Privacy Policy

Your privacy is important to us

Introduction

This is the privacy policy for DC Thomson & Co. Ltd and the companies and brands that form part of the DC Thomson group (“DC Thomson”).   It explains how we use your personal information when you give it to us, or when we collect it from you as you interact with our brands.

When we say “we” or “us” in this policy, we’re referring to companies and brands that are part of DC Thomson.  Each of our companies is what is known under data protection law as a ‘data controller’.  This means each company is responsible for processing your personal information in a lawful manner – and where more than one of our companies is involved, they’re jointly responsible. If you have any questions about how your we use your personal information or wish to exercise any of your rights, then you should use the contact details below.

To make it easier for you to understand how we use your personal information, we’ve created a single policy to cover our companies and brands.  Our brands page contains information about many of these.  We also have a single point of contact for any questions that you may have in relation to our use of your personal information.

Some brands within DC Thomson have their own separate privacy policies. These include:

Where one of our brands has its own privacy policy, or uses a supplemental privacy policy, then we’ll let you know about that at the time we collect that information from you.

What Personal information do we collect and how do we use it?

In this policy, ‘personal information’ means personal data about you, from which you can be identified.  It does not include data that can no longer be used to identify you.

The types of personal information we collect and how we use it depend on how you interact with us.  You can find out how we use your personal information by clicking on the sections below that are most relevant to you:

If you subscribe to one of our newspapers, magazines or apps

We process your personal information when you have an active newspaper, magazine, digital product or app subscription with us, as well as afterwards. This includes collecting your personal information, recording it, storing it, using it, amending it, deleting it and in some circumstances sharing it.

The personal information we process about you and the purposes for which we use it are set out in the table below. We can only use your personal information when we have a good, lawful reason for doing so – our reasons are typically that:

  • we need to use your personal information so we can provide you with the newspaper, magazine, digital product or app subscription;
  • we have a good business justification to use your personal information, which we think is reasonable and treats you fairly (for example, we might record your calls to us for training and quality purposes). Under data protection law, this is referred to as a ‘legitimate interest’; or
  • we need to use your personal information so we can comply with a legal obligation (for example, an obligation to notify you of a product recall)

 

Reason for processing your personal information Your personal information Legal ground(s) for processing Our legitimate interest (where applicable)
To process your order including sending you (or the nominated recipient) your physical purchase

To make your subscription available online or via an app if it is digital-based or includes a digital component

To register and operate your online account

To contact you with information and updates regarding your subscription, including renewal notifications

To notify you of subscriber-related content and events and provide you with access to them

 Name

Email address

Home address

Delivery address (if different)

Phone number(s)

Title

Company/ organisation name

Job title

Purchase details and order history

Login details for your online account or app

If you register using Facebook, Google or Apple we will collect the information you’ve allowed them to share with us

If you connect with our app using your social account and select to allow us to access your basic profile information etc we may access your basic public profile and friend list, including username, email (encrypted) and avatar.

Marketing preferences you’ve indicated to us

Nominated recipient details

Gift message for nominated recipient

 Necessary to perform the contract between us

Necessary for our legitimate interests

 To maintain our subscriber numbers so we can continue to provide you with our products

To remain engaged with you and to bring you additional benefits where possible
To process your payments (including recurring payments) and collect and recover money owed to us Name

Email address

Billing address

Phone number(s)

Bank account or payment card details

If you use a payment service (for example PayPal) we collect the limited information they share relevant to the transaction

Purchase details and order history

Company/ organisation name

Job title

VAT number

If your subscription is purchased via an app store, the app store holds your purchase information not us.

 Necessary to perform the contract between us

Necessary for our legitimate interests

Legal obligation (for example provision of an invoice for VAT registered businesses, or to provide confirmation/receipt of payment/Direct Debit set up)

 To recover debts owed to us

To provide you with order documentation such as order confirmation

 

 
Manage in-App game/puzzle play and provide the functions and features you have registered for including:

game status and rewards

saving your state of play and customise some elements

 

Access the app across multiple devices

 Email address

In-app username

Game/Puzzle Status

Purchase history

In-app progress, including time, streaks, game play history, rewards, completion rates, hints and puzzle token usage, spend, state of play etc.

Language setting

If you connect with our app using your social account and select to allow us to access your basic profile information etc we may access your basic public profile and friend list, including username, email (encrypted) and avatar
To send you marketing communications with our suggestions and recommendations about goods and services that may be of interest to you

This includes:

when we provide you with personalised content and/or display tailored messaging to you when you visit our websites or Apps; and

when we may show you our marketing (for example adverts) on other platforms such as Facebook

 Name

Email address

Home address

Delivery address (if different)

Phone number(s)

Purchase details and order history

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)

Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information

Game/Puzzle Status

In-app progress, including time, streaks, game play history, rewards, completion rates, hints and puzzle token usage, spend, state of play etc.

Language setting

 Necessary for our legitimate interests

Consent

 To promote our products and services

To send direct marketing communications, to make these more relevant to you where possible, and analyse the effectiveness of our campaigns

To remain engaged with you and to bring you additional benefits where possible
To manage our relationship with you including:

notifying you about changes to our terms or privacy policy;

asking you to leave a review, complete a survey or take part in research;

dealing with any queries, requests or issues you have including those sent from within app; and

confirming when you have completed a particular activity (for example when you have changed personal details associated with your subscription)

 Name

Email address

Home address

Phone number(s)

Login details for your online account or app

Marketing preferences you’ve indicated to us

Purchase details and order history

Payment information

Nominated recipient details

 Necessary to perform the contract between us

To comply with a legal obligation (for example to tell you about a change to our terms that may significantly affect you)

Necessary for our legitimate interests

 To keep our records updated and to learn how our customers use our services

To provide a good level of customer service and deal promptly with your questions, comments or suggestions
To help us analyse and improve the technical functionality, security and performance of our websites and Apps I.P. address and other device identifiers

Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)

Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information

 Necessary for our legitimate interests To ensure our websites and apps operate to the high standards you expect
To help us improve the quality and variety of the content and features we provide in our newspapers, magazines, digital products and apps I.P. address and other device identifiers

Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)

Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information

 Necessary for our legitimate interests To continuously improve our content and features, as well as develop new ideas that we think our customers will like
To help us build an understanding of our customers, whether as individuals or as larger groups, so we can identify customers who may have similar interests, preferences and characteristics Name

Email address

Home address

Delivery address (if different)

Phone number(s)

Title

Company/ organisation name

Job title

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers may include operating system and device type

Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)

Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information

Purchase details and order history

Nominated recipient details

 Necessary for our legitimate interests To understand the differing needs of different groups of customers, so we can tailor our products and services accordingly.  For example, we would like to offer you content based on what we think similar customers are interested in.

 

How we obtain your personal information

We collect your personal information directly from you when you take out a newspaper, magazine, digital or app subscription. Sometimes we get your details from a friend, relative or your employer if your subscription has been purchased as a gift or on your behalf.  We also analyse how you interact with us, for example when you visit one of our websites or get in touch with a query.

We may obtain your personal information from third parties who process subscription offers, such as isubscribe or magazine.co.uk.

We also obtain some limited information from the app stores you have downloaded our app from. For example, order/purchase history including in app purchase details. We do not receive any payment card details; this is wholly held by the app stores.

Where we need your personal information to enter into or perform a contract with you then if you don’t provide it, we may not be able to process your subscription. For example, if you have requested a printed subscription but you don’t give us the delivery address, we won’t be able to send the newspaper or magazine.

Sharing your personal information with other organisations

As well as using your personal information across DC Thomson, we also share your personal information with other organisations:

  • Service providers: We may share your personal information with third-party service providers who perform services on our behalf or for your benefit, such as payment processors, credit referencing providers, providers who process our orders and/or deliver physical products, providers that host our technical infrastructure and those who assist us with hosting and/or delivering our marketing campaigns.
  • Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers.
  • Business transfers: Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed to an administrator or liquidator or other insolvency professional if we enter financial difficulties so that they can continue to run the business, transfer it to another organisation or wind it up.
  • HM Revenue and Customs, regulators and other authorities: We may share your personal information with HMRC and other regulators or authorities in the UK where required to do so by law.
  • ABC audit of circulation figures: We may share your personal data with a third-party auditing organisation (ABC) so they can verify aggregated statistics about circulation and usage of our products or review our policies, processes and procedures for compliance with relevant standards. You can view their privacy policy by following this link.

Where we pass your personal information to a third-party service provider, that service provider will usually be a processor, processing your personal information on our instructions. This privacy policy will continue to apply, because we will remain in control of your personal information and be responsible for looking after it.

In some cases, a service provider will be a data controller in their own right with their own privacy policy, which they will make available to you in accordance with their obligations under data protection law.

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If you visit one of our websites or register for an online account or app account (including ‘free’ accounts)

We process your personal information while you visit one of our websites or register for an online account or app account with us, as well as afterwards.  This includes collecting your personal information, recording it, storing it, using it, amending it, deleting it and in some circumstances sharing it.

The personal information we process about you and the purposes for which we use it are set out in the table below. We can only use your personal information when we have a good, lawful reason for doing so – our reasons are typically that:

  • we need to use your personal information so we can provide you with content, services, events, puzzles or games through our websites, your online account or your app account;
  • we have a good business justification to use your personal information, which we think is reasonable and treats you fairly (for example, we might record your calls to us for training and quality purposes, or use your information to contact you about a question you’ve asked or a comment you’ve added to our content). Under data protection law, this is referred to as a ‘legitimate interest’; or
  • we need to use your personal information so we can comply with a legal obligation (for example to update you about how we use your personal information under data protection laws).

Non-Registered guest players

This option allows you to play as an anonymous player and no personal data is retained by us. If the App is uninstalled, your profile is forgotten, along with any part completed or fully completed puzzle state of play. You will not be able to pick up account and state of play on any other device or new device.

Your purchase history is between you and the app stores and as such is protected via your app store(s) account.

 

Reason for processing your personal information Your personal information Legal ground(s) for processing Our legitimate interest (where applicable)
To register and operate your online account and/or app account Name

Email address

Home address

Phone number(s)

Title

Company/organisation name

Job title

Job function

Login details for your online account or app

If you register using Facebook, Google or Apple we will collect the information you’ve allowed them to share with us

Information shared through the app stores when you download or purchase an app

If you connect with our app using your social account and select to allow us to access your basic profile information etc we may access your basic public profile and friend list, including username, email (encrypted) and avatar.

Marketing preferences you’ve indicated to us

 Necessary to perform the contract between us
To provide and administer any content or features you’ve registered for (e.g. premium articles or the ability to save articles to read later)

To display your comments online

 Name

Email address

Home address

Phone number(s)

Title

Company/ organisation name

Job title

Login details for your online account or app

Personal interests you’ve indicated to us

Display name

Personal information included in your comments, for example, an indication of your political or religious beliefs

Details of your interactions with other users’ comments

 Necessary to perform the contract between us  
To moderate comments that you make on our website content Name

Email address

Login details for your online account or app

Display name

Personal information included in your comments, for example, an indication of your political or religious beliefs

Details of your interactions with other users’ comments

 Necessary for our legitimate interests

 

 To ensure that comments posted within our communities do not breach our community standards and to investigate any comments reported to us
Manage in-App game/puzzle play and provide the functions and features you have registered for including:

game status and rewards

saving your state of play and customise some elements

 

Access the app across multiple devices

 In App username for game/puzzle apps

Email address

Game/Puzzle Status

In-app progress, including time, streaks, game play history, rewards, completion rates, hints and puzzle token usage, spend, state of play etc.

Language setting

If you connect with our app using your social account and select to allow us to access your basic profile information etc we may access your basic public profile and friend list, including username, email (encrypted) and avatar.
To send you marketing communications with our suggestions and recommendations about goods and services that may be of interest to you

This includes:

when we provide you with personalised content and/or display tailored messaging to you when you visit our websites or use our apps; and

when we may show you our marketing (for example adverts) on other platforms such as Facebook

 Name

Email address

Home address

Phone number(s)

Title

Company/organisation name

Job title

Marketing preferences you’ve indicated to us

Personal interests you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)

Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information

Game/Puzzle Status

In-app progress, including time, streaks, game play history, rewards, completion rates, hints and puzzle token usage, spend, state of play etc.

Language setting

 Necessary for our legitimate interests

Consent

 To promote our products and services

To send direct marketing communications, make these more relevant to you where possible, and analyse the effectiveness of our campaigns

To remain engaged with you and to bring you additional benefits where possible
To manage our relationship with you including:

notifying you about changes to our terms or privacy policy;

asking you to leave a review, complete a survey or take part in research;

dealing with any queries, requests or issues you have, including those sent from within app; and

confirming when you have completed a particular activity (for example when you have entered one of our competitions)

 Name

Email address

Home address

Phone number(s)

Title

Company/organisation name

Job title

In App username for game/puzzle apps

 Necessary to perform the contract between us

To comply with a legal obligation (for example to tell you about a change to our terms that may significantly affect you)

Necessary for our legitimate interests

 To keep our records updated and to learn how our customers use our services

To provide a good level of customer service and deal promptly with your questions, comments or suggestions
To help us analyse and improve the technical functionality, security and performance of our websites and our apps I.P. address and other device identifiers

Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)

Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information

 Necessary for our legitimate interests To ensure our websites and apps operate to the high standards you expect
To help us improve the quality and variety of the content and features we provide through our websites, online accounts and apps I.P. address and other device identifiers

Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)

Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information

 Necessary for our legitimate interests To continuously improve our content and features, as well as develop new ideas that we think our customers will like
To help us build an understanding of our customers, whether as individuals or as larger groups, so we can identify customers who may have similar interests, preferences and characteristics Name

Email address

Home address

Phone number(s)

Title

Company/organisation name

Job title

Job function

Marketing preferences you’ve indicated to us

Personal interests you’ve indicated to us

I.P. address and other device identifiers, may include operating system and device type

Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)

Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information

Details of your interactions with other users’ comments

 Necessary for our legitimate interests To understand the differing needs of different groups of customers, so we can tailor our products and services accordingly.  For example, we would like to offer you content based on what we think similar customers are interested in.

 

How we obtain your personal information

We collect your personal information directly from you when you visit one of our websites register for an online account, register for an app account or play a puzzle or game within one of our apps. Where an organisation (such as your employer) has registered for an online account and you have been approved as a user of the account, we may collect your personal information from them. We also analyse how you interact with us, for example when you comment on an article or game/puzzle or get in touch with a query.

We may obtain your personal information from third parties you use to access our websites (e.g. Facebook), but only the limited information you allow them to share with us or you agree to us accessing via an app connection.

We also obtain some limited information from the app stores you have downloaded our app from. For example, order/purchase history including in app purchase details. We do not receive any payment card details; this is wholly held by the app stores.

Where we need your personal information to enter into or perform a contract with you then if you don’t provide it, we may not be able to provide the content or features you want. For example, if you don’t give us your email address, you won’t be able to register for an online account.

Sharing your personal information with other organisations

As well as using your personal information across DC Thomson, we also share your personal information with other organisations:

  • Service providers: We may share your personal information with third-party service providers who perform services on our behalf or for your benefit, such as providers of particular website or app features (e.g. the feature that enables you to comment on our newspaper articles), providers that host our technical infrastructure and those who assist us with hosting and/or delivering our marketing campaigns and advertising.
  • Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers.
  • Business transfers: Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed to an administrator or liquidator or other insolvency professional if we enter financial difficulties so that they can continue to run the business, transfer it to another organisation or wind it up.
  • HM Revenue and Customs, regulators and other authorities: We may share your personal information with HMRC and other regulators or authorities in the UK where required to do so by law.

Where we pass your personal information to a third-party service provider, that service provider will usually be a processor, processing your personal information on our instructions. This privacy policy will continue to apply, because we will remain in control of your personal information and be responsible for looking after it.

In some cases, a service provider will be a data controller in their own right with their own privacy policy, which they will make available to you in accordance with their obligations under data protection law.

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If you participate in one of our online communities or membership groups

We process your personal information when you use or register for an account on one of our online communities or membership groups, as well as afterwards. This includes collecting your personal information, recording it, storing it, using it, amending it, deleting it and in some circumstances sharing it.

The personal information we process about you and the purposes for which we use it are set out in the table below. We can only use your personal information when we have a good, lawful reason for doing so – our reasons are typically that:

  • we need to use your personal information so we can provide you with access to the online community or membership group through your account; or
  • we have a good business justification to use your personal information, which we think is reasonable and treats you fairly (for example, we might record your calls to us for training and quality purposes or use your information to contact you about a question you’ve asked). Under data protection law, this is referred to as a ‘legitimate interest’; or
  • we need to use your personal information so we can comply with a legal obligation (for example, to update you about how we use your personal information under data protection laws).

 

Reason for processing your personal information Your personal information Legal ground(s) for processing Our legitimate interest (where applicable)
To register and operate your online account Name

Date of birth

Email address

Home or delivery address

Company/organisation name

Job title

Job function

Login details for your online account

Display name

Subscription details

 Necessary to perform the contract between us  
To provide and administer any content or features you’ve registered for (e.g. premium content or articles)

To display your comments online

 Name

Date of birth

Home address

Email address

Phone number(s)

Title

Login details for your online account

Personal information included in your comments, for example, an indication of political or religious beliefs

Details of interactions with other users’ comments

 Necessary to perform the contract between us  
To moderate comments that you make on our online communities. Display name

Email address

Login details for your online account

Personal information included in your comments, for example, an indication of political or religious beliefs

Details of interactions with other users’ comments

 Necessary for our legitimate interests

 

 To ensure that comments posted within our communities do not breach our community standards and to investigate any comments reported to us
To process your subscription payment and collect and recover money owed to us Name

Email address

Billing address

Bank account and payment card details

Subscription details

 Necessary to perform the contract between us

Necessary for our legitimate interests

 To recover debts owed to us
To send you marketing communications with our suggestions and recommendations about goods and services that may be of interest to you.

This includes:

when provide you with personalised content and/or display tailored messaging to you when you visit our websites; and

when we may show you our marketing (for example adverts) on other platforms such as Facebook.

 Name

Email address

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests

Consent

 To promote our products and services

To send direct marketing communications, make these more relevant to you where possible, and analyse the effectiveness of our campaigns

To remain engaged with individuals and to bring them additional benefits where possible
To manage our relationship with you including:

notifying you about changes to our terms or privacy policy;

asking you to leave a review, complete a survey or take part in research;

dealing with any queries, requests or issues you have; and

confirming when you have completed a particular activity (for example when you have changed personal details associated with your online account)

 Name

Email address

Phone number(s)

Display name

Login details for your online account

Marketing preferences you’ve indicated to us

Payment information

 Necessary to perform the contract between us

To comply with a legal obligation (for example to tell you about a change to our terms that may significantly affect you)

Necessary for our legitimate interests

 To keep our records updated and to learn how our customers use our services

To provide a good level of customer service and deal promptly with your questions, comments or suggestions
To help us analyse and improve the technical functionality, security and performance of our websites I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests We have an interest in ensuring our websites operate to the high standards you expect.
To help us improve the quality and variety of the content and features we provide through our online communities and membership groups I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To continuously improve our content and features, as well as develop new ideas that we think our customers will like
To help us build an understanding of our customers, whether as individuals or as larger groups, so we can identify customers who may have similar interests, preferences and characteristics Name

Date of birth

Email address

Home or delivery address

Company/organisation name

Job title

Job function

Billing address

Bank account and payment card details

Subscription details

Details of interactions with other users’ comments

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To understand the differing needs of different groups of customers, so we can tailor our products and services accordingly.  For example, we would like to offer you content based on what we think similar customers are interested in.

 

How we obtain your personal information

We collect your personal information directly from you when you register for an account on our online community. Where an organisation (such as your employer) has registered for an online account and you have been approved as a user of the account, we may collect your personal information from them.

We may also collect personal information that you include in comments you make online.  We also analyse how you interact with us, for example when you visit one of our websites or contact us about something and how you interact with other users in the online community.

We may obtain your personal information from third parties you use to access our websites (e.g. Facebook), but only the limited information you allow them to share with us.

Where we need your personal information to enter into or perform a contract with you then if you don’t provide it, we may not be able to facilitate your membership. For example, if you don’t give us your email address, you wont be able to register for an account on one of our online communities or membership groups.

Sharing your personal information with other organisations

As well as using your personal information across DC Thomson, we also share your personal information with other organisations:

  • Service providers: We may share your personal information with third-party service providers who perform services on our behalf or for your benefit, such as a service provider of a customer relationship management tool, providers that host our technical infrastructure and those who assist us with hosting and/or delivering our marketing campaigns.
  • Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers.
  • Business transfers: Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed to an administrator or liquidator or other insolvency professional if we enter financial difficulties so that they can continue to run the business, transfer it to another organisation or wind it up.
  • HM Revenue and Customs, regulators and other authorities: We may share your personal information with HMRC and other regulators or authorities in the UK where required to do so by law.

Where we pass your personal information to a third-party service provider, that service provider will usually be a processor, processing your personal information on our instructions. This privacy policy will continue to apply, because we will remain in control of your personal information and be responsible for looking after it.

In some cases, a service provider will be a data controller in their own right with their own privacy policy, which they will make available to you in accordance with their obligations under data protection law.

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If you listen to one of our radio stations

We process your personal information when you listen to our radio stations online, register for an online account, contact us or make a purchase, as well as afterwards. This includes collecting your personal information, recording it, storing it, using it, amending it, deleting it and in some circumstances sharing it.

The personal information we process about you and the purposes for which we use it are set out in the table below. We can only use your personal information when we have a good, lawful reason for doing so – our reasons are typically that:

  • we need to use your personal information so we can provide you with content through our websites or your online account;
  • we have a good business justification to use your personal information, which we think is reasonable and treats you fairly (for example, to manage our interaction with you as a listener, or to record your calls to us for training and monitoring purposes). Under data protection law, this is referred to as a ‘legitimate interest’; or
  • we need to use your personal information so we can comply with a legal obligation (for example, should a regulator ask us to contact our audience).

 

Reason for processing your personal information Your personal information Legal ground(s) for processing Our legitimate interest (where applicable)
To register and operate your online account Name

Email address

Home address

Phone number(s)

Date of birth

Gender

Employment status

Login details for your online account

Listening preferences you’ve indicated to us

Marketing preferences you’ve indicated to us

 Necessary to perform the contract between us
To facilitate your entry into a competition we’re running

To provide you with your competition prize if you’re successful

 Name

Date of birth

Home address

Email address

Phone number(s)

Login details for your online account

Reasons for you taking part in the competition (if provided), including your competition entry

 Necessary to perform the contract between us

Consent where the particular competition requires it
To enable you or someone you nominate to take part in our radio shows or features (for example, phone-ins, interviews or pranks) Name

Email address

Phone number(s)

Details of the person you’ve nominated

Reasons for you and/or the person you’ve nominated taking part in the show or feature

Additional personal information we may request from you that is relevant to your taking part in the show or feature

 Necessary to perform the contract between us

Consent where the particular show or feature requires it
To send you marketing communications with our suggestions and recommendations about goods and services that may be of interest to you

This includes:

When we provide you with personalised content and/or display tailored messaging to you when you visit our websites; and

when we may show you our marketing (for example adverts) on other platforms such as Facebook

 Name

Email address

Home address

Phone number(s)

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests

Consent

 To promote our products and services

To send direct marketing communications, make these more relevant to you where possible, and analyse the effectiveness of our campaigns

To remain engaged with you and to bring you additional benefits where possible
To process your order including sending you (or the nominated recipient) the item you’ve purchased Name

Email address

Home address

Phone number(s)

Purchase details and order history

Nominated recipient details

Gift message (if applicable)

 Necessary to perform the contract between us
To process your payments and collect and recover money owed to us Name

Email address

Billing address

Bank account and payment card details

If you use a payment service (for example PayPal) we collect the limited information they share relevant to the transaction

Purchase details and order history

 Necessary to perform the contract between us

Necessary for our legitimate interests

 To recover debts owed to us

To provide you with order documentation such as order confirmation
To manage our relationship with you including:

notifying you about changes to our terms or privacy policy;

asking you to leave a review, complete a survey or take part in research;

dealing with any queries, requests or issues you have; and

confirming when you have completed a particular activity (for example when you have changed personal details associated with your online account)

 Name

Email address

Home address

Phone number(s)

Purchase details and order history

Login details for your online account

Marketing preferences you’ve indicated to us

 Necessary to perform the contract between us

To comply with a legal obligation (for example to tell you about a change to our terms that may significantly affect you)

Necessary for our legitimate interests

 To keep our records updated and to learn how our listeners use our services

To provide a good level of customer service and deal promptly with your questions, comments or suggestions
To help us analyse and improve the technical functionality, security and performance of our websites I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To ensure our websites operate to the high standards you expect
To help us improve the quality and variety of the content and features we provide through our websites and online accounts I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To continuously improve our content and features, as well as develop new ideas that we think our listeners will like
To help us build an understanding of our listeners, whether as individuals or as larger groups, so we can identify listeners who may have similar interests, preferences and characteristics Name

Email address

Home address

Phone number(s)

Date of birth

Gender

Employment status

Purchase details and order history

Login details for your online account

Listening preferences you’ve indicated to us

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To understand the differing needs of different groups of listeners, so we can tailor our products and services accordingly.  For example, we would like to offer you content based on what we think similar listeners are interested in.

 

How we obtain your personal information

We collect your personal information directly from you when you contact us, make a purchase and/or register for an online account. Sometimes we get your details from a friend or relative if they’ve nominated you to take part in a feature we’re running or placed a request for you. We also analyse how you interact with us, for example when you visit one of our websites or contact us about something.

We may obtain your personal information from third parties who have referred you to us and who have your consent to transfer your personal data to us.

Where we need your personal information to enter into or perform a contract with you then if you don’t provide it, we won’t be able to process your order or register your account. For example, if you don’t give us a delivery address if you win a physical competition prize, we won’t be able to deliver the prize.

Sharing your personal information with other organisations

As well as using your personal information across DC Thomson, we also share your personal information with other organisations:

  • Service providers: We may share your personal information with third-party service providers who perform services on our behalf or for your benefit, such as payment processors, credit referencing providers, third party sales processor (includes fulfilment services), service providers that host our technical infrastructure and those who assist us with hosting and/or delivering our marketing campaigns.
  • Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers.
  • Business transfers: Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed to an administrator or liquidator or other insolvency professional if we enter financial difficulties so that they can continue to run the business, transfer it to another organisation or wind it up.
  • HM Revenue and Customs, regulators and other authorities: We may share your personal information with HMRC and other regulators or authorities in the UK where required to do so by law.
  • Providers of competition prizes: Where you’re the winner of a competition prize, we may share your personal details with the provider of the prize to allow delivery, or where you have specifically agreed that we can do so.

Where we pass your personal information to a third-party service provider, that service provider will usually be a processor, processing your personal information on our instructions. This privacy policy will continue to apply, because we will remain in control of your personal information and be responsible for looking after it.

In some cases, a service provider will be a data controller in their own right with their own privacy policy, which they will make available to you in accordance with their obligations under data protection law.

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If you participate in one of our competitions

We process your personal information when you participate in one of our competitions (whether in one of our publications or online), as well as afterwards.  This includes collecting your personal information, recording it, storing it, using it, amending it, deleting it and in some circumstances sharing it.

The personal information we process about you and the purposes for which we use it are set out in the table below. We can only use your personal information when we have a good, lawful reason for doing so – our reasons are typically that:

  • we need to use your personal information so we can facilitate the competition and provide prizes; or
  • we have a good business justification to use your personal information, which we think is reasonable and treats you fairly (for example, we might record your calls to us for training and quality purposes). Under data protection law, this is referred to as a ‘legitimate interest’; or
  • we need to use your personal information so we can comply with a legal obligation (for example, an obligation to notify you of a product recall)

 

Reason for processing your personal information Your personal information Legal ground(s) for processing Our legitimate interest (where applicable)
To facilitate your entry into a competition we’re running

To provide you with your competition prize if you’re successful

 Name

Date of birth

Home address

Email address

Phone number(s)

Login details for your online account

Reasons for you taking part in the competition (if provided), including your competition entry

 Necessary to perform the contract between us

Consent where the particular competition requires it
To send you marketing communications with our suggestions and recommendations about goods and services that may be of interest to you

This includes:

when we provide you with personalised content and/or display tailored messaging to you when you visit our websites; and

when we may show you our marketing (for example adverts) on other platforms such as Facebook

 Name

Email address

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests

Consent

 To promote our products and services

To send direct marketing communications, make these more relevant to you where possible, and analyse the effectiveness of our campaigns

To remain engaged with you and to bring you additional benefits where possible
To manage our relationship with you including:

notifying you about changes to our terms or privacy policy;

asking you to leave a review, complete a survey or take part in research;

dealing with any queries, requests or issues you have; and

confirming when you have completed a particular activity (for example when your competition entry has been submitted)

 Name

Email address

Display name

Login details for your online account

Marketing preferences you’ve indicated to us

 Necessary to perform the contract between us

To comply with a legal obligation (for example to tell you about a change to our terms that may significantly affect you)

Necessary for our legitimate interests

 To keep our records updated and to learn how our customers use our services

To provide a good level of customer service and dealing promptly with your questions, comments or suggestions
To help us analyse and improve the technical functionality, security and performance of our websites

 

 I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To ensure our websites operate to the high standards you expect
To help us improve the quality and variety of the content and features we provide through our publications and websites I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To continuously improve our content and features, as well as develop new ideas that we think our customers will like
To help us build an understanding of our customers, whether as individuals or as larger groups, so we can identify customers who may have similar interests, preferences and characteristics Name

Date of birth

Home address

Email address

Phone number(s)

Reasons for you taking part in the competition (if provided), including your competition entry

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To understand the differing needs of different groups of customers, so we can tailor our products and services accordingly.  For example, we would like to offer you content based on what we think similar customers are interested in

 

How we obtain your personal information

We collect your personal information directly from you when you enter a competition.  Sometimes we get your details from a friend or relative if they have submitted an entry on your behalf.  We also analyse how you interact with us, for example when you visit one of our websites or contact us about something.

Where we need your personal information to enter into or perform a contract with you then if you don’t provide it, we may not be able to facilitate your entry to a competition. For example, if you don’t give us a contact email address or phone number, we won’t be able to contact you if you’re a competition winner.

Sharing your personal information with other organisations

As well as using your personal information across DC Thomson, we also share your personal information with other organisations:

  • Service providers: We may share your personal information with third-party service providers who perform services on our behalf or for your benefit, such as third parties who provide a prize for a competition (to allow delivery), providers that host our technical infrastructure and those that assist us with hosting and/or delivering our marketing campaigns.
  • Third-party brands: Where you have consented to us doing so, we may share your personal information with a third-party brand in order for them to send you marketing communications about goods or services that you might be interested in.
  • Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers.
  • Business transfers: Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed to an administrator or liquidator or other insolvency professional if we enter financial difficulties so that they can continue to run the business, transfer it to another organisation or wind it up.
  • Advertising Standards Agency (ASA), regulators and other authorities: We may share your personal information with the ASA and other regulators or authorities in the UK where required to do so by law.

Where we pass your personal information to a third-party service provider, that service provider will usually be a processor, processing your personal information on our instructions. This privacy policy will continue to apply, because we will remain in control of your personal information and be responsible for looking after it.

In some cases, a service provider will be a data controller in their own right with their own privacy policy, which they will make available to you in accordance with their obligations under data protection law.

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If you sign up for one of our events

We process your personal information when you sign up to attend an event, as well as afterwards. This includes collecting your personal information, recording it, storing it, using it, amending it, deleting it and in some circumstances sharing it.

The personal information we process about you and the purposes for which we use it are set out in the table below. We can only use your personal information when we have a good, lawful reason for doing so – our reasons are typically that:

  • we need to use your personal information so we can deliver the event;
  • we have a good business justification to use your personal information, which we think is reasonable and treats you fairly (for example, we might record your calls to us for training and quality purposes). Under data protection law, this is referred to as a ‘legitimate interest’; or
  • we need to use your personal information so we can comply with a legal obligation (for example, to contact you to advise you of a change to the event venue due to health and safety regulations).

 

Reason for processing your personal information Your personal information Legal ground(s) for processing Our legitimate interest (where applicable)
To facilitate your event booking and to send you a copy of your ticket and event information either by post or email Name

Email address

Home or delivery address

Phone number(s)

Company/organisation name

Job title

 Necessary to perform the contract between us

 

  
To organise and deliver the event and to cater for all our event guests Name

Date of birth

Dietary requirements including allergy information

Special access requirements

Emergency contact details

Additional details of your company/ organisation, where needed for the specific event

 Necessary to perform the contract between us  
To process your payments (including recurring payments) and collect and recover money owed to us Name

Email address

Billing address

Phone number(s)

Bank account or payment card details

Purchase details

VAT number

Company/ organisation name

 Necessary to perform the contract between us

Necessary for our legitimate interests

Legal obligation (for example provision of an invoice for VAT registered businesses, or to provide confirmation/receipt of payment)

 To recover debts owed to us

To provide you with order documentation such as order confirmation

 
To send you marketing communications with our suggestions and recommendations about events that may be of interest to you Name

Email address

Purchase details

Marketing preferences you’ve indicated to us

 Necessary for our legitimate interests

Consent

 To promote our products and services

To send direct marketing communications, make these more relevant to you where possible, and analyse the effectiveness of our campaigns
To manage our relationship with you including:

notifying you about changes to our terms or privacy policy;

asking you to leave a review, complete a survey or take part in research;

dealing with any queries, requests or issues you have; and

confirming when you have completed a particular activity (for example when you have changed personal details associated with your event booking)

 Name

Email address

Home or delivery address

Phone number(s)

Purchase details

Marketing preferences you’ve indicated to us

Payment information

 Necessary to perform the contract between us

To comply with a legal obligation (for example to tell you about a change to our terms that may significantly affect you)

Necessary for our legitimate interests

 To keep our records updated and to learn how our customers use our services

To provide a good level of customer service and deal promptly with your questions, comments or suggestions
To help us analyse and improve the technical functionality, security and performance of our websites I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To ensure our websites operate to the high standards you expect
To help us improve the quality and variety of the content and features we provide through our websites I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To continuously improve our content and features, as well as developing new ideas that we think our customers will like
To help us build an understanding of our customers, whether as individuals or as larger groups, so we can identify customers who may have similar interests, preferences and characteristics Name

Date of birth

Email address

Home or delivery address

Phone number(s)

Company/organisation name

Job title

Purchase details

Marketing preferences you’ve indicated to us

I.P. address and other device identifiers

Information you provide when you visit our websites (e.g. a record of the pages you visit) and other services you may use to access our websites (e.g. Facebook)

 Necessary for our legitimate interests To understand the differing needs of different groups of customers, so we can tailor our products and services accordingly.  For example, we would like to offer you content based on what we think similar customers are interested in.

 

How we obtain your personal information

We collect your personal information directly from you when you book an event. Sometimes we get your details from a friend, relative, your employer or another third party if someone else is making a booking for the event on your behalf.  We also analyse how you interact with us, for example when you visit one of our websites or get in touch with a query.

Where we need your personal information to enter into or perform a contract with you, then if you don’t provide it, we may not be able to process your event booking. For example, if you don’t provide us with an email address, we will not be able to send an e-ticket for the event to you.

Sharing your personal information with other organisations

As well as using your personal information across DC Thomson, we also share your personal information with other organisations:

  • Service providers: We may share your personal information with third-party service providers who perform services on our behalf or for your benefit, such as payment processors, providers of card validation services, third party ticket sales processors and those service providers who assist us with hosting our events (for example, the venue and catering team).
  • Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers.
  • Business transfers: Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed to an administrator or liquidator or other insolvency professional if we enter financial difficulties so that they can continue to run the business, transfer it to another organisation or wind it up.
  • HM Revenue and Customs, regulators and other authorities: We may share your personal information with HMRC and other regulators or authorities in the UK where required to do so by law.

Where we pass your personal information to a third-party service provider, that service provider will usually be a processor, processing your personal information on our instructions. This privacy policy will continue to apply, because we will remain in control of your personal information and be responsible for looking after it.

In some cases, a service provider will be a data controller in their own right with their own privacy policy, which they will make available to you in accordance with their obligations under data protection law.

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If you place an advert or notice in one of our publications

We process your personal information when you place a notice with us (such as a birth, death or marriage announcement) or pay us to advertise for you across any of our publications, websites or radio stations, as well as afterwards.  This includes collecting your personal information, recording it, storing it, using it, amending it, deleting it and in some circumstances sharing it.

The personal information we process about you and the purposes for which we use it are set out in the table below. We can only use your personal information when we have a good, lawful reason for doing so – our reasons are typically that:

  • we need to use your personal information so we can provide the notice or advertising you have requested;
  • we have a good business justification to use your personal information, which we think is reasonable and treats you fairly (for example, if you represent a business customer that has previously advertised with us, we may contact you to ask if you would like to re-advertise). Under data protection law, this is referred to as a ‘legitimate interest’; or
  • we need to use your personal information so we can comply with a legal obligation (for example, to update you about how we use your personal information under data protection laws.

 

Reason for processing your personal information Your personal information Legal ground(s) for processing Our legitimate interest (where applicable)
To discuss, design and agree your notice or advertisement Name

Email address

Home or business address

Billing address

Phone number(s)

Title

Company/ organisation name

Job title

 Necessary to perform the contract between us
To process your payments (including recurring payments) and collect and recover money owed to us Name

Email address

Billing address

Phone number(s)

Bank account or payment card details

Company/ organisation name

Job title

VAT number

 Necessary to perform the contract between us

Necessary for our legitimate interests

Legal obligation (for example provision of an invoice for VAT registered businesses, or to provide confirmation/receipt of payment)

 To recover debts owed to us

To provide you with order documentation such as order confirmation

 

 
To manage our relationship with you including:

notifying you about changes to our terms or privacy policy;

contacting you about your notice or advertisement (e.g. to update you about how an advertising campaign is performing);

inviting you to place another notice (e.g. on the anniversary of an event) or to re-advertise; and

dealing with any queries, requests or issues you have

 Name

Email address

Home or business address

Phone number(s)

Title

Company/ organisation name

Job title

Marketing preferences you’ve indicated to us

Purchase details and order history

 Necessary to perform the contract between us

To comply with a legal obligation (for example to tell you about a change to our terms that may significantly affect you)

Necessary for our legitimate interests

 To keep our records updated and to learn how our customers use our services

To provide a good level of customer service and deal promptly with your questions, comments or requests
To help us improve the quality and variety of the services we provide Home or business address

Company/ organisation name

Job title

Purchase details and order history

 Necessary for our legitimate interests To continuously improve our services, as well as develop new ideas that we think our customers will like
To help us build an understanding of our customers, whether as individuals or as larger groups, so we can identify customers who may have similar interests, preferences and characteristics Name

Email address

Home or business address

Billing address

Phone number(s)

Title

Company/ organisation name

Job title

Marketing preferences you’ve indicated to us

Purchase details and order history

 Necessary for our legitimate interests To understand the differing needs of different groups of customers, so we can tailor our products and services accordingly.  For example, we would like to offer you advertising options based on what we think similar customers are interested in.

 

How we obtain your personal information

We collect your personal information directly from you when you contact us with an enquiry, to place a notice or to buy advertising.

Where we need your personal information to enter into or perform a contract with you then if you don’t provide it, we may not be able to provide the services you want. For example, if you don’t give us your email address, we will not be able to send you information about how your advertisement is performing.

Sharing your personal information with other organisations

As well as using your personal information across DC Thomson, we also share your personal information with other organisations:

  • Service providers: We may share your personal information with third-party service providers who perform services on our behalf or for your benefit, such as payment processors, providers that host our technical infrastructure and those who assist us with hosting and/or delivering your advertising campaigns.
  • Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers.
  • Business transfers: Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed to an administrator or liquidator or other insolvency professional if we enter financial difficulties so that they can continue to run the business, transfer it to another organisation or wind it up.
  • HM Revenue and Customs, regulators and other authorities: We may share your personal information with HMRC and other regulators or authorities in the UK where required to do so by law.

Where we pass your personal information to a third-party service provider, that service provider will usually be a processor, processing your personal information on our instructions. This privacy policy will continue to apply, because we will remain in control of your personal information and be responsible for looking after it.

In some cases, a service provider will be a data controller in their own right with their own privacy policy, which they will make available to you in accordance with their obligations under data protection law.

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Sharing your personal information within DC Thomson

However you interact with us, we use your personal information across our companies, brands and departments in order to:

  • provide you with the products or services that you’ve requested
  • develop new products or services and improve our existing ones
  • help us to better understand our relationship with you, your preferences and the different parts of DC Thomson that you interact with
  • anticipate what products and services you and other customers might be interested in
  • ensure that your personal information is accurate and up to date

We won’t send you marketing from other DC Thomson companies or brands unless you’ve indicated that you are happy to receive it.

How long we keep your personal information

We only keep your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may keep it for a longer period in the event of a complaint or if we reasonably believe there’s a prospect of litigation in respect to our relationship with you.

If you’d like more information on how long we keep your personal information, please contact us – see the ‘How to contact us’ section below.

Your marketing preferences

You can change your marketing preferences at any time and how you do this will depend on how you interact with us (for example, whether you subscribe to one of our newspapers or have bought something from one of our online shops).

You can opt out of marketing whenever you wish, but please note this won’t affect any service messages that we need to send you in relation to any products or services you purchase or events you attend. For example, we’ll still send you communications with information about an event that you’ve registered to attend or to tell you about a change in the price of your magazine subscription.

We won’t share your personal information with anyone else for marketing purposes unless you’ve told us you agree to that.

Sending your personal information outside of the UK

We may transfer your personal information within DC Thomson and/or to third parties – see Sharing your personal information with third parties – which may involve your personal information being transferred to, stored, or processed in a country other than the one in which it was collected.

If we do so, we’ll comply with applicable law regarding such transfers. Where such transfers require appropriate or suitable safeguards recognised under privacy laws, we may rely on them. Typically, these may include:

  • Adequacy decision: We may transfer your personal information to countries which the Information Commissioner’s Office has approved as providing adequate protection to personal information (for example, the European Economic Area).
  • Approved contracts: We may be entitled to put in place a contract with the recipient of your information which requires them to protect that information to the same standards as if the information were being processed within the country where it was collected.
  • With your consent: In respect of certain transfers, we’ll obtain your consent to transfer your personal information outside the UK after first informing you about the possible risks of such a transfer

The safeguards we use will depend on where the recipient of the personal information is based, what they are doing, and the personal information being transferred.

You can request more information by contacting us.

Your rights

Under data protection law, you have the following rights:

  • A right to receive a copy of the personal information we hold about you and information about how we use it
  • The right to update any of the personal information we hold about you if it is no longer correct
  • The right to require us to delete or remove your personal information
  • The right to require us to stop processing some of your personal information for a particular reason
  • The right to withdraw any consent you have provided
  • The right, in certain circumstances, to require us to transfer your personal information to another company

These rights are qualified. This means that depending on what you ask us to do, we may not be able to comply with your request. If that is the case, we’ll explain why.

Before we can act, we may also ask you to confirm your identity so we can be sure we’re speaking to the right person. We won’t usually ask you to pay any money to exercise any of these rights, but we’ll tell you at the time if a fee will apply.

How to contact us

If you want to exercise any of your rights, change any of your choices about how we use your personal information or just ask us a question, please email us at privacy@dcthomson.co.uk.

If you’re unhappy about how we’ve handled your personal information, you can make a complaint to the Information Commissioner’s Office. Information on how to do this is available at www.ico.org.uk/make-a-complaint but we would appreciate the chance to deal with your concerns first.

Updates to this notice

We keep this policy under regular review to make sure it is still accurate. This policy was last updated on 26 August 2024