may see you are also interested in content on films and classify you as a 'football and films intender'. As a result you may see advertising content related to football and films, when you visit our sites. + +**[\*\*\* Click here to go back to 'Contents' \*\*\*]()** + ## 13\. How we keep your data secure, why we may keep it, and countries we may transfer it to **13.1 How we keep your data secure.** We are committed to protecting the personal data we hold and keep your information secure by taking appropriate technical and organisational measures, including for example encryption techniques and access control, to protect personal and sensitive data against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. @@ -1064,13 +1209,13 @@ To exercise this right please use our [right to erasure request form](https://docs.google.com/forms/d/1FPYI30k_YxTZTRMeJFKOifbszAvNBcKv4mXE2hJbCSU/viewform). **15.4 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 newsletters and email communications, you can withdraw your consent to receive the communication by clicking the 'Unsubscribe' link at the bottom of any email. Additionally, you can prevent email open-tracking independently by disabling the 'load remote images' setting within your specific email application provider. To withdraw your consent for how we are using your information, please use our [unsubscribe request form](https://docs.google.com/forms/d/1BzxjkfB1KIdmiTUWF3ij_2Ezs4dOb-KS6O1_a5bqeuQ/viewform) For targeted advertising on our websites, you can access the screen to do this by clicking the "Privacy" tag with the 'cog' icon or link at the bottom of every webpage 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'. @@ -1096,13 +1241,13 @@ To exercise this right please use our [other rights request form](https://docs.google.com/forms/d/1l5UU-bfte8NUvRWG5BTUV0076O78C6ZDxpazy5n_Kpk/viewform). **15.8 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 using our [data protection complaints form](https://docs.google.com/forms/d/1HqiwFBdi3amJGQYGKtGwBjVbNhQx--YXQZG4L1Cmz5k/viewform) 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. +If you remain dissatisfied with the outcome of your complaint, once you have brought it to our attention, 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 @@ -1132,13 +1277,13 @@ Privacy legislation in the US and Canada is evolving and as a result there are special rights for residents of certain states. This section details the existing state laws and consumer privacy rights and will be updated as the new laws are introduced. We have appointed a Privacy Officer to oversee our data protection and privacy practices, in the US and Canada. Our Data Protection Officer holds this position. If you have any comments, concerns, or questions, including any requests to exercise your legal rights, you can contact our Privacy Officer as follows: - By email: privacyofficer@reachplc.com -- By post: Privacy Officer, Reach Plc, 19th Floor, 200 Liberty Street, New York, NY 10281 +- By post: Privacy Officer, Reach Plc, 14 Wall Street, FL 20, New York, NY, 10005 It would be very helpful for us if you could include your full name, your postcode, details of the service you are using and/or account information when contacting us. This section covers the following: **[16.1 California Residents]()** data collection, use and sharing, and privacy rights @@ -1146,27 +1291,35 @@ **[16.2 Residents of US states with applicable privacy legislation]()** specific information and privacy rights **[16.3 Residents of other states and territories with applicable legislation]()** **[16.4 Other Notices]()** -**16.1 California Residents** +**QUICK LINK** +For information on how to opt out of the "sale" and "sharing" of your information see the following: + +**California - See** [16.1.5 Do Not "Sell" or "Share" My Personal Information](). + +**All other States with Applicable Legislation - See** [16.2.4 Exercising these Rights](). + +**[16.1 California Residents]()** + This section applies to California residents. It describes how we collect, use and share Personal Information of California residents when operating our business, and their rights with respect to that Personal Information. This section should be read in conjunction with the rest of this Privacy Notice which provides further details on the nature of our data processing. -For purposes of this section, "**Personal Information**" has the meaning given in the California Consumer Privacy Act of 2018 ("**CCPA**") and amended by the California Privacy Rights Act of 2020 ("**CPRA**"). It does not include: (i) information that is lawfully made available from federal, state or local government records; (ii) de-identified or aggregated data; or (iii) information excluded from the scope of the CCPA/CPRA. +For purposes of this section, "**Personal Information**" has the meaning given in the California Consumer Privacy Act of 2018 ("**CCPA**") including as amended by the California Privacy Rights Act of 2020. It does not include: (i) information that is lawfully made available from federal, state or local government records; (ii) de-identified or aggregated data; or (iii) information excluded from the scope of the CCPA. On some occasions, in order to provide our Services to our clients, we may process service data that we receive from or on behalf of our clients. If you are a California resident, you may have certain CCPA rights with regards to this information. Under the CCPA, when we act as a "service provider" (as opposed to a "business" or a "third party") over such information, we only process your information in a way required to provide our services to our clients, at our clients' direction. If you wish to exercise any of your rights under CCPA regarding such information, please contact the relevant business that collected the information from you, as they control and determine how your information is processed. **16.1.1 Personal Information that we collect, use and share** The table below provides a summary of the categories of your personal information Reach may have collected, the sources of that data, the reasons for collection and who we may have disclosed the data to over the last twelve months. The information gathered in this table may apply to you in different ways depending on how you have interacted with us. **Please see the keys below the table to inform the second and third column:** -

Category	Business Purpose for Disclosure	Categories of Recipients of Disclosures	Do we share this data?
Personal Information
Identifiers such as name, email address, billing information, username, any provided phone numbers, such as home, or mobile, online screen name, security questions and password.	P1, P2, P3, P4, P5, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	No
Commercial Data such as records of your purchases and transaction data.	P1, P2, P3, P4, P6, P7	D1, D2, D3, D6, D7, D8	No
Customer Records such as financial or payment information to process payments and information about your transactions and purchases with us.	P1, P7	D2, D6, D7, D8	No
Internet & electronic network activity information including, but not limited to browsing history, search history, and information regarding interactions with an internet website, video, application, or advertisement, including other usage data related to your use of any of our Services or other online services. Please see our Cookie Notice for further information.	P1, P2, P3, P4, P5, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	Yes
Device information and identifiers such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers.	P1, P2, P3, P4, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	Yes
Geolocation Data such as general location, and, if you provide permission, precise GPS location.	P1, P2, P3, P4, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	Yes
Sensory Data such as audio recordings if you call our customer service or volunteer this information as part of using our services and photographs in connection with your social media account	P1, P2, P5, P7	D1, D2, D6, D7, D8	No
Financial Data such as credit or debit card number, verification number, and expiration date, to process payments and information about your transactions and purchases with us.	P1, P7	D2, D6, D7, D8	No
Social media information (which may include personal identifiers, photos, location, user generated content, demographic information). If you link your account or access the Services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings, such as your name, email address, photo, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, YouTube, and Twitter).	P1, P2, P3, P4, P5, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	No
Research, survey, or sweepstakes information (including personal identifiers and user generated content) collected if you participate in a survey or sweepstakes; includes information needed for you to participate (such as contact information), and to fulfil your prize.	P1, P2, P3, P4, P5, P6, P7	D1, D2, D3, D5, D6, D7, D8	No
Inference Data including inferences drawn from any of the information identified above to create a profile reflecting a consumer's preferences, characteristics, behaviour or attitudes.	P1, P2, P3, P4, P6, P7	D1, D2, D3, D5, D6, D7, D8	No
Sensitive Personal Information
Account log-in in combination with any required security questions or password collected if you create an account with us.	P1, P2, P7	D2, D6, D7, D8	No

Category	Business Purpose for Disclosure	Categories of Recipients of Disclosures	Do we share this data?
Personal Information
Identifiers such as name, email address, billing information, username, any provided phone numbers, such as home, or mobile, online screen name, security questions and password.	P1, P2, P3, P4, P5, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	No
Commercial Data such as records of your purchases and transaction data.	P1, P2, P3, P4, P6, P7	D1, D2, D3, D6, D7, D8	No
Customer Records such as financial or payment information to process payments and information about your transactions and purchases with us.	P1, P7	D2, D6, D7, D8	No
Internet & electronic network activity information including, but not limited to browsing history, device ID, search history, and information regarding interactions with an internet website, video, application, comments or advertisement, including other usage data related to your use of any of our Services or other online services, including travel search queries and map interactions via our partner Stay22. Please see our Cookie Notice for further information.	P1, P2, P3, P4, P5, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	Yes
Device information and other identifiers such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, hashed pseudonymous emails and app identifiers.	P1, P2, P3, P4, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	Yes
Geolocation Data such as general location, and, if you provide permission, precise GPS location.	P1, P2, P3, P4, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	Yes
Sensory Data such as audio recordings if you call our customer service or volunteer this information as part of using our services and photographs in connection with your social media account	P1, P2, P5, P7	D1, D2, D6, D7, D8	No
Financial Data such as credit or debit card number, verification number, and expiration date, to process payments and information about your transactions and purchases with us.	P1, P7	D2, D6, D7, D8	No
Social media information (which may include personal identifiers, photos, location, user generated content, comments, demographic information). If you link your account or access the Services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings, such as your name, email address, photo, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, YouTube, and Twitter).	P1, P2, P3, P4, P5, P6, P7	D1, D2, D3, D4, D5, D6, D7, D8	No
Research, survey, or sweepstakes information (including personal identifiers and user generated content) collected if you participate in a survey or sweepstakes; includes information needed for you to participate (such as contact information), and to fulfil your prize.	P1, P2, P3, P4, P5, P6, P7	D1, D2, D3, D5, D6, D7, D8	No
Inference Data including inferences drawn from any of the information identified above to create a profile reflecting a consumer's preferences, characteristics, behaviour or attitudes.	P1, P2, P3, P4, P6, P7	D1, D2, D3, D5, D6, D7, D8	No
Sensitive Personal Information
Account log-in in combination with any required security questions or password collected if you create an account with us.	P1, P2, P7	D2, D6, D7, D8	No

**Data collection key** Purposes - P1 - Performing services; including but not limited to customer service and related requests, processing orders or other transactions, managing and maintaining your account, marketing or advertorial services, analytics. @@ -1177,79 +1330,85 @@ - P6 - Repairs; review of assets and management of debugging and other fixes to maintain and improve functionality. - P7 - Security, fraud and legal compliance; actions deemed necessary to protect and defend Reach assets against illegal, malicious and damaging activity. Disclosures - D1 - Reach subsidiaries and affiliates; we may disclose information in order to deliver services in the ways described in this Privacy Notice. Marketing will only be sent to you where the necessary consent has been provided. -- D2 - Service partners; we may disclose information where we work in partnership to provide you with products or services. +- D2 - Service providers or contractors; we may disclose information where we work in partnership to provide you with products or services. - D3 - Commercial partners; we may disclose information with third parties to provide you with relevant content and advertising on websites and mobile apps where we have the necessary permissions to do so. We may also disclose information to enable you to receive marketing you have asked to receive. - D4 - Social media; we may disclose information with social media networks where we have the necessary permission to do so. - D5 - Analytics providers; we may disclose information with data analytic providers to review, evaluate and improve our services. - D6 - Security; we may disclose information where it is necessary to do so in order to protect the rights, assets, employees and customers of Reach. - D7 - Legal requirements; we may disclose information where necessary to comply with our legal obligations or if we believe it is required in relation to the investigation or prevention of suspected or actual illegal activity. - D8 - Business Development; we may disclose information for the purpose of business transfers, mergers, acquisitions, bankruptcy proceedings or similar. **16.1.2 Sharing of your data** -- Like many companies, we use services that help deliver interest-based ads, content and services to you and may transfer personal information to business partners for their use. California law classifies our use of these services as "sharing" your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads, content and services more likely to interest you.This sharing is limited to advertising partners with whom we have a contractual agreement and to the online marketing related purposes agreed by you via Reach's Consent Management Platform (CMP). The data types include an online identifier, URLs from Reach pages, a referrer identifier, and a truncated IP address. +- Like many companies, we use services that help deliver interest-based ads, content and services to you and may transfer personal information to business partners for their use. California law classifies our use of these services as "sharing" your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads, content and services more likely to interest you.This sharing is limited to advertising partners with whom we have a contractual agreement and to the online marketing related purposes agreed by you via Reach's Consent Management Platform (CMP). The data types include an online identifier, URLs from Reach pages, a referrer identifier, hashed and pseudonymised emails and a truncated IP address. For example, we may share your data with identity and advertising partners, such as LiveRamp, Roqad and Freestar to recognise you across different devices and to serve you more relevant, interest-based advertising. Roqad utilises these cookies, mobile device identifiers, and hashed email addresses solely to build their identity graph. We also share internet network activity and inferred commercial data with Stay22 to display contextual accommodation options based on the articles or events you are browsing. + For information on the third party partners we work with please click [here](https://www.reachplc.com/site-services/third-party-cookies) + **16.1.3 Sources of Personal Information.** In general, we may collect the categories of personal information identified in the table above from the following categories of sources: - Directly from you and your devices - Through your use of our services - From third parties and service providers, including affiliates, commercial partners, social media networks, analytic providers, credit reference agencies **16.1.4 California Residents' Rights.** As a California resident, you have the following rights (subject to certain limitations): -- **Information.** You can request the following information about how we have collected and used your Personal Information during the past 12 months: +- **Information.** You can request the following information about how we have collected and used your Personal Information. This includes information beyond the standard 12-month period for any personal information collected on or after January 1, 2022, at your request: - The categories of Personal Information that we have collected. -- The categories of sources from which we collected Personal Information. +- The categories of sources from which we collected Personal Information **(such as social media networks and credit reference agencies)**. - The categories of information collected both directly and indirectly, including through a service provider or contractor. - The business or commercial purpose for collecting and/or selling Personal Information. -- The categories of third parties with whom we share Personal Information. -- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient. +- The categories of third parties with whom we share Personal Information **(such as analytics providers and social media networks)**. +- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient, including the categories of PI disclosed to a service provider. - Whether we've sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient. -- **Access**. You can request a copy of the Personal Information that we have collected about you during the past 12 months. +- **Access**. You can request a copy of the Personal Information that we have collected about you. You may request a copy of personal information collected on or after January 1, 2022, beyond the standard 12-month look-back period. - **Deletion.** You can ask us to delete the Personal Information that we have collected from you. +- **Retention**. How long we keep your data and the criteria for those periods. - **Correction.** You can request that we correct inaccurate Personal Information. - **Portability.** You have the right to receive your information in an easily understandable, machine readable and transmittable form. - **Opt-out of sale or sharing.** You have the right to opt out of the sale or sharing of your Personal Information. - **Limit the use of your Sensitive Personal Information.** You have the right to limit the use or disclosure of your sensitive personal information ("SPI") to the information necessary to perform services or provide goods reasonably expected. -- **Non-discrimination.** The right not to be subject to discriminatory treatment for exercising their rights under the CPRA/CPRA. +- **Non-discrimination.** The right not to be subject to discriminatory treatment for exercising their rights under the CCPA. +- **Decline the use of Profiling and Automated Decision Making**.The right to not be subject to profiling and automatic decision making which results in significant effects. In the past 12 months, we have shared your Personal Information with third parties in the following circumstances, which California law classifies as a "sale" of your Personal Information: - supplying your data to third parties with your express consent (e.g. where you opt-in to receive notifications or create an account) or with promotional partners, such as when you enter a promotion, contest or sweepstake; - supplying attendee data to third parties who provide services in connection with our events, and sending your data to suppliers of certain products and services (where you have consented to hear from such third parties); - using services that help deliver interest-based ads, content and services to you and may transfer personal information to business partners for their use. California law classifies our use of these services as "sharing" your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads, content and services more likely to interest you. -**16.1.5 Do Not "Sell" or "Share" My Personal Information** +**16.1.5 Do Not "Sell" or "Share" My Personal Information.** California residents may opt out of the "sale" or "sharing" of their personal information. -- **Sale**: Reach does not "sell" any of your personal information in exchange for money. However, the term "sell" has a broader meaning under the CCPA/CPRA than would ordinarily be understood in a non-legal context. If we "sell" your Personal Information, you can opt-out. In addition, if you direct us not to "sell" your Personal Information, we will consider it a request pursuant to California's "Shine the Light'' law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. +- **Sale**: Reach enters into commercial arrangements where specific personal information may be disclosed for monetary or other valuable consideration, which qualifies as a sale under applicable privacy legislation. If we "sell" your Personal Information, you can opt-out. In addition, if you direct us not to "sell" your Personal Information, we will consider it a request pursuant to California's "Shine the Light'' law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. -- **Sharing:** We do "share" your Personal Information, as defined, with trusted business partners to deliver interest-based ads, content and services to you, including for site measurement. See section 16.1.2. Depending on what services you use, we may provide the following categories of personal information to third parties for these purposes: +- **Sharing:** We also "share" your Personal Information, as defined, with trusted business partners to deliver interest-based ads, content and services to you, including for site measurement. See section 16.1.2. Depending on what services you use, we may provide the following categories of personal information to third parties for these purposes: - For online targeted advertising purposes: demographic and statistical information, contact and registration information, device information and identifiers, browser and usage data, geolocation, and social media information. -Reach does not knowingly share the personal information of children under the age of 16 without the necessary permissions as required by the CPRA. +Reach does not knowingly share the personal information of children or teens under the age of 18 without the necessary permissions as required by the CCPA. **To opt out of the "sale" and "sharing" of your information.** -- Whilst browsing our websites you have the right under CPRA to opt out of these purposes by selecting the **'Do Not Sell or Share My Personal Information'** link in the footer of the relevant website. If you access this site and/or app from other devices or browsers, or clear your cookies on your devices or browsers, you will need to indicate your preferences again from those devices or browsers. Alternatively to opt out of "sales" or "sharing" of personal information you can toggle your cookies off in the cookie preference centre or enable Global Privacy Control ("GPC") on your browser. To learn more about GPC, please visit [http://globalprivacycontrol.org](http://globalprivacycontrol.org/). +- Whilst browsing our websites you have the right under CCPA to opt out of these purposes by selecting the **'Do Not Sell or Share My Personal Information'** link in the footer of the relevant website. You can also update your preferences via the **Privacy Settings link**. If you access this site and/or app from other devices or browsers, or clear your cookies on your devices or browsers, you will need to indicate your preferences again from those devices or browsers. + Alternatively to opt out of "sales" or "sharing" of personal information you can toggle your cookies off in the cookie preference centre or enable Global Privacy Control ("GPC") on your browser. To learn more about GPC, please visit [http://globalprivacycontrol.org](http://globalprivacycontrol.org/). + - To opt out of the "sale" of other data, including email, you may also submit a request directly by submitting the [rights request form](https://docs.google.com/forms/d/e/1FAIpQLSe_S4UU9agFYuaYgp0IJr_OmXICpKF8oS8N2AaP-ybt29L-rw/viewform) or by emailing privacyofficer@reachplc.com quoting 'California Privacy Rights-(insert name of Reach Group brand)' in the subject header and state 'Opt out of Sale'. We reserve the right to ask for evidence of your residency in California before processing your request. -Please note that a 'Do Not Sell or Share My Personal Information' request does not cover information that has previously been disclosed to third parties for these purposes and does not prevent the ongoing disclosure of data to our service providers. +Please note that a 'Do Not Sell or Share My Personal Information' request does not prevent the ongoing disclosure of data to our service providers. It also does not cover information that has previously been disclosed to third parties for these purposes who may re-sell or re-share your personal information for the purpose of delivering ads tailored to your interests. To opt out of re-sales by such downstream participants, visit their digital properties listed at [https://www.iabprivacy.com/optout.html](https://www.iabprivacy.com/optout.html). **16.1.6 Limit the use of your Sensitive Personal Information.** California residents have the right to limit the use or disclosure of their sensitive personal information ("SPI") if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services. While we recognise opt-out preference signals (aka, Global Privacy Controls) when required to do so by law, given the specific methods by which Reach may collect your SPI in the limited circumstances it collects SPI, opt-out preference signals would be an ineffective and technologically impractical means for honouring limit the use requests. Therefore, please make your request to limit the use of your SPI using the [rights request form](https://docs.google.com/forms/d/e/1FAIpQLSe_S4UU9agFYuaYgp0IJr_OmXICpKF8oS8N2AaP-ybt29L-rw/viewform) or by emailing privacyofficer@reachplc.com quoting 'California Privacy Rights-(insert name of Reach Group brand)' in the subject header and state 'Limit the use of Sensitive Data'. We reserve the right to ask for evidence of your residency in California before processing your request. **16.1.7 Exercising your rights to Information Access and Deletion** @@ -1259,13 +1418,13 @@ We will take steps to verify your request by (i) sending you an email confirmation to which you must respond to confirm your request; and (ii) matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with such information to verify your request. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. **16.1.8 Our Response Time to Your Request** -We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, the CPRA allows us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond and the reason for the extension. +We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, the CCPA allows us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond and the reason for the extension. **16.1.9 Authorised Agents** Authorised agents may initiate a request on behalf of another individual by providing evidence of authority from the individual; authorised agents will be required to provide proof of their authorisation and we may also require that the relevant consumer directly verify their identity and the authority of the authorised agent. **16.1.10 Shine The Light** @@ -1273,13 +1432,13 @@ California residents may request and obtain a list of any third parties that we have disclosed personal information to over the previous calendar year for the purposes of sending you direct marketing about the third party's own products and services. If you would like to request this information please contact us using the [rights request form](https://docs.google.com/forms/d/e/1FAIpQLSe_S4UU9agFYuaYgp0IJr_OmXICpKF8oS8N2AaP-ybt29L-rw/viewform) or by emailing privacyofficer@reachplc.com quoting 'California Privacy Rights-(insert name of Reach Group brand)' in the subject header and state which right(s) you wish to exercise. **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** **16.2 Residents of US states with applicable privacy legislation** -This section applies solely to individual residents of States with applicable privacy legislation including, but not limited to Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Jersey, New Hampshire, Tennessee, Minnesota and Maryland.. It describes how we collect, use and share Personal Information of residents when operating our business, and their rights with respect to that Personal Information. This section should be read in conjunction with the rest of this Privacy Notice which provides further details on the nature of our data processing. +This section applies solely to individual residents of States with applicable privacy legislation including, but not limited to Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Jersey, New Hampshire, Tennessee, Minnesota, Maryland, Indiana, Kentucky and Rhode Island. It describes how we collect, use and share Personal Information of residents when operating our business, and their rights with respect to that Personal Information. This section should be read in conjunction with the rest of this Privacy Notice which provides further details on the nature of our data processing. **16.2.1 Personal Information We Collect** We may collect the following types of Personal Information about you as described below: **A. Personal Information You Provide to Us** @@ -1310,12 +1469,13 @@ - Your location data - Your behaviour, movement and activity on or within the Product; - Your profile information - Account login in combination with any required security questions or password collected if you create an account with us. - Mobile application identification and behaviour, use, and aggregated usage, performance data, and where the application was downloaded from. - If you sign up for text messaging, cookies or other tracking devices may be used to personalise your experience (for example, to send you personalised text message offers). +- Data identifying your interactions with community engagement features, such as commenting history, likes, or shares. **C. Personal Information We May Receive from Third Parties** We may collect or receive additional Personal Information about you from third-party websites and apps, social media platforms and video viewing platforms, such as, but not limited, to Facebook, Twitter, TikTok, Instagram, SnapChat and YouTube ("Social Media Platforms"), third party data providers, and sources providing publicly-available Personal information (e.g., from the U.S. postal service) for the purposes described in "How We Use Personal Information" section below. Personal Information we may access from Social Media Platforms may include, but is not limited to: @@ -1352,35 +1512,53 @@ **B. Disclosing Your Personal Information to Other Parties** We may disclose your Personal Information to other parties, including: - Our affiliates -- Service providers -- Advertisers, advertising technology companies, Social Media Platforms, analytics companies and other third parties with whom we have business relationships. +- Service providers and contractors, including companies that handle the technical aspects of account operation, such as LoginRadius, which hosts identifiers and login credentials on our behalf. +- Advertisers, advertising technology companies, Social Media Platforms, analytics companies. +- Community engagement and identity management platforms, such as Viafoura, which provide analytics and diagnostic capabilities to facilitate community interactions and site performance. +- Other third parties with whom we have business relationships to provide you with relevant content and advertising. - Government regulators - Our legal advisors and parties involved in a legal process. - To an entity involved in the sale of our business - Third parties to whom you or your agents authorise us to disclose your Personal Information in connection with products or Services we provide to you. -In order to provide advertisements and content that are more relevant to you, we and our advertising and content providers may collect certain types of Personal Information when you use our Products (such as, by way of example, your email, the IP address of your device, the identifier on your mobile device, or cookies stored on your device). We may combine this information with other information we have, or that we collect through other sources, and may share the information we collect with third parties to provide interest based or targeted advertising and content, including textual and/or audio-visual ads or content. In addition, our advertising partners and Social Media Platforms may use information received from us to combine it with other information they may have obtained about you through other sources or through your relationship with them. If you would like to opt out from this use, or for more information, please see our Cookie Policy for more information. **We do not sell your sensitive personal data.** +**Large Language and Artificial Intelligence Models:** Reach does not disclose or process private consumer account data, behavioral profiles, or subscriber information for the purpose of training large language models. However, we do license our published editorial content archives to technology partners, including Google, for model fine-tuning, evaluation, and capability improvement. This public text may contain personal data natively embedded within our news reporting (such as names or quotes). -For information on the third party advertising and analytic partners we work with please [click here](https://www.reachplc.com/site-services/third-party-cookies). For information on the social media operators and their privacy policies please see our list of [Social Media Platforms](https://www.reachplc.com/site-services/social-media-cookies). +**Targeted Advertising**: In order to provide advertisements and content that are more relevant to you, we and our advertising and content providers may collect certain types of Personal Information when you use our Products (such as, by way of example, your email, the IP address of your device, the identifier on your mobile device, or cookies stored on your device). We may combine this information with other information we have, or that we collect through other sources, and may share the information we collect with third parties to provide interest based or targeted advertising and content, including textual and/or audio-visual ads or content. As part of this activity, and where you have provided your consent, we share specific identifiers, including hashed email data and mobile advertising identifiers, with identity resolution partners such as Roqad to build identity graphs that assist in identifying devices across platforms. In addition, our advertising partners and Social Media Platforms may use information received from us to combine it with other information they may have obtained about you through other sources or through your relationship with them. +**"Sale" or "Share" of Your Personal Information:** Reach enters into commercial arrangements where specific personal information may be disclosed for monetary or other valuable consideration, which qualifies as a sale under applicable privacy legislation. The term sale has a broader meaning under privacy legislation than would ordinarily be understood in a non legal context. If we sell or share your Personal Information, you have the absolute right to opt out. You can exercise this right at any time by clicking the Do Not Sell or Share My Personal Information link located in the footer of our websites or within our application settings. + +We do share your Personal Information, as defined, with trusted business partners to deliver interest-based ads, content and services to you, including for site measurement, community engagement features and account management services. For example, when you use our site, we share information collected from you with our identity partner, [LoginRadius Inc](https://www.loginradius.com/)., to manage your account and secure your login credentials across our platforms and with **Viafoura** to facilitate our community features. + +Depending on what services you use, we may provide the following categories of personal information to third parties for online targeted advertising purposes: demographic and statistical information, contact and registration information, device information and identifiers, browser and usage data, geolocation, and social media information. + +For example, when you use our site, we share information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with our identity partners, including LiveRamp Inc. This is used to recognise you across different devices and to serve you more relevant, interest-based advertising.This process links your activity on the site to LiveRamp's offline identity graph to create a privacy safe link for advertisers. Detailed information on LiveRamp's data processing activities is available in [LiveRamp's Privacy Notice](https://liveramp.uk/privacy/service-privacy-policy/) and opt-out [here](https://optout.liveramp.com/opt_out).You may also opt-out via the Global Privacy Control (GPC) signal on your browser. + +Furthermore, cross-context behavioral tracking and geolocation analytics are shared with our travel mapping partner, Stay22 Inc., to serve real time localised accommodation offerings tailored to your browsing context. + +If you would like to stop your email being used in this way, please email [privacyofficer@reachplc.com](mailto:privacyofficer@reachplc.com) stating 'opt out of hashed email'. + +If you would like to opt out from this use generally, or for more information, please see our Cookie Policy for more information. We do not sell your sensitive personal data. + +For information on the third party advertising and analytic partners we work with please click [here](https://www.reachplc.com/site-services/third-party-cookies). For information on the social media operators and their privacy policies please see our list of [Social Media Platforms](https://www.reachplc.com/site-services/social-media-cookies). + **16.2.3 Residents Rights** Privacy laws in some US states give residents certain rights with respect to their personal data. These rights include: - **Access.** You can request a copy of the Personal Information we collected about you. - **Right to correct.** You have the right to correct inaccuracies in the personal information we collect from you, taking into account the nature of the personal information and the purposes for which we process it. - **Right to delete.** You have the right to delete personal information that you have provided or that we have obtained about you. Please note that we may deny such a request if the requested deletion falls under an exception to this right set as provided by the relevant law. Additionally, if you request the deletion of your personal information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your personal information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such personal information for any purpose except for those allowed under the relevant legislation. - **Right to data portability.** You have the right to access and obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. - **Right to Know.** You have the right to obtain a list of the third parties that have received your personal data from us. -- **Right to opt out of targeted ads, sales to third parties, or profiling**. You have the right to opt-out of the processing of your personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As described in this privacy notice: +- **Right to opt out of targeted ads, sales to third parties, or profiling**. You have the right to opt-out of the processing of your personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or to review the personal data used in the processing to understand how these decisions were made. As described in this privacy notice: - We DO process personal information for the purposes of targeted advertising; - We DO NOT sell your personal information in exchange for monetary consideration; - We DO NOT engage in profiling decisions based on your personal information that produce legal or similarly significant effects concerning you. **16.2.4 Exercising these Rights** @@ -1388,23 +1566,25 @@ **How to exercise your right to information, access, and deletion** You may exercise your privacy rights by submitting the [rights request form](https://docs.google.com/forms/d/e/1FAIpQLSe_S4UU9agFYuaYgp0IJr_OmXICpKF8oS8N2AaP-ybt29L-rw/viewform) or by emailing privacyofficer@reachplc.com quoting 'US Privacy Rights (insert name of Reach Group brand)' in the subject header and detail which right(s) you wish to exercise, and the US state you live in. **How to exercise your right to opt-out of the "sale or sharing" of your Personal Information** -- **For internet and mobile users.** If you do not wish for us or our online third-party partners (such as advertising networks) to sell or share your personal information with others, please click on the "Do Not Sell or Share My Personal Information" link in the footer of the relevant website. If you access this site and/or app from other devices or browsers, or clear your cookies on your devices or browsers, you will need to indicate your preferences again from those devices or browsers. Alternatively to opt out of "sales" or "sharing" of personal information you can toggle your cookies off in the cookie preference centre or, in applicable states, enable Global Privacy Control ("GPC") on your browser. To learn more about GPC, please visit [https://globalprivacycontrol.org/](https://globalprivacycontrol.org/). +- **For internet and mobile users.** If you do not wish for us or our online third-party partners (such as advertising networks) to sell or share your personal information with others, please click on the "Do Not Sell or Share My Personal Information" link in the footer of the relevant website. You can also update your preferences via the **Privacy Settings link**. If you access this site and/or app from other devices or browsers, or clear your cookies on your devices or browsers, you will need to indicate your preferences again from those devices or browsers. -- **For other offline users eg account holders:** You may also submit a request directly by submitting the [rights request form](https://docs.google.com/forms/d/e/1FAIpQLSe_S4UU9agFYuaYgp0IJr_OmXICpKF8oS8N2AaP-ybt29L-rw/viewform) or by emailing privacyofficer@reachplc.com quoting 'US Privacy Rights-(insert name of Reach Group brand)' in the subject header and state 'opt-out of third-party sale or share'. We reserve the right to ask for evidence of your residency before processing your request. + Alternatively to opt out of "sales" or "sharing" of personal information you can toggle your cookies off in the cookie preference centre or, in applicable states, enable Global Privacy Control ("GPC") on your browser. To learn more about GPC, please visit [https://globalprivacycontrol.org/](https://globalprivacycontrol.org/). +- **For other offline users eg account holders:** You may also submit a request directly by submitting the [rights request form](https://docs.google.com/forms/d/e/1FAIpQLSe_S4UU9agFYuaYgp0IJr_OmXICpKF8oS8N2AaP-ybt29L-rw/viewform) or by emailing [privacyofficer@reachplc.com](mailto:privacyofficer@reachplc.com) quoting 'US Privacy Rights-(insert name of Reach Group brand)' in the subject header and state 'opt-out of third-party sale or share'. Alternatively, if you specifically wish to prevent your email address from being converted into a hashed format for sharing with identity resolution or advertising partners, you can email [privacyofficer@reachplc.com](mailto:privacyofficer@reachplc.com) stating 'opt out of hashed email'. + **16.2.5 Our Response Time to Your Request** We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, the legislation allows us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond and the reason for the extension. For particular states where the time frame for response may be shorter, we will adhere to the required legal timeframe. **16.2.6 Right to Appeal** -Residents of certain states, including Virginia, Colorado, Connecticut, Oregon, Texas, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota and Maryland may appeal a refusal to take action on a request by contacting us by emailing [privacyofficer@reachplc.com](mailto:privacyofficer@reachplc.com). +Residents of certain states, including Virginia, Colorado, Connecticut, Oregon, Texas, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky and Rhode Island may appeal a refusal to take action on a request by contacting us by emailing [privacyofficer@reachplc.com](mailto:privacyofficer@reachplc.com). **[\*\*\* Click here to go back to 'Contents' \*\*\*]()** **16.3 Residents of other states and countries with applicable legislation** Residents may be covered by other local state or country data protection or privacy legislation. To exercise these rights, for example a deletion request, please use the [rights request form](https://docs.google.com/forms/d/e/1FAIpQLSe_S4UU9agFYuaYgp0IJr_OmXICpKF8oS8N2AaP-ybt29L-rw/viewform), to submit a request in relation to your data rights.

Reach Group - Privacy Notice

Full text changes — 20251101_rev01 to 20260811_rev01