Privacy Policy | Harrogate Informer

Harrogate Informer Privacy Notice

Who are we?

The Harrogate Informer is a trading name of Timothy Cook Media, a sole trader located at 13 Yewdale Road, Harrogate, North Yorkshire HG2 8NF

Background

The term “you” or “your” refers to the user or viewer of the Website.

This privacy notice (the “Privacy Notice”) will inform you as to how we look after your personal data (“Personal Data”) when you visit the website and any related or linked documents (the “Website”). It is important that you read this Privacy Notice carefully, along with any other privacy notices or policies we may provide on specific occasions when we are collecting or processing personal data so that you are fully aware of how and why we are using the data. We keep our Privacy Notice under regular review. This version was last updated on the date given at the foot of this page. This Privacy Notice supplements any other privacy notice or fair processing notice we may provide to you and is not intended to override them. Please revisit this page of the Website periodically to make sure that you have read the most recent version. Where we make substantive changes to this Privacy Notice and how we process your Personal Data, we will notify you of those changes.

References to data protection laws include the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018 (DPA 2018) and The Privacy and Electronic Communications (EC Directive) Regulations 2003 (PERC).

What is personal data?

Personal Data is any data or information from which an individual can be identified. It does not include data where the individual’s identity has been removed (anonymous data). The Website is not directed at children under 16, and we do not knowingly collect, use or disclose Personal Data from anyone under the age of 16. If we become aware that we have unknowingly collected Personal Data from a child under the age of 16, we will make reasonable efforts to delete such data from our records. Please read our Privacy Notice carefully before using, or submitting information to, the Website.

Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how we collect and process your Personal Data through your use of the Website, including any data you may provide through the Website. It is also intended to inform you about the choices you have regarding our use of, and your ability to correct, that Personal Data.

If you have any questions or concerns regarding this privacy notice, please contact us by email at: tim@timothycook.co.uk

Information we collect about you

We may collect, use, store and transfer different kinds of Personal Data about you, which may include:

Your name, title, date of birth and gender (“Identity Data”).
Your address, email address and telephone number i.e. personal information which you knowingly give us through the email alert subscription (“Contact Data”).
Your bank account (“Financial Data”).
Details about any investments you have made in us (“Investment Data”).
Your IP address, login data, browser type and version, and operating system and platform (“Technical Data”).
Information about how you use our Website (“Profile/Usage Data”).
Details of your marketing communication preferences from us and our third parties.

We may also collect, use and share aggregated data (“Aggregated Data”) such as statistical or demographic data. Aggregated Data may be derived from your Personal Data. For example, we may use this data to determine how our users engage with the Website or access specific features.

Unless contained in public notices lawfully submitted to us for publication or you have chosen to provide that type of personal data to us, we do not collect any sensitive personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), or any information about criminal convictions and offences.

Your duty to inform us of changes

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed of any changes to your Personal Data during your relationship with us.

If you fail to provide us Personal Data

Where we need to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may cancel a product or service you have with us and notify you of such cancellation.

How your Personal Data is collected

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

Direct Interactions. You may give us your Identity Data, Contact Data and Financial Data by completing forms on the Website, or by corresponding with us by email, phone or post. This includes Personal Data you provide when you:

interact with the Website;
correspond with us;
request marketing communications; and
engage with us on social media.

Automated technologies. As you interact with the Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies – a small piece of information sent from the Website and stored in the web browser of your computer and/or device – and other similar technologies. Each time you load the Website, the browser sends the cookie back to the server to notify the Website of your previous activity. You may refuse the use of cookies by selecting the appropriate settings in your browser. However, if you do this you may lose some useful functionality and some parts of the Website may not function properly.

Third Parties. We may receive Personal Data about you from various third parties and public sources as set out below:

Analytics providers who provide us with Aggregated Data, Technical Data and Usage Data.
Service providers who may provide us with Identity Data, Contact Data and Payment Data.

How do we use your Personal Data and the lawful basis for our use?

The table below sets our the Personal Data we typically process, the reason why we collect this information, our lawful basis for doing so and the applicable retention periods.

INFORMATION	WHY WE COLLECT IT	LAWFUL BASIS	RETENTION PERIOD
Information you provide to us when you contact us: this may include your name, address, contact details and any other personal information which you choose to provide to us (or which we otherwise obtain as part of that process (such as an IP address)).	Enquiries: If you contact us to enquire about any aspect of our business, goods or services, we will collect your personal information in order to respond to your query and we may also use your information where there is another legitimate reason for us to do so.	On the basis of our and your legitimate interests. Our interests being that we would like to assist you with any queries you may have and inform you about our goods and services.	We will retain this information for no longer than necessary for the uses set out in this Privacy Notice, or while there is a legitimate interest for us doing so. If during our correspondence with you, you enter a contract with us or consent to direct marketing, please see the relevant section of this table for details as to how we will use your personal information.
	Call recordings: When you engage with us via phone or video call, we may record the conversation in order to allow us to maintain a record of our conversation which we can return to if we need to check any of the queries which we are to respond to you on, for the purposes of training and improving our services, and for security. You will be notified at the beginning of the call if it is being recorded.	On the basis of our and your legitimate interests. Our interests being that we wish to improve our services and ensure we respond fully to your queries.	We will retain this information for no longer than necessary for the uses set out in this Privacy Notice, or while there is a legitimate interest for us doing so.
	Recruitment: If you contact us in relation to applying for a job with us, we will collect your personal information in order to assess whether you are suitable for the position you applied for.	On the basis of our and your legitimate interests. Our interests being that we would like to consider you for the position you applied for.	If your application is unsuccessful, we will delete this information within 12 months of receiving your application. If your application is successful, we will issue you with a further privacy notice in relation to the retention and use of your personal information.
Information you provide to us when you enter a contract for our goods or services, for example, subscribing to one of our newspapers, signing up to one of our events: this may include: (a) your name, (b) address, (c) contact details, (d) payment information, (e) the details of the event (if relevant), (f) where and how you signed up for it, and (g) your dietary requirements.	Entering a contract: If you enter a contract with us to provide you with any of our goods or services, we will collect your personal information to enable us to provide those goods or services to you (for example to receive payment for the services or to contact you in relation to the event you are attending) and we may also use your information where there is a legitimate reason for us to do so.	(i) On the basis that this is necessary to fulfil our contractual obligations to you; and (ii) On the basis of your and our legitimate interests. Our interests being that we would like to assist you with any queries you may have and inform you about our goods and services.	We will retain this information for the duration of our contract with you. Once our contract has ended we will retain your personal information for up to six years in accordance with relevant legal and accounting requirements. Where you have signed up to one of our events, we will retain your contact details for a period of two years thereafter. We do this on the basis of it being in our and your legitimate interests to notify you of events which you may wish to attend, or to inform you about our goods and services. If we do not hear from you during this period, we will delete your personal information.
	Dietary requirements: If you are attending one of our events, we may ask you about your dietary requirements in order for us to provide you with suitable catering. This information could contain special category data, for example, it could relate to your religion.	We will only collect and process this information on the basis of your consent.	We will delete this information within one month of the event being held.
Information provided to us for marketing purposes by third parties: this may include your name and contact details.	118 Data Resource Limited: We have a contract with 118 Data Resource Limited under which it provides us with the contact details of individuals who have indicated that they consent to us contacting them. If we receive your personal information in this manner, we will contact you to ask you for consent to send you further communications (including marketing and other communications).	We collect this information on the basis that you have provided 118 Data Resource Limited with your consent for us to do so.	We will retain this information until we have contacted you to ask you for consent to send further marketing communications and for up to a maximum of one month. If you do not provide your consent, we will delete your personal information. Where you no longer wish to hear from us, we will retain a minimal amount of your personal information on a “suppression list” to ensure we do not contact you again. If you do provide us with consent, please see below in relation to our use of personal information for the purposes of direct marketing.
Information you provide to us when you post information on our websites: this may include your name, contact details and gender.	Forums: Where our websites allow you to post on the website, for example via comments sections, we will collect any personal information which you submit via this function. We offer these functions to allow you to engage with our websites and services.	On the basis of our and your legitimate interests. Our interests being that we wish to improve our services and allow you to interact and engage with our websites and services.	Where you post information or comments to a website, this information will be displayed until we remove the relevant article or webpage where you have posted the information or until you delete it or contact us to ask us to delete it. Use of our website is subject to separate terms which can be accessed from any of those sites.
Information that we collect about you when you sign up to our newsletters or direct marketing services: this may include your name and contact details.	Newsletters / marketing communications: Where you sign up to our newsletters or other direct marketing communications, we will collect your personal information in order to be able to send you these newsletters or communications, or where there is another legitimate reason for contacting you.	We will only collect this information and contact you in this way when you have provided your consent for us to do so. We will thereafter contact you on the basis of your and our legitimate interests. Our interests being that we would like to inform you about our goods and services. You may withdraw your consent to this type of communication at any time by contacting us or clicking on the unsubscribe button where relevant.	We will check whether you wish to continue receiving communications of this nature at least every 12 months. If you respond to opt out, we will delete your information within 1 month of your response. If you do not respond, we will contact you again within two weeks after our first communication to check whether you wish to opt out. If we still do not receive a response, we will delete your personal information within one month of this second attempt to contact you. Where you no longer wish to hear from us, we will retain a minimal amount of your personal information on a “suppression list” to ensure we do not contact you again.
Information that we collect about you by way of cookies. This includes your IP address, browser type and operating system.	Cookies: We collect this information in order to improve your experience of using our website and to enable us to assess how our websites are used to ensure our services and advertisements are relevant. For further information in relation to cookies, please see the cookies information tool displayed in the footer of each of our websites which you visit. Social Media: We publish content on Social Media platforms. We may place one or more social media platform “tags” on our websites in order to better understand how we may be of best value to you by providing you with the most relevant content available according to what you have chosen to read on our own websites. These tags only record information around activities to help us understand if you are registered or subscribed with us, or visit our websites so that we may use your reading preferences to provide more relevant content and/or offers to you, on social media platforms, e.g. removing subscription offers from your feed if you are a current subscriber. We do not have direct access to your personal data on your social media platforms.	Other than cookies which are strictly necessary for the functioning of our website, we will use cookies only on the basis of your prior consent. Please see our cookies information tool which is displayed in the footer of each of our websites to review the types of cookies which you have consented to. On the basis of our and your legitimate interests. Our interests being that we wish to improve our services and allow you to interact and engage with our websites and services. We will use cookies only on the basis of your prior consent. Please see our cookies information tool which is displayed in the footer of each of our websites to review the types of cookies which you have consented to.	Please see our cookies information tool for further information. Please see our cookies information tool for further information.

Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, which is compatible with the original purpose. You may request an explanation of how the processing of your Personal Data for the new purpose is compatible with the original purpose by contacting us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the lawful basis that allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is permitted or required by law.

Disclosures of Personal Data

As part of fulfilling our contractual obligations we may have to share your Personal Data with third party processors.

The following third parties may have access to your personal information for the purposes noted below:

Software providers: we use a range of software providers in order to administer our business, these providers include the host of the Website, the providers of our call recording system, email system, automated email marketing system and customer databases.
Service providers: we use a range of service providers in order to effectively operate our business, for example providers of subscription voucher services.
Event organisers: where we hold events, we may share your personal information with third party organisers of the event including caterers and venues, for example. We may also share your name with the venue for the purposes of administering a guest list.
Competition prize providers: where you enter one of our competitions, we may share your information with the third party who is supplying the prize to ensure they are able to provide you with any prize that you may win. We may also pass your contact details to the prize provider if you have requested to receive their marketing material.
Cookies providers: for example, Google Analytics and 1PlusXAG, please see our cookies information tool for further information.
We are part of a group structure of companies, and your personal information may require to be transferred to one of our subsidiaries or affiliates in order to ensure the proper functioning of our business.
Any other person who is authorised to act on your behalf.
Regulators, government departments, law enforcement authorities, tax authorities, accountants, insurance companies, lawyers and other professional advisers.
Any relevant dispute resolution body or the courts.
Persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in our business.

Some of these entities may also be data controllers under the data protection laws. However in the first instance you should contact us using the contact details below if you have any queries.

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

Except as provided above, we will not share personal information with any other third parties without informing you beforehand, unless required by, or in connection with, law and / or regulatory requirements.

We will not sell, trade or lease your personal information to others.

Transfer of Personal Data outside the UK

The information we collect from you may be stored inside the UK, the European Economic Area (“EEA“) or outside the EEA.

If you live or work outside the UK, we may need to transfer your personal information outside of the UK to correspond with you. Where this applies, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.

We also transfer personal information outside the UK where our service providers host, process, or store personal information outside the UK. Where this is the case we use contractual arrangements and safeguards to protect this personal information (as required by Article 46 of the UK GDPR), these safeguards include:

The country to which the personal information will be transferred has been deemed to provide an adequate level of protection for personal information by the Information Commissioner’s Office (ICO). For further details, see ICO website.
Where we use certain service providers, we may use specific contractual clauses set out by the ICO which give personal information the same protection it has in the UK. For further details, see ICO International Data Transfer Agreement and Guidance.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.

Data Security

We have put in place commercially reasonable security measures to protect your Personal Data from your computer to the Website and prevent such information from loss, misuse, unauthorised access, disclosure, alteration, or destruction. In addition, we limit access to your Personal Data to those employees, agents, contactors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and remain subject to confidentiality obligations.

Unfortunately, the transmission of Personal Data via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. We have put in place procedures to deal with any suspected Personal Data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, you may ask us to delete your Personal Data (see “Your rights” below). We may anonymise your Personal Data (so that it can no longer be associated with you) in certain instances for research or statistical purposes and to help us develop and improve our services. In these circumstances, we may use your Personal Data indefinitely without further notice to you.

Your rights

You have a number of rights concerning the way that we use your Personal Data. At any time, you have the right to:

request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
request correction of Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Please note, we may need to verify the accuracy of any new details you provide.
request erasure of your Personal Data. This enables you to ask us to delete Personal Data where there is no good reason for us continuing to process it. This may also apply where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to delete your Personal Data to comply with local law. Please note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
object to processing. This enables you to object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your personal situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
withdraw consent. You may withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
request to transfer data. This enables you to request the transfer of your Personal Data to you or a third party. We will transfer the data in a structured, commonly used, machine readable format. This right applies only in respect of automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Exercising your rights

When you exercise your rights, we may need to ask for information to help us confirm your identity to ensure that your Personal Data is not disclosed or shared with any person who is not authorised to receive it. We may also ask for clarification or further information in relation to your request to enable us to efficiently comply with your request.

We try our best to respond to all legitimate requests timeously and within one month. However, it may take us longer than a month for more complex requests or if you have made multiple requests. In such circumstances, we will make you aware of the likely timescales and keep you updated of our progress.

You do not have to pay a fee to exercise any of your rights. However, we can and may charge a reasonable fee if your request is excessive, repetitive or unfounded. We may also refuse to comply with your request in such circumstances.

CCPA

If you are a resident of the State of California, USA, you have the following rights under the California Consumer Privacy Act (CCPA):

Request access to your personal information: The right to request access to the personal information we may hold on you for a lookback period of 12 months.
Right to opt-out of the sale of personal information: If you are over the age of 16 you have the right to opt-out of the sale of any personal information we may hold on you.
Right to Deletion: The right to request we delete any personal information we hold on you or restrict how it is used. This right is subject to certain exemptions.
Right to Non-Discrimination: The right not to be subject to discriminatory treatment in response to exercising any of your CCPA rights.

If you want to make any of these requests, please contact admin@harrogate-news.co.uk. Please specify that you are making a request under the CCPA when contacting us. We will respond to California-specific requests within the time limits set out in the CCPA. We reserve the right to confirm your residency in California before processing your request.

This section should be read in conjunction with the rest of this privacy notice for further details on our data processing. Information provided in this section applies exclusively to residents of California and their rights under the CCPA. This section refers to ‘personal information’ as opposed to ‘personal data’ in line with the definitions used in the CCPA.

Contact Information

We are the “data controller”, that is, the company responsible for, and which controls the processing of, your Personal Data collected in accordance with this Privacy Notice. If you have any questions, concerns or comments about this Privacy Notice, wish to exercise any of your rights or if you wish to contact us (or our data protection officer) about the personally identifiable information held about you, please write to us or email us with the details below:

Email: admin@harrogate-news.co.uk

If you have any concerns about our use of your information, you also have the right to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of Personal Data in the UK, via their helpline on 0303 123 1113. We would appreciate the opportunity to address your concern so please contact us in the first instance.