We are committed to maintaining the confidentiality of our clients and others who may provide us with their personal information.
This Privacy Policy explains how and why we collect, store, use and otherwise process personal information, and provides information about your individual rights under data protection laws, including the General Data Protection Regulation 2016/679 (GDPR).
This Privacy Policy applies to personal information supplied to us either directly, by the individual to whom the information pertains (data subject), or indirectly, by other third parties. We may use personal information supplied to us for any of the purposes set out in this Privacy Policy, or as otherwise notified at the time of collection.
This Privacy Policy guides our use of any personal information that we may have about you, and we recommend that you read it carefully and keep a copy for your future reference.
To ensure that our data privacy practices remain current and reflect any changes of law, we may update this Privacy Policy from time to time. You are advised to consult our Privacy Policy webpage regularly for any changes.
In this Privacy Policy, we use the following terms:
we, us and our (and other similar terms) to refer to means Triangle News Group Ltd a company registered in England and Wales, Company Number 09425594, whose Registered Office is at Office F31c F31c Parkhall Business Centre, 40 Martell Road, Dulwich, London, England, SE21 8EN;.
personal information (also referred to as personal data) is any information relating to an identified or identifiable natural person;
identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors; and
you and your (and other similar terms) refer to our clients, contacts, suppliers, individuals/entities that submit content to us, and visitors to our website.
What personal information are we likely to collect about you?
We aim to be transparent about how and why we process personal information, including letting you know what personal information we obtain and hold about you.
Our Website Visitors
We collect minimal personal information by way of our website. If you visit our Contact Us webpage, you can find contact details for our office. You may also submit a message to us via this webpage. If you do so, you will be asked for the following information:
· Name
· Email address
· Your brief message (which may contain personal information, including special categories of personal data, depending on your message content)
When you visit our website, we may receive the following data about you from Google, Inc. (based outside the EU) through their Google Analytics platform, which will almost always be anonymised and aggregated before reporting back to us:
· number of visitors to our website
· pages visited while at the website and time spent per page
· page interaction information, such as scrolling, clicks and browsing methods
· websites where visitors have come from and where they go afterwards
· page response times and any download errors
· other technical information relating to end user device, such as IP address or browser plug-in (IP address may also be used to approximate your location, for example we may be able to determine that most visitors to our website come from England).
Cookies and server log data are used to collect this information, and the following cookies are set and accessed by Google, Inc. via our website for this purpose:
To find out more about Google Analytics and to learn how to opt out, please visit:
· How Google uses data when you use our partners’ sites or apps, or
· https://tools.google.com/dlpage/gaoptout/.
We process this information to understand how visitors use our website and to compile statistical reports regarding that activity. This processing is crucial to the running of our website and business and necessary for us to pursue our legitimate interests in improving our website and providing a better service and source of information to visitors. This information is not used to develop a personal profile of you.
We will only retain your personal information for as long as necessary depending on the purpose for which we have obtained that information.
Our Clients (and those individuals associated with our clients)
You may supply us with personal information about yourself (and others) for us to provide our services. We ask our clients (and their contacts) to provide us with only that personal information which is necessary for us to carry out our services. We also ask our clients to provide their contacts with a copy of this Privacy Policy before they provide us with any personal information.
Personal information that may be requested/processed includes:
· Full name (and title)
· Email and postal addresses
· Telephone number(s)
· Passport or other ID
· Date of Birth
·Bank account details
· Correspondence
We may also receive other personal information of a similar nature from you or from other public resources, as well as details of others involved.
We may process the personal information that we obtain from or on behalf of our clients for the following purposes:
· Provision of services
· Billing purposes
· Regulatory compliance (such as evidence of identity and prevention of fraud)
When you ask us to collect and process personal data for the purposes of your matter, you promise that you have obtained all appropriate licences, clearances and consents.
Our content suppliers
You may supply us with personal information about yourself (and others) where you provide us with content. We ask that our content suppliers only provide us with that personal information which is necessary for us to use of the content as necessary for us to fulfil our obligations to you, including for payment where agreed.
Personal information that may be requested/processed includes:
· Full name (and title)
· Email and postal addresses
· Telephone number(s)
· Passport or other ID
· Date of Birth
· Bank account details
· Biographical details including pictures
· Correspondence with a content supplier
We may also receive other personal information of a similar nature from you or from other public resources.
We may process the personal information that we obtain from or on behalf of our content suppliers for the following purposes:
· purposes related to the supply of content
· Billing purposes
· Regulatory compliance (such as evidence of identity and prevention of fraud)
When you ask us to collect and process personal data for the purposes of content supply, you promise that you have obtained all appropriate licences, clearances and consents.
Our third party suppliers and contractors
Where we engage third party suppliers, we may collect and use basic contact details of their representatives in order to enable the performance of the related services, manage the supplier relationship and ultimately to allow us to provide our services to our clients/content suppliers.
When will we share your personal information?
On occasion, we may need to share your personal information with third parties. We will only do so when we are legally permitted to share that information.
We will not disclose your personal information to third parties other than with your consent or where we are permitted by law or where it is in our legitimate interests to do so.
If you are a client, we will consider this to also be an instruction to process the personal information that you disclose to us or that we obtain on your behalf in order to provide those services, unless you instruct us otherwise.
If you are a content provider, we will consider this to also be an instruction to process the personal information that you disclose to us or that we obtain on your behalf in order to use that content.
Should we collect personal information about others on your behalf, and we consider some personal information should not be processed by us, we will return or delete it as appropriate (wherever practicable).
Your rights
You have the following rights over the way we process personal information relating to you. We aim to comply without undue delay, and within one month at the latest:
· to ask for a copy of data we are processing about you.
· to have inaccuracies corrected.
· to ask us to restrict, stop processing, or to delete your personal data.
· to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer.
If you are an individual and wish to make a subject access request at any time, please email us at [INSERT], and your request will be dealt with as efficiently as possible. For any other request in relation to these rights, please email us at [INSERT].
If you are unhappy with the way that we are processing your personal information, please let us know. The best way to bring this to our attention is by emailing us at [INSERT]. Alternatively, you may make a complaint to the relevant data protection supervisory authority, which in the UK is the Information Commissioner’s Officer. You may contact them at: https://ico.org.uk/concerns/
Personal information relating to Children
On occasion, we may process personal information pertaining to children. When we are required to process children’s information, we will only undertake that processing where we have a legal basis to do so. In most circumstances, this will involve seeking the consent of a parent or legal guardian.
Use of our website is intended for persons above the age of 16, and we do not knowingly solicit information or send communications to children unless instructed to do so as per the above example.
If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us without consent of a parent or guardian, we ask that this be brought to our immediate attention. We will make it our priority to address this situation, working with you to resolve this and to delete information relating to the child as soon as practicable. In such an event, please contact us at [INSERT].
Security
We take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our clients and their contacts, our employees, content suppliers, visitors to our website and in relation to any data subject for whom we process personal information.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by us.
Please note: whilst we design and maintain the security of our IT network, our website and your personal information to keep all information secure and prevent unauthorised access, no security system is 100% secure. Always consider therefore which is the most appropriate means of communication and media when transferring sensitive or confidential data or personal information and advise us of any particular sensitivities around any information you may provide and with whom it may be shared (and to which correspondence addresses which may write to you at).
You should always employ up to date, industry recognised, virus prevention software and cyber security measures to keep your system(s) secure. Please let us know if you would like further advice in this regard. We may regard any email address you provide to us as secure and you acknowledge the risks associated with the use of that email address.
Retention
In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary. Once the purpose for which information has been collected has been fulfilled or extinguished, we will either permanently delete your personal information or remove all identifiers within it so that it is no longer personal data unless otherwise required to retain that information as instructed by a legal authority or to comply with applicable law.
For more detailed retention information, please see the above section “What personal information are we likely to collect about you?” If you would like us to stop using your personal information, please email us at [INSERT].
Transfers of personal data outside the EEA
Our servers are located in the European Union and the information that we collect directly from you will be stored in these servers.
We do not routinely transfer data outside the UK, but there are circumstances that may arise from time to time where international data transfer may be required. For example, when we content provided is concerning an international story (or where an individual involved may reside outside the EEA).
Prior to any transfer of personal data to an individual or organisation outside the EEA, agreements will be put in place to ensure that any international transfers of personal data are done according to appropriate safeguards, including any onward transfers, that meet the requirements of EU data protection laws.
If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this policy, please let us know by emailing us at [INSERT].
Journalistic Exemption
Under the Data Protection Act there is a specific exemption to protect journalism in certain circumstances which we may rely where we reasonably believe that the publication of such journalistic material would be in the public interest.
Journalism in the public interest means that processing is carried out with a view to the publication of journalistic material and we reasonably believe that the publication of such material would be in the public interest (taking into account the importance of the public interest in the freedom of expression and information).
Changes to this Policy
This privacy policy may be updated from time to time. We will notify you of any changes to our privacy policy by posting the new privacy policy on our website. It is advisable to consult this privacy policy webpage regularly for any changes.
Contact Us
Questions, comments and requests in relation to this privacy policy are welcome and should be addressed to the Data Protection Officer, Triangle News Group Ltd Office F31c F31c Parkhall Business Centre, 40 Martell Road, Dulwich, London, England, SE21 8EN.