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Privacy

Introduction

Data Controller

Under the EU General Data Protection Regulation (GDPR) which comes into force on 25 May 2018, we have to say who the ‘data controller’ is for (Tradeclips) and services provided through it. The data controller is the organisation responsible for protecting information and, in our case, this is Caters Media Group Limited, a company incorporated in England, with company number 09635833, whose registered office address is 68 Argyle Street, Birkenhead, Merseyside, United Kingdom, CH41 6AF, which is part of the Caters News Media Group (Caters).

ICO Registration Number: ZA286679

How to contact us

Please address requests and questions about this or any other question about this Privacy Policy to the Data Protection Officer at dpo@catersnews.com, or call us on +44 (0)121 616 1100 or write to us at Caters Media Group Limited, The Drop Forge, 6-10 Hockley Street, Birmingham, West Midlands, B18 6BL, United Kingdom.

Legal information

Complaints will be dealt with by the Data Protection Officer and will be responded to within 30 days at the latest.

If you are not satisfied with the way your complaint was handled

You are able to refer your complaint to your local data protection regulator. For example, in the United Kingdom this is the Information Commissioner’s Office, and in Australia is the Office of the Australian Information Commissioner.


We take your privacy very seriously and we ask that you read this Privacy Policy carefully as it contains important information on:       

  • the personal data we collect about you;       
  • how we collect your personal data;
  • how and why we use your personal data;       
  • disclosures of your personal data; and      
  • your legal rights in relation to your personal data

The data we collect about you

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 (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:       

  • Identity Data includes first name, last name, username or similar identifier.       
  • Contact Data includes email address and telephone numbers.       
  • Technical Data includes details of visits to our site, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.       
  • Profile Data includes your username and password.       
  • Usage Data includes information about how you use our website, products and services    
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes 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 collect any information about criminal convictions and offences.

Personal Data about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:       

  • give consent on his/her behalf to the processing of his/her personal data;       
  • receive on his/her behalf any data protection notices; and       
  • give consent to the transfer of his/her personal data abroad.

Where Tradeclips proposes to use your personal data for any other purpose we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal data for purposes other than those listed above.

Cookies

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a "device") browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows.

Tradeclips uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies and the information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of Tradeclips, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using Tradeclips, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to Google’s privacy policy for more information on how it treats your data: http://www.google.com/privacypolicy.html.

If you would like to opt-out of Google Analytics monitoring your behaviour on Tradeclips please use this link (https://tools.google.com/dlpage/gaoptout/).

If you wish to restrict or block the cookies which are set when you visit Tradeclips, you can do so through your browser settings, however please note that if you do this you may not be able to use the full functionality of Tradeclips. Please visithttps://www.aboutcookies.org for comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies.

Users aged 16 or under  

We do not knowingly collect or store any personal data about children under the age of 16 and we do not offer any of our products or services directly to children under the age of 13.

If you fail to provide personal data   

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Sharing of data  

Depending on where you live, your personal information may be shared with the Caters News Media Group of companies that are based in the UK, USA, Australia & India. For example, if you are based in Australia, your data may initially be held on our systems in the United Kingdom and then shared with our subsidiary Caters News Australia, 55 Pyrmont Bridge Road, NSW 2009 in Australia for administration purposes.

We will not share your personal data with others for marketing purposes unless you have given us your permission. If we have your permission, we will share your personal data only with other organisations we have chosen carefully. This is set out in more detail later in the Privacy Policy.

We may make other organisations’ services available, through our sites, although we are not necessarily operating these sites. We process any information which we collect when you access a service provided by another organisation under this Privacy Policy. Information these other organisations collect is governed by their own privacy policies.   

We can access and release personal data to keep to relevant laws and government requests, to operate our systems properly and to protect both us and our users.

Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the European Economic Area (EEA).

Any transfer of your data out of the EEA will be subject to a European Commission approved contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

Some of our webpages use plug-ins from other organisations (such as the ‘Facebook Share’ function). These other organisations may use information about your visit to Tradeclips or our other websites on their pages. If you browse these pages while still also logged in to your account with us, information they collect may be connected to your account on their site. For more information on how these organisations use information, please read their privacy policies.   

How is your personal data collected?   

We use different methods to collect data from and about you including through:       

  • Direct correspondence. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:               
    • apply for our products or services;               
    • create an account on our website;      
    • subscribe to our service or publications;               
    • request marketing to be sent to you;               
    • subscribe to a promotion or survey; or               
    • give us some feedback.            
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.catersmediagroup.com/cookies for further details.     
  • Third parties or publicly available sources. We may receive personal data about you from various third parties including Technical Data from Google, as set out previously

How and why we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:        

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.     
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

The table below sets out how we use your data and the lawful basis for doing so.

   

Activity Which data? Why?

               

To register you as a new customer

           

               

(a) Identity

               

(b) Contact

           

               

Performance of a contract with you

           

               

To contact you regarding completion of the registration process

           

               

(a) Identity

               

(b) Contact

           

               

Performance of a contract with you

           

               

To process and deliver your order including:

               

(a) Manage payments, fees and charges

               

(b) Collect and recover money owed to us

           

               

(a) Identity

               

(b) Contact

               

(c) Financial

               

(d) Transaction

               

(e) Marketing and Communications

           

               

(a) Performance of a contract with you

               

(b) Necessary for our legitimate interests (to recover debts due to us)

           

               

To manage our relationship with you which will include:

               

(a) Notifying you about changes to our terms or privacy policy

               

(b) Asking you to leave a review or take a survey

           

               

(a) Identity

               

(b) Contact

               

(c) Profile

               

(d) Marketing and Communications

           

               

(a) Performance of a contract with you

               

(b) Necessary to comply with a legal obligation

               

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

           

               

To enable you to complete a survey

           

               

(a) Identity

               

(b) Contact

               

(c) Profile

               

(d) Usage

               

(e) Marketing and Communications

           

               

(a) Performance of a contract with you

               

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

           

               

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

           

               

(a) Identity

               

(b) Contact

               

(c) Technical

           

               

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

               

(b) Necessary to comply with a legal obligation

           

               

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

           

               

(a) Identity

               

(b) Contact

               

(c) Profile

               

(d) Usage

               

(e) Marketing and Communications

               

(f) Technical

           

               

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

           

               

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

           

               

(a) Technical

               

(b) Usage

           

               

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

           

               

To make suggestions and recommendations to you about goods or services that may be of interest to you on the basis of previous sales to you via electronic means (telephone, email, SMS or App push notifications)

           

               

(a) Identity

               

(b) Contact

               

(c) Technical

               

(d) Usage

               

(e) Profile

           

               

Necessary for our legitimate interests (to develop our products/services and grow our business)

           


Note that we may process your personal data for more than one lawful 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 we are relying on to process your personal data where more than one ground has been set out in the table above.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase. We will continue to communicate with you for reasons essential to the fulfilment of any orders.  

Disclosures of your personal data

We may have to share your personal data with the parties set out below, for the purposes outlined in the table, above.        

  • Service providers who provide IT and system administration services.     
  • Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.       
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your rights under the GDPR

Under the Data Protection Act 1998 (DPA) and now under the GDPR, organisations must set out how they intend to use your personal data and the rights you have in relation to this and must do so in a concise, transparent, intelligible and easily accessible way. Privacy Notices should also include the lawful basis for processing your personal data, that an organisation is choosing to rely upon.  

What rights do you have   

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

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.

Data Retention  

How long will you use my personal data for?

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.  

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

For Personal Data that is not required to be kept for legal purposes, we will retain your data for 24 months from the point at which you provide it.

If you contact us to delete your personal data from your system, we will send you one final email to confirm that this has been done and we will only retain the email from you which requests the deletion of that data.

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.  

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, these include:       

  • Request access to your personal data.
  •        

  • Request correction of your personal data.
  •        

  • Request erasure of your personal data.
  •        

  • Object to processing of your personal data.
  •        

  • Request restriction of processing your personal data.
  •        

  • Request transfer of your personal data.
  •        

  • Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us at dpo@catersnews.com. You have the right to:       

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.       

  •  Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.           

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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. 

  • 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 which makes you want to object to processing on this ground as you feel it impacts on 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 which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.   

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

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 will notify you and keep you updated.

Changes to the Privacy Policy

Should we elect to change our Privacy Policy we will post the changes here. Where the changes are significant, we may also choose to email all our registered users with the new details. Where required by law, will we obtain your consent to make these changes.