Last updated: May 2018
- Introduction & General Terms
- Who we are
- What Data we collect
- How we use your data
- How we keep your personal data secure
- Who we share your personal data with
- How long we keep your data
- Personal Data – Your rights
- Contact our Data Privacy Team
Introduction & General Terms
Our Commitment to you
We may use third party suppliers to provide part of our service to you. In some circumstances these providers may be based in countries outside the European Economic Area whose laws provide for a different standard of protection for your personal information than that provided under UK Law. In such circumstances:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
If you would like further information about the specific mechanism, used by us when transferring your personal data out of the EEA please contact: firstname.lastname@example.org
Your personal data will not be disclosed to state institutions and authorities except if required by law or other regulation. Before we release data on this basis, we will ensure that the information is being provided to a genuine and properly authorised investigation.
Who we are
What Data we collect
When you send us information, talk to us over the phone, submit an online form or when you visit one of our websites, we may collect both personal and pseudonymous data about you.
Data you provide to us
Data we buy from a 3rd party
Data we collect through your use of our website
When we talk about personal data we mean any information that can identify you as an individual or company, such as your name and postal address. Pseudonymous data doesn’t identify you as a person, but it might be used in aggregate, for instance when you participate in a survey or when we analyse audience interaction with our products and services.
Data you provide to us
When you participate in, access, purchase or sign up to any of our services, activities or online content, such as magazine subscriptions, newsletters, competitions or events, we receive personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, as well as information collected about your use of our services (such as when you enter our sites and how long you stay on them).
Data we buy from a third party
We occasionally purchase data from third party suppliers. The data we purchase is primarily business data. Business data may include but not be limited to a business email address, business job title and business postal address. Such a purchase may result in you receiving communications from Eljays44 regarding your business sector or business interests without you having directly supplied your information to us. We keep clear records of the data suppliers and provide an unsubscribe option at every contact. If you have any queries concerning the use of business data we hold about you please email email@example.com
Data we collect through your use of our websites
We may collect information about how you use our websites or other content online, and the device(s) you use to access the services. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network device on the internet. Anonymous data will be recorded for the purpose of reporting web traffic statistics, advertisement ‘click-throughs’, and/or other activities on our sites. We may receive information about you from any third parties we may partner with through the use of cookie technologies to personalise advertisements for goods and services (please see Online Advertising below for further information) To opt out of receiving advertisements tailored to your interests by our partners, visit the European Interactive Digital Advertising Alliance at https://youronlinechoices.eu/
How we use your data
We may use the information you share with us and the information we collect through your use of our sites in the ways described below and as described at the time of capture.
- Competitions & Prize Draws
- Magazine Subscription
- Customer Services
- Direct Marketing
- Cookies and how we use them
- Online Advertising
- Links to third party websites
- Using our websites from outside the UK
Competitions & Prize Draws
We will use the details you have shared to manage your entry to any competition or prize draw. This may include your name, e-mail address and telephone number. We shall use such information to notify you if you are the winner. Your data will be retained for the period of the competition only and will not be added to any marketing lists unless you have consented to this and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of your prize.
We will use the details you have shared to send you the newsletter to which you have subscribed. We will not add them to any marketing lists, unless you have consented to this. We will provide a way for you to unsubscribe on every newsletter we send to you. Details you share with us for the purpose of newsletter subscription will never be shared with a third party.
We will use the details you have shared to manage your registration and entry into our event. This may include contact via telephone, email, SMS and post with information relating to the event you have registered to attend. Your data will not be added to any marketing lists unless you have consented to this and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery and or registration of the event.
We will use the information you provide to deliver customer services related to your purchase and to respond to inquiries or requests that you direct to us. Your data will not be added to any marketing lists unless you have consented to this and will only be shared with third parties where we have appointed them to manage specific aspects of your customer care.
We may use the information you provide to invite you to participate in surveys and focus groups about our products, advertisers and services. Participation is always voluntary and the answers you provide are anonymous and aggregated to support our learnings and inform changes we can make to improve our products and services. Your data will not be added to any marketing lists unless you have consented to this and were informed at the point of capture and will only be shared with third parties where we have appointed them to manage research activity on our behalf.
Occasionally we get paid by commercial partners to carry out research on their behalf. In this situation, the data we share with them will be anonymous however we may share your personal data with specific commercial partners where they were named at point of capture and where you agreed to the sharing of your personal data with them.
We may use the details you share with us to send you offers and promotions by email, post, telephone or SMS wherever we have legitimate interest grounds to do so and where you have not objected. We will provide a way for you to opt-out of receiving marketing promotions both at the time of data capture and every time we contact you thereafter. You can also email mailto:firstname.lastname@example.org to request your details are suppressed from all promotional campaigns. We won’t use your personal data for marketing purposes at all if you’ve told us not to.
We may process your personal data based on a legitimate interest which may include promoting similar products or services via direct marketing activity, to manage suppression and unsubscribe requests received from you, to identify and prevent fraudulent behaviour, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns.
Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights.
Cookies and how we use them
Strictly Necessary Cookies – These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information
Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
Functional Cookies – These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
Targeting Cookies – These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media Cookies – These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They can track your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
Eljays44 portfolio of websites uses Google Analytics & Statcounter as its primary solutions for tracking website visits, interactions and events. Eljays44 uses website analytics data to help improve the way we delivery content and online experiences to visitors.
For full details on how Google processes your data please visit: https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008
For full details on how Statcounter processes your data please visit: https://statcounter.com/about/cookies/
From time to time, Eljays44 may share this aggregated data with our advertising partners. This could mean that when you are on other websites you are served advertising based on your behaviour across Eljays44 titles or you may be served advertising based on your behaviour on other sites.
Behavioural retargeting is another form of Online Behavioural Advertising that enables us and some of our advertising partners to show you adverts based on browsing patterns and interactions with the site away from our sites. For example, if you have visited the website of a car dealership you may start seeing adverts from that same dealership site displaying special offers or showing you the products that you were browsing. This allows companies to advertise to website visitors who leave their website without making a purchase.
If you want to opt out of receiving Online Behavioural Advertising this does not mean that you will no longer receive advertising when you are using our sites. It just means that the advertising you see will not be customised for you. If you would like more information about online behavioural targeting and how to opt out of it, please visit www.youronlinechoices.com or you can also visit https://www.networkadvertising.org/
Links to third party websites
Using our websites from outside the UK
We use servers located in the EEA to store data. When you submit your details and in whichever country you are situated you agree to the data being transferred to the EEA and processed under the terms of Regulation (EU) 2016/679 (GDPR) including any implementing data protection legislation in the UK. If you are not in agreement, please do not add your personal details on the website. Eljays44 makes no representation or warranty that the content and materials on the Website are appropriate or available for use in locations outside of the United Kingdom. Those who choose to access the Website or use the services from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent applicable.
How we keep your personal data secure
Eljays44 security policies, rules and technical measures have been implemented to protect your personal information from unauthorised or improper use and from accidental loss.
All our employees and data processors that have access to, and are associated with, the processing of your personal information are legally obliged to respect the confidentiality of your data and are bound by contract to do so.
Note that some of our websites provide forums and commenting facilities where you can post information. When you do so, be aware that other visitors may collect any information you make public.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Who we share your personal data with
Eljays44 has formed partnerships with a variety of carefully selected companies that we share data with in order to carry out the activities described in the section How we Use your Data. Below is a non-exhaustive list of our key partners:
Freshsales, CircData, Jotform, Jonas Event Technologies
Statcounter, Google Analytics, Mail Chimp, Survey Monkey, Typeform
How long we keep your personal data for
We will hold your personal information on our systems only for as long as required to provide you with the products and/or services you have requested.
Where you sign up to receive email marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving emails in order to ensure that we continue to honour and respect that request. To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.
In some circumstances you can ask us to delete your data: see ‘Your rights’ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Personal Data – Your rights
Under the GDPR = including any implementing data protection legislation in the UK you have the rights shown below: –
- Your right to be informed
- Your right of access
- Your right to rectification
- Your right to erasure
- Your right to restrict processing
- Your right to data portability
- Your right to object
- Your rights in relation to automated decision making and profiling.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out towards the end of this document and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out towards the end of this document and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the How we use your data section of this Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out towards the end of this document and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
If you wish to exercise any of these rights or simply wish to find out what information, if any, we hold that relates to you, you must make your request in writing by sending an email to email@example.com or a letter to The Administration Team, Eljays44, 3 Churchill Court, 112 The Street, Rustington BN16 3DA.
You can help us to process your request quickly by providing us with information that will help us identify records we hold that relate to you. For example, your name, address, email address, telephone number, subscriber id or in the case of information captured via cookies, the IP address of the device you have used.
Contact our Data Privacy Team
If we decide to change our Privacy Notice we will post these changes on this page so that you are always aware of what information we collect, how we use it and in what circumstances we disclose it.
22nd May 2018 – New Policy Published