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Privacy Policy

This Privacy Policy explains how we use any personal data we may collect about you when you use our sites or services, or contact us directly.

1. Introduction

This Privacy Policy applies to personal data or information that we collect about you:

  • when you visit our site;
  • when you submit an enquiry;
  • when you sign up for, and sign into account;
  • when you subscribe to one of our newsletters;
  • when you contact us via social media;
  • when you email us directly;
  • when you write to us by post or telephone us;
  • in the course of delivering online advertising;
  • in the course of other marketing.

 

Unless otherwise stated below, Roosters.news (“we”, “us” or “our”) is the data controller of the personal data that we collect and process.

By continuing to use our site, you acknowledge our collection, storage and use of your personal information as described below.

2. The data we collect about you

The term “personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).

We may collect, use, store and transfer different kinds of personal data about when you visit our site.

Website functionality

We aim to provide our users with useful services through site functionality, some of which depends on our collecting and storing information relating to your preferences or browsing behaviour. When you are not signed into an account, we store this in persistent cookies on your web browser.

Cookies more generally

For further details of how we use cookies on our site, please see our Cookie Policy.

Children’s data

Our sites are not aimed at under-18s. Some content that is accessible on or via our sites will not be appropriate for children under the age of 18.

Special data

We do not seek to collect any special categories of personal data about you: those would include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we seek to collect any information about criminal convictions and offences.

If, however, when using any interactive feature of the site (such as an online contact form), you in fact provide us with any such special data or information about criminal convictions and offences, then by submitting such data/information, we’ll assume that you are fine with our use of such data/information for (a) the purpose for which you have voluntarily provided such data/information and (b) any purpose that is reasonably compatible with such purpose.

3. How we use your personal data

We shall only use your personal data when the law allows us to do so. We have set out below a description of all the ways that we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one legal ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out below.

Processing purposes

Analytics and web logs

When you visit our sites, we use analytics tools to collect, store and analyse standard web log data, which includes the web page you have requested, the web page from which you clicked a link to Roosters.news (if applicable), your computer’s public IP address, your web browser’s name and version number, and your device’s operating system, and any cookies we have stored when you have previously accessed our sites (if you haven’t configured your browser to refuse to store them).

In order to diagnose bugs, to gain a better understanding of usage patterns, and to identify and block abusive patterns of access, our analytics tools generate and store a unique browser identifier in a persistent cookie on your browser, which we log with each web page you request. This lets us distinguish unique users and link the log data we collect when you visit the site, with the log data from your previous and subsequent visits.

Our log data are only collected and processed in a way that does not identify anyone. We do not make any attempt to link this data to any personally identifiable information you might give us when submitting an online enquiry, subscribing to our newsletter, or signing up for or into an account.

We operate an in-house analytics tool as well as a third-party analytics tool called Google Analytics, a service run by Google acting under contract as a data processor. Your IP address is anonymised when processed by Google Analytics. We store your full IP address in our in-house web logs to allow us to identify and block abusive patterns of access. We also determine your country and city from your IP address, to understand usage patterns.

We retain our own in-house web log data records for around 30 days. Google Analytics does not allow us to access individual web log records. We retain aggregated and anonymised log data indefinitely in our in-house analytics tool and in Google Analytics.

We use those tools to allow us to diagnose bugs when they occur, to identify and block abusive patterns of access in order to maintain the security and performance of our sites, and to improve our services through understanding usage patterns.

Other functionality relying on cookies
Our sites also rely on storing data in other persistent and non-persistent browser cookies (known as session cookies) in order to provide other functionality. Please see our Cookie Policy for more details.
When you submit an online enquiry

We request and store your name and email address, and optionally your telephone number, company/organisation, position/job title and details of your enquiry, so that we can respond to your enquiry.

We will also collect some standard analytics and web log data (as explained above) and we may use it to better process your request, but we do not collect any data that would allow us to link your enquiry to any other web log records of your use of our site.

We retain enquiry records indefinitely to allow us to identify patterns in reported issues, and to maintain our relationship with repeat enquirers.

When you submit an online enquiry

We request and store your name and email address so that we can deliver our newsletters and address you correctly. We use in-house tools and a third-party provider, to deliver our email newsletters. When you open an email or click on a link embedded in an email, we gather statistics using industry-standard technologies, including clear gifs to help us monitor and improve our e-newsletter.

We will also collect some standard analytics and web log data (as explained above) and we may use it to better process your application, but we do not collect any data that would allow us to link your application to any other web log records of your use of our site.

When you contact us via social media

If you send us a private or direct message via a social media platform, a copy of the message may be sent to us by email as if you had emailed us directly (although without your name or email address if the social media platform does not store or forward this information).

We retain enquiry records indefinitely to allow us to identify patterns in reported issues, and to maintain our relationship with repeat enquirers.

When you email us directly

We use your email address, your name if you include it, and any other data you may include, to respond to your enquiry.

We may retain enquiry records indefinitely for as long as reasonably required for us to identify patterns in reported issues, and to maintain our relationship with repeat enquirers.

We may monitor emails sent to us, including file attachments, for viruses or malicious software.

When you write to us by post or telephone us.

We may retain correspondence with you when you write to us by post, as well as records of any correspondence by telephone.

We may retain enquiry records indefinitely for as long as reasonably required for us to maintain such correspondence.

Online advertising

We may serve personalised advertising content on web pages that you visit on the site, in which case we and/or our ad network partners may use personal data relating to you to generate such personalised advertising content.

Please note that our operations are funded by online advertising. We work directly with many firms (partners) to get the best value from our ad space. Some, known as ‘exchanges’, resell our ad space in a global market of products and services of brands and retailers, through their own direct relationships with those brands/retailers or other firms that represent them. Other partners provide us with other services, such as ad serving.

Our exchange partners may perform some of the following activities:

Collecting and processing information about your use of our sites with the aim of subsequently personalising advertising for you on our sites, or in other contexts, such as on other sites or apps. Typically, the pages of our site that you access are used to make inferences about your interests, which when combined together (to create a profile) inform future selection of advertising.

Selecting and delivering advertisements to you. This includes using contextual information about the pages of our site that you access, which may be combined with previously collected information about you to select ads.

Measurement of delivery and performance of ads and user activity, which includes processing data about what ads were shown, how often they were shown, when and where they were shown, and whether you took any action related to the ad, such as clicking an ad or making a purchase.

Our partners, in performing any of the above activities, do so where either they have independently obtained consent (which we may have facilitated) or have established a legal basis other than consent for those activities.

Other marketing

You may receive direct marketing emails from us if you have consented to receive those or if those relate to our services where you have bought similar services from us and, in each case, you have not opted out of receiving that marketing.

Change of purpose

We shall only use your personal data for the purposes for which we collected the data, unless we reasonably consider that we need to use such data for another reason and that reason is compatible with the original purpose. If you would like to get an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if and to the extent that this is required or permitted by law.

4. Disclosures of your personal data

We may share your personal data with the third parties set out below for the purposes set out in section 3 above. We require all such third parties to respect the security of your personal data and treat it in accordance with the law.

Regulatory bodies and other authorities, based in the EU, acting as processors or separate controllers, which may require reporting of processing in certain circumstances.

Other disclosures

In addition to the disclosures reasonably necessary for the purposes identified elsewhere in this Privacy Policy, we may share your personal information if we believe in good faith that access to or use, preservation or disclosure of such information is reasonably necessary: (a) to satisfy any applicable law, regulation, legal process or enforceable governmental request; (b) to enforce any contractual rights that we may have in relation to the services we provide to you; (c) to detect, prevent or otherwise deal with fraud, security or technical issues; or (d) to protect against harm to the rights, property or safety of Roosters.news , our employees or contractors, our business partners, our users or the public.

If we become involved in any prospective or actual transaction with a third party relating to our company, our business or substantially all our assets, we may share your personal information with that third party. We will endeavour to ensure the confidentiality of any personal information involved in such a transaction until (if at all) such personal information is transferred and becomes subject to a different privacy policy.

5. International transfers

Some of the disclosures described above may involve a transfer of data outside the European Economic Area (“EEA”).

Whenever we transfer your personal data out of the EEA, we strive to ensure that a similar degree of protection is afforded to such data by ensuring that at least one of the following safeguards is implemented:

  • transferring data to a provider based in the USA, if such provider adheres to the Privacy Shield framework, an agreement between the EU and the USA designed to protect data transferred between the two regions;
  • transferring your personal data to a country, organisation or sector that has, at the time of transfer, been deemed to provide an adequate level of protection for personal data by the European Commission;

 

and/or

  • using specific forms of contract approved by the European Commission that give personal data the same protection it within Europe.

 

For further details of such safeguards, please see the European Commission’s website.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

We have put in place appropriate security measures (including user authentication software and secure data-sharing feeds) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach, and we shall notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected such data, including for the purposes of satisfying any legal, accounting or reporting requirements.

In some circumstances you can ask us to delete your personal data: please see section 8 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.

8. Your legal rights

You may have the following rights (which may, in certain circumstances, be subject to certain exceptions under data protection laws):

(a) Right to be informed — you have the right to be told how your personal information will be used. This Privacy Policy and other policies and statements used on our sites and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.

(b) Right to withdraw consent — where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time. This will not, however, affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain content or services to you. We shall inform you if that is the case at the time when you withdraw your consent.

(c) Right to access — you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. We may need to seek evidence that you are entitled to see the information requested and to confirm your identity.

(d) Right to rectification — if our records of your personal information are inaccurate, you have the right to ask for those records to be updated. We may need to verify the accuracy of the new data that you provide to us.

(e) Right to erasure — you can ask us for your personal information to be deleted from our records where

  • (i) there is no good reason for our continuing to process such data,
  • (ii) you have successfully exercised your right to object to processing (see below),
  • (iii) we may have processed your information unlawfully or
  • (iv) we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

 

(f) Right to restrict processing — you may have the right to ask for processing of your personal data to be restricted, where

  • (i) you would like us to establish the accuracy of such data;
  • (ii) our use of the data is unlawful, but you do not want us to erase the data;
  • (iii) you need us to hold the data even if we no longer require the data as you need the data to establish, exercise or defend legal claims; or
  • (iv) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use the data.

 

(g) Right to data portability — where we are processing your personal information

  • (i) with your consent,
  • (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request before entering into a contact or
  • (iii) by automated means, you may ask us to provide it to you – or to another service provider – in a machine-readable format.

 

(h) Right to object to processing — you may have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you believe that it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

(i) Right to not to be subject to automated decision-making where that would have a significant effect on you. We do not in fact engage in such activities, so this right will not, in practice, be relevant in the context of your use of our sites.

To exercise these rights, please send a description of the personal information in question using the contact details at section 9 below. Where we consider that the information with which you have provided us does not enable us to identify the personal information in question, we reserve the right to ask for

  • (i) personal identification

 

and/or

  • (ii) further information.

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we shall notify you and keep you updated.

9. How to contact us

If you have any questions about this Privacy Policy or our use of your personal information, please contact us at: info@roosters.news