Your Privacy Matters
This privacy statement is effective as and from 23rd May 2018
Your privacy is important to The Irish Times and maintaining your trust is paramount to us. We are fully committed to keeping your personal information safe. We will comply with the terms of the General Data Protection Regulation (GDPR) and all other relevant data protection legislation. If we ask another organisation to provide a service for us, we will make sure that they do too.
This privacy statement is intended to provide you with information about the personal information we collect and how that personal information is used and shared. It also sets forth your privacy rights. Please take a moment to familiarise yourself with our privacy practises.
Any reference to the “Group” within this privacy statement includes of any of our subsidiaries, our ultimate holding company and its subsidiaries including The Irish Times DAC, My Home.ie, Irish Times Training, Irish Racing Services and Rewarding Times. By using our Group websites, mobile applications, products or services (collectively our “Services”), the collection, use and sharing of your personal data is subject to this privacy statement.
We will update this privacy statement from time to time. If we make changes, we will notify you prior to the changes taking effect by posting a notice on our websites and where appropriate, sending you a notification. By continuing to use our services after such revisions are in effect, you accept and agree to the revisions and to abide by them.
We value your opinions. Should you have any questions or comments related to this privacy statement, please contact us at email@example.com.
The Irish Times DAC of 24-28 Tara Street, Dublin 2, Ireland is the data controller of the personal data you provide to us. We can be contacted by email at firstname.lastname@example.org or by phone at +353-1-675 8000.
Data Protection Officer
We have appointed an internal Data Protection Officer (DPO) for you to contact if you have any questions regarding this privacy statement, our privacy practises or if you wish to exercise your legal data rights (see “Your Data Rights” section below). Whilst we have appointed a DPO, our Customer Care team will be your initial point of contact for all data protection inquiries. They can be reached by email at email@example.com or by phone at +353 1 675 8000.
Information we collect
We collect information about you, including personal information, as you use our services and interact with us.
Information you provide us and how we use it
You provide personal information to us for a variety of reasons, such as:
To pay for the services you have requested from us (Contract)
We may collect your payment information to pay for the services you have requested from us. This includes but is not limited to your credit and debit card number, card expiry date, CSV /CV2 number, BIC (Bank Identifier Code), IBAN (International Bank Account Number), Direct Debit mandate authorisation and cheques. Credit and debit card information is processed directly by PCI compliant payment providers who perform payment services on our behalf. Occasionally our employees receive payment information from customers over the phone. When this occurs the payment information is entered as instructed into the relevant payment system and all other copies are deleted or destroyed immediately. We use your payment information to administer process and pay for the services you have requested.
To receive marketing communications (Consent)
With your permission, we may periodically send promotional emails about features, events, exclusive offers and competitions to the email address you have provided. To receive marketing emails from us, you will need to provide us with at least your email address and in some cases, your first name, last name, job title & company. We have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing communications tailored to your interests. You may at any time choose not to receive marketing communications from us by following the unsubscribe instructions included at the end of each email communication.
For competition and promotional purposes (Contract)
We regularly run competitions or similar promotions that you can voluntarily enter. In most cases, to enter a competition you will need to provide us with your name, email address, phone number and county information. We ask for your county information to help distinguish between entrants with the same name when selecting a winner. In some cases, the competition entries will be shared with the promoter and this will be specified when you enter. If you win a competition you enter, you will be notified by phone call and we will publish your name on our website and indicate the prize you have won. In the event that you share the same name with another competition entrant, we will publish your county alongside your name. We use your personal information to administer the competition or similar promotion and as per the terms and conditions you accept when you enter.
We deliver these communications to the email address you provided us when you subscribed. We rely on the lawful processing ground of our legitimate interests (See “The purpose and legal basis for processing your information” section below).
You can opt out of these email communications at anytime by unsubscribing at the bottom of each email communication.
Live chat (Contract)
We provide “Live Chat” sessions on our website to assist you while assessing the subscriptions we offer. You can use our live chat sessions to talk directly to one of our Customer Care representatives. We ask you to provide us with your name and email address and we use this information so that we can respond to your inquiry. You can, if you wish, request that we send a copy of the transcript of the chat to the email address you have provided. Your live chat correspondence is maintained by us for verification purposes and is processed to take the necessary steps at your request prior to entering into a subscription contract with us.
In correspondence with us (Legitimate Interest)
If you correspond with us we will collect information such as your name, address, phone number and email address and any other personal information contained within the correspondence and use it to respond to your inquiry. We process this information in pursuit of our legitimate interests (see “The purpose and legal basis for processing your information” section below). which include developing and maintaining relationships with our customers and readers.
Irish Times Training services (Contract)
The Irish Times provide professional training and education services through our subsidiary Irish Times Training. Irish Times Training is a QQI (Quality and Qualifications Ireland) centre offering multiple programmes leading to qualifications from QQI on the National Framework of Qualifications. The executive education programmes offered are delivered by Ulster University and Boston College.
To enrol for one of our training courses you will need to provide us with your name, address, email address, phone number and in some cases payment information. If your enrolment is being sponsored by your employer, we will need to know the name of the Company you work for. Depending on the specific course you are enrolling for and the requirements of the professional body accrediting the course, you may need to provide us with additional information as follows:
- If your course is QQI accredited, we will collect your PPS number and date of birth on behalf of QQI who require it for authentication and fraud prevention purposes. We will treat your PPS number as highly sensitive information.
We use the personal information you provide us to administer and manage these training services including admission, enrolment, billing, collection of fees and charges and examinations. We will collect your exam results and in conjunction with maintaining your certification(s), your record of participation in our training courses. We will use the email address you provide for the purpose of distributing any training materials related to your course. We may also collect and store information provided by you to assess your training needs for the purpose of tailoring course content and/or to evaluate the performance of your trainer and of the training material provided.
Your personal information may be shared with our third-party training partners, trainers, external independent examiners and accreditation bodies. If your training course is delivered by an external university, we will share your personal data with that external university as appropriate.
Not all of the personal information we hold about you for our training services will come directly from you.
- If you are in receipt of social welfare, you may be eligible for a Technical Employment Support Grant (TESG) which can be used towards the cost of some of the training courses we provide. If we receive an application from The Department of Employment and Social Protection we will know you are in receipt of social welfare. We will treat this information as highly sensitive.
- If you complete an accredited training course with us, the accreditation body may share your final exam results with us. We process this information in accordance with our legitimate interests (see “The purpose and legal basis for processing your information” section below). which are assessing the effectiveness of our training material, our training staff and in advertising the success rate of our training services.
- You may be signed up for our training services by a third party such as one of our training partners, or your own employer. By signing you up for our services, they indicate they have the appropriate consent to do so.
By enrolling on a training course with us, you agree for your personal information to be processed in the manner described above and as per Irish Times Training’s Terms & Conditions you accept when you enrol.
If you attend one of our events (Contract)
We host many events throughout the year. These include but are not limited to breakfast briefings, live content events, live lectures, podcast recordings, training, conferences and seminars. If you register for one of our events we will collect your name and contact information and in some cases your address and payment details and use this information to register for the event, process your payment and provide you with information and services associated with the event. In some cases we make audio or video recordings of these events and we may record information about you as a consequence. We will always inform you in advance if the event is being recorded so that you can choose not to participate if wish. Registration for our events is voluntary. Once you register however, we process your personal information as per the terms and conditions of that specific event.
To verify your identity (Legal)
To exercise your data rights (see “Your Data Rights” section below), we may need to collect additional personal information from you to verify your identify. We will verify your identity by reference to acceptable identification documentation supplied by you, which may include copies of your current passport, driving licence or Public Services Card (PSC).
To participate in a survey or poll (Consent)
We conduct surveys and polls that we use to produce original research from our network. Your participation is entirely voluntary. You may consent to The Irish Times contacting you at the email address provided to participate in this research. We do not track individuals but look at the information in the aggregate. Any opinion you express therefore is anonymous. The type of information we collect varies and is wholly dependent on the individual survey or poll. If you would like more information about the type of information we collect in our surveys and polls please contact us at firstname.lastname@example.org.
From time, upon completing a survey or poll we may ask for your email address and in some cases your full name for competition, promotional or gifting purposes. Participation is entirely voluntary and this information is processed and stored separately from the information you provide us for the survey or poll. Where you provide this information to us, it will be processed only to to administer the competition or promotion.
Personalisation (Legitimate Interest)
We use some of the information you provide to personalise your experience with us as you use our services such as addressing you personally on our services and making navigation on our sites easier. We use aggregate information we collect about you to suggest and recommend tailored content. This processing is necessary for the purpose of our legitimate interests (see “The purpose and legal basis for processing your information” section below).
in delivering relevant content. You have the right to object to this processing if you wish, please contact us at email@example.com if you wish to object.
When you provide services to us (Contract)
You may provide us with your personal information if you provide professional services to us. This typically includes your contact information, address, phone number, your VAT registration number and maybe your banking information. We process this information so that we can administer, manage and pay for the relevant services you provide and as per the terms and conditions of our contract. In some circumstances your services may extend to delivering live lectures or involvement in our live events in which case we may make audio or video recordings of you.
Information we collect and how we use it
The Irish Times collect the following information about you as you use our services and interact with us:
Use of our services
We collect information relating to your use of our services to track how you gain access to or read our content. We typically collect this data in a form that does not, on its own, permit direct association with any specific individual and therefore cannot be reasonably used to identify you. Aggregated and anonymous data is considered non personal information for the purposes of this privacy statement. If we can link usage data with your personal information and identify you, we will treat that linked data as personal information for as long as it remains combined.
We use login information, cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services as follows:
- We log certain technical information that your browser sends us including the Internet protocol (IP) address, browser type and version, time zone setting, access time; browser plug-in types and versions, operating system and platform and device type.
- We log usage information about the use of our website and services, including a history of the pages you view and other actions you take while visiting us including the full Uniform Resource Locators (URL) clickstream to, through and from our site; articles, content and products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Technical information, including the type of mobile device you use, unique mobile identifies, such as the devices IMEI number, mobile network information, your mobile operating system, the type of mobile browser you use and the time zone setting.
- Details of your use of our mobile applications including but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
- We may also use GPS technology to determine your location. Some of our location enabled services require your personal data for the feature to work. If you wish to use a particular feature you will be asked to specifically consent to your data being used for this purpose.
- When you sign up for or subscribe to one of our services, we will track and aggregate non personal information previously collected about you through our services with the personal information provided when you register or subscribe. If we link other data with your personal information and can identify you we will treat that linked data as personal information for as long as it remains combined.
Cookies and similar technologies
We use such technologies to determine whether you’ve opened an e-mail communication from us or clicked on a link contained in an e-mail. Collecting information in this manner allows us to gather statistics about the usage and effectiveness of our services and products including our email newsletters and direct marketing communications.
Our premises at 24-28 Tara Street, Dublin 2 are monitored by CCTV camera surveillance. We may record personal information about you if visit our offices or walk in close proximity to our business premises. CCTV notices are on display outside our building to inform you of our practises and to give you advance notice of any recording so that you can exercise your right to object if you wish to do so.
We are processing CCTV video surveillance data generally without your consent in pursuit of our legitimate interests (see “The purpose and legal basis for processing your information” section below) to protect the rights, property and safety of The Irish Times DAC or the rights, property or safety of our employees or others.
The CCTV surveillance information we collect may be shared with An Garda Síochána or other third parties where we are required to do so by law.
Information we get from other sources and how we use it
Not all of the personal information we hold about you will come directly from you. We collect information from third parties such as our partners, service providers and publically available sources such as social media platforms.
We collect your social media profile details including your name and email address when you sign up for one of our services through a social media account. We use these details for the purposes of our registration process. We may also automatically import your profile photo and membership status of Facebook, LinkedIn and Twitter if you choose to make these details public.
If you complete an accredited training course with us, the accreditation body may share your final exam results with us.
Social welfare status
If you are in receipt of social welfare, you may be eligible for a Technical Employment Support Grant (TESG) which can be used towards the cost of some of the training courses we provide. If we receive an application from The Department of Employment and Social Protection we will know you are in receipt of social welfare. We will treat this information as highly sensitive.
Signed up for our services by a third-party
You may be signed up for our training or subscription services by a third party such as one of our training partners, or your own employer. By signing you up for our services, they indicate they have the appropriate consent to do so. We may share your personal information with these parties for billing and payment purposes.
Anonymous information we process
Third-party vendors, including Google, display advertising on our services. Some of the ads you receive when using our services are customised based on predictions about your interests generated from your visits to our site. Such online advertising helps support the content, products and services The Irish Times provide.
We and third-party vendors, including Google, use first-party cookies and third-party cookies together to inform, optimise and serve ads based on users’ past visits to this website. We use data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender and interests) with Google Analytics to understand who our users are in order to create a better experience for them while visiting our website. We may use Remarketing with Google Analytics to advertise online.
Advertising networks may track you in order to measure the effectiveness of the ads they serve, or to create a web surfing profile for you that is used to create more personalised ads. The AdChoices icon on our ads lets you know when information about your interests may be collected or used for relevant advertising. By clicking on the AdChoices icon you can learn more about the ad, the collection practices and be provided with the ability to opt-out of such targeting. By turning off ads personalisation, you will still see ads on our site, but they’ll be less targeted to you. You can also object by visiting your browser cookie settings.
The purpose and legal basis for processing your information
We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.
To enter into and perform a contract with you
We use your personal information to carry out our obligations arising from any contracts entered into between you and us or to take the necessary steps at your request prior to entering into a contract with us including:
- To provide you with the subscription, services or products you have requested.
- To process your payment information.
- To authenticate and verify your account.
- To provide customer and technical support.
- To administer and manage the training services you have contracted with us to provide including admission, enrolment, billing collection of fees and charges and examinations.
- To administer competitions or similar promotions.
- To process live chat information at your request prior to entering into a subscription contract with us.
- To provide our recruitment services to you when requested.
- To administer, process and pay for the services you may deliver to us.
- To send important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service. We may do this by phone, post, email, SMS text or through other digital media.
With your consent
We will, in certain circumstances, rely on your explicit consent to process your personal data. Where we do, you have the right to withdraw your consent at anytime. In most circumstances your consent can be withdrawn by following the unsubscribe instructions included at the end of each email communication from us. You can also contact us at firstname.lastname@example.org and we will be happy to facilitate your request.
To comply with our legal obligations
We may be required to process your personal information to comply with certain legal obligations to which we are subject, including.
- In the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets in which case the personal information we hold on you may be one of the transferred assets.
- Proving information to an Gardai Síochána, the Revenue Commissioners or other government bodies or agencies when required to do so by law.
- In order to enforce or apply; Irish Times Training’s Terms & Conditions that you accept when you enrol and/or The Irish Times Terms of Service as applicable.
- Where necessary for the establishment, exercise or defence of legal claims.
- If you have exercised one of your data rights, we will retain a copy of all correspondence to demonstrate our compliance with data protection legislation.
- If you have exercised one of your data rights and ask us not to contact you by email at a particular email address, we will need to retain a copy of that email address in order to comply with your no-contact request.
Processing based on our legitimate interests
We process your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. Our legitimate business interests do not automatically override your interests. You have the right, free of charge to object to our use of your personal information for our legitimate interests. Please bear in mind that if you do object, this may affect our ability to carry out certain tasks for your benefit.
Where you object to our use of your personal information for our legitimate interests we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so. We will always ensure that there is a fair balance between our legitimate interests and your fundamental right and freedoms.
We process personal information for the following legitimate business purposes:
- To manage our everyday business needs and for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, auditing, technical support and fraud prevention.
- To provide you with a more personalised experience, such as making content recommendations. By understanding which content you find useful or interesting, we can recommend more content that you might also like, as well as continuing to produce the most valuable content to meet your needs.
- To support our advertising services.
- To determine the effectiveness of promotional campaigns, email campaigns and advertising.
- To research and improve The Irish Times’ products, services, and customer communications.
- To ensure that content from our site and mobile applications is presented in the most effective manner for you and for your device.
- To implement customer retention and win-back strategies
- To better understand and improve the usability, performance, and effectiveness of our services.
- We may process your information to protect you against fraud when transacting on our services and to detect, prevent, investigate security or technical issues to ensure our services are secure.
- To protect the rights, property and safety of The Irish Times DAC or the rights, property or safety of our employees or others.
- To provide you with information about other goods and services we offer that are similar to those that you have already subscribed for, purchased or enquired about;
- Assess the effectiveness of our training material, our training staff and in advertising the success rate of our training services.
- To understand the demographics of our customers and readers.
You have the right to object to this processing if you wish, and if you wish to do so please contact us at email@example.com.
When and how your information is shared
Within our group
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries and use it in a manner that is consistent with this privacy statement.
We may share your personal information with third parties for a number of reasons as outlined below. We do not sell your personal information to anyone and only share it with third parties who are facilitating the delivery or fulfilment of our services and or are working on our behalf. We contractually require that our suppliers protect such information from unauthorised access, use, and disclosure.
Third-party service providers
We may share your personal information with third party service providers that perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, payment providers, lawyers, providers of security and administration services and and other business advisors.
Third-party service partners
We provide certain services and run promotions in conjunction with third parties and we may share your personal information if the service you have requested is fulfilled by them. Examples include but are not limited to our Page and Photo sales service, travel offers, restaurant reservations, family notices and our promotions in association with other publishers. These third parties have their own security and privacy policies. You are advised to review these separately.
We disclose non-personally identifiable aggregate information to third-party advertisers and to help advertisers reach the kind of audience they want to target. We share summary aggregate reports for our advertisers to measure the effectiveness of the ads they have served.
Third-party training partners
If you participate in an Irish Times Training course your personal information may be shared with our third-party training partners, trainers, external independent examiners and accreditation bodies. If your training course is delivered by an external university, we will share your personal data with that external university as appropriate.
We may share your personal data with a third-party auditing organisation (ABC) in accordance with our legitimate interests to verify aggregated statistics about circulation and usage of our products or review our policies, processes and procedures for compliance with relevant standards.
Social networking sites
Data storage and retention
The Irish Times DAC will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information no longer than is necessary to comply with our business and legal obligations. Where we enter into a legal contract with you we will hold your personal information for a period of 7 years from the date of completion of this contract by reference to the statute of limitation for a legal claim under contract. In other instances, such as in relation to direct marketing, we will hold your personal information for a period of 12 months after you have unsubscribed from receiving direct marketing communications from us. For more information on our data retention policies please contact us at firstname.lastname@example.org.
Personal information we collect from you may be processed outside the European Economic Area (EEA). We safeguard the transfer of personal data outside of the EEA by partnering with data processors that adhere to data protection frameworks that the European Commission have decided provide an equivalent level of privacy protection . All personal data that is transferred outside the EEA is transferred on the basis of an adequacy decision from the EU Commission as set forth in Article 45 of the GDPR.
Your Data Rights
You have several rights under data protection law in relation to how we use your personal information. You have the right, free of charge, to:
- Request a copy of the personal information we hold about you in a structured, commonly used and machine readable format
- Rectify any inaccurate personal information we hold about you
- Withdraw your consent where we have relied upon your consent to process your information.
- Erase the personal information we hold about you subject to certain exceptions.
- If technically feasible, have your personal information transmitted to another data controller at your request.
- Restrict processing of your personal information in certain circumstances.
- Object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes.
- Not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not knowingly make automated decisions of this nature.
- Lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data.
These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights please contact us at email@example.com.
We will take measures to verify your identify which we will do by reference to acceptable identification documentation supplied by you. These include but are not limited to copies of your current passport, current driving licence or current Public Services Card (PSC).
We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.