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Privacy & Cookies Policy

This is the Privacy Policy (including Cookies) of The Fleet News (collectively referred to as “we”, “us” or “our” in this policy).

It is based upon the UK Data Protection Act 2018, alongside which sits the UK GDPR (General Data Protection Regulations).

The date of this Privacy Policy is 4 October 2023. There are no previous versions.

Sections in this policy

  1. Introduction

  2. About this policy

  3. Who we are and how to contact us

  4. Types of personal data we collect, how and why

  5. How we use your personal data

  6. Security of the data we hold

  7. Sharing your personal data

  8. International data transfers

  9. How long we keep your personal data

  10. How we may contact you

  11. Cookies and similar technologies

  12. Your privacy and data protection rights

  13. The Information Commissioner’s Office (ICO)

  14. Other relevant legislation

  15. Changes to this policy

1. Introduction

The Fleet News is a free local newsletter publication, and we are committed to keeping your personal details safe. This policy explains how and why we use your personal data, to ensure that you remain informed and in control of your information.

As The Fleet News is a publication, data protection law includes certain exemptions when personal data is processed for the purposes of journalism. Those exemptions apply to some of the ways The Fleet News uses personal data. This privacy policy does not cover personal data that we process for the purposes of journalism.

The Fleet News is both a Data Holder/Controller and Data Processor.

We consider carefully how we collect, use and store your personal data in order to provide you with articles and information that interest you, presented in such a way to make it easy for you to access and read.

To help us achieve this involves understanding you, our readers, through the collection of data. For example, knowing which website articles you click on and read helps us to understand your interests so that we can provide you with further relevant content of interest.

As The Fleets News is free to readers and primarily funded by advertising (and supported by contributions and donations), our advertisers ask us about our readership so that their ads reach the right audiences.

To grow our number of readers and supporters, we are reliant on marketing and advertising.

Below you can find the details of what we do to protect your privacy, including:
• Information about your rights, the choices available to you, and our obligations.
• Transparency about how we collect and use your personal data, including when and how it is shared.
• Information on how we protect your personal data.
• Information on how we will facilitate your rights and respond to your questions.

2. About this policy

There are three important definitions to describe the roles of people or entities in this policy. These are definitions used by the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights.

• ‘Data Subject’: this is you.
As the data subject, this policy refers to you and your personal data.

• ‘Data Holder/Controller’: this is us, The Fleet News.
With your consent, we collect your personal data.

• ‘Data Processor’: this is a person, or organisation, who processes your data on our behalf.

If we work with organisations or individuals (Data Processors), we always set up a written contract with them to protect your data. For example, this could be for a marketing or social media campaign or an event. They at no point ‘own’ your data, so you will not be contacted by them directly or for any other purpose than for the task we have agreed with them. They will always delete your data from their systems when they have completed the task in hand. We ensure your personal data is sent and managed in a secure manner.

We will never sell your personal data.

Our website may sometimes contain links to other websites, or embedded content from other websites, with their own privacy policies, which we recommend you read.

3. Who we are and how to contact us

The Fleet News is a free local newsletter published in print and online covering the Bloomsbury and Kings Cross areas of London. It is a publication and a brand name owned by Fleet News South East Limited, a private company limited by guarantee registered in England & Wales No. 14714572.

We publish community-led journalism, useful local information, features and articles, reviews and opinion pieces on subjects that are of interest to people resident, working or visiting the Bloomsbury and Kings Cross areas of London.

Should you wish to know or correct the personal data we hold about you, or about our privacy policy, please contact us. Our office hours are Monday-Friday 9am-5pm.

The Editor
The Fleet News
71-75 Shelton Street
Covent Garden
London WC2H 9JQ

editor@thefleetnews.com
+44 (0)7984 453 477

4. Types of personal data we collect, how and why

There are two categories of data covered by this privacy policy: personal data and sensitive personal data. Sometimes personal data is referred to informally as personal information.

• Personal data relates to you, the data subject, as someone who can be identified, directly or indirectly, by reference to an ‘identifier’ such as:
– Your name or identification number, date of birth, gender, email address, postal address, phone number, mobile number, or financial details, such as payment cards you use to support our publication.
– Details about your physical, physiological, genetic, mental, economic, cultural or social identity.
– Information about your device, location data or online identifier (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based).
– Information relating to how you use and interact with our website or app.

• Sensitive personal data includes information about your race, ethnicity, politics, religion or spiritual beliefs, trade union status, health, sex life, sexual orientation or crimes.

We collect only very limited personal data, relevant to the type of interaction you have with The Fleet News.

We do not generally collect sensitive personal data, unless there is a clear purpose and clearly communicated reason for doing so.

Our forms to collect data are clearly written to state what personal data is being collected and why we need it.

You have the right to request, update and/or delete your personal data that we hold.

We do not knowingly collect children’s personal data. We do not aim our publication or any articles, information or advertising directly at children. When we refer to a child (children), we mean anyone under the age of 13.

We collect data either directly or indirectly, when you:
• Subscribe to receive our email newsletter.
• Contribute to our publication.
• Make donations to fund and support us.
• Pay for advertising or any other products/services for yourself or others.
• Attend our events (in person and/or virtually).
• Enter our competitions, prize draws or surveys.
• Use mobile devices to access our content.
• Access and interact with our website or app.
• Contact us via email, social media, our app or similar technologies or when you mention us on social media.
• Provide us with feedback or make an enquiry.

Direct data collection means you submit data to us.

• When you subscribe to our email newsletter, you consent to receive our email newsletter and you submit your personal data, namely: your name, email address and your interest or role in the Bloomsbury and Kings Cross area (resident, visitor, student, business owner, worker). You can update information or unsubscribe by using the links in the email newsletter or by contacting us.

• When you advertise with us you submit information that is to appear in your advert as well as any business or financial information to facilitate invoicing and payment for advertising.

• When you make a contribution to content or financial donation you submit information to enable your contribution to be published or the financial transaction, invoicing and payment to be administered and completed.

• When you contact us by email or online form, by post or phone, you submit data to us, such as your name, address or location, email address and/or phone or mobile number to allow us to accept your contribution or handle your feedback, comment or enquiry.

• When you follow, connect with, or direct message one of our Social Media accounts, you submit your personal data, namely your social media name or account name, and any personal data publicly available on that social media platform such as your location. If you mention, post or repost, or link to The Fleet News in posts on social media sites, we may collect your social media handle. For example, if you mention The Fleet News in a tweet, we may collect your X (previously known as Twitter) handle.

Indirect data collection takes place passively as you interact with our website, app or social media. Such as through cookies.

• Cookies
Our website uses Cookies – please see Section 11 of this policy ‘Cookies and similar technologies’. Cookies are small text files that are placed on your computer, tablet or mobile phone when you browse websites or use apps.

We place a Cookies Notice banner on our website when you access our site. This banner gives you the option to accept cookies or change and save the cookies settings you prefer. However, if you click on any link on our website and continue to read our pages you agree to accept all cookies.

• Web Analytics
We use web analytic services, like Google Analytics. These use cookies to collect data that is collated and analysed which helps us provide you with better articles, information, services and website experience. This information is anonymous (does not personally identify you). It helps us understand reading behaviour (which web pages, articles or adverts are clicked on and read, or which web pages and content are most popular amongst readers); web browser and device type which helps us fine tune the technical aspects of our website; what word(s) are used to search to find our website; which page on our website is most often landed on; and location - what country or city website visitors are in, when connected to our website - by identifying an IP Address.

• An IP Address
Every device connected to the Internet is assigned a number known as an Internet protocol (IP) Address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet. However, it does not identify you personally.

Please read Google’s Privacy & Terms on https://policies.google.com/privacy?hl=en-GB

To prevent your data from being used by Google Analytics when visiting websites, go to https://tools.google.com/dlpage/gaoptout where you can download and install Google’s web browser ‘add-on’ compatible with Chrome, Safari, Firefox and Microsoft Edge.

• Third-parties services or platforms
Our website may allow you to access, use, or interact with third-party websites, apps, content, and other products and services. When you use third-party services, their terms and privacy policies govern your use of those services. We do not control and are not responsible for the actions or policies of any third-party service. Your use of any third-party service is at your own risk. We encourage you to read any privacy policy accompanying a third-party service and ask them for any clarifications you may need.

For example, we use VISTAxWIX to host our website. VISTAxWIX is a business arrangement between VISTAPRINT and WIX.

We use WIX to store your personal data - your name and email address that you submit when you subscribe to our email newsletter.

We use WIX e-newsletter, marketing and analytics services.

With regard to your personal data and their services, please see their privacy policies:
https://www.wix.com/about/privacy WIX is a company that provides cloud-based web development services, along with their third-party service providers, whose services and solutions complement, facilitate and enhance WIX’s own.

https://www.vistaprint.co.uk/privacy-and-cookie-policy VISTAPRINT is an e-commerce company that produces physical and digital marketing products for small businesses.

• Social Media
Cookies help enable the sharing of web pages with social media platforms. We also might obtain your personal data through your use of social media such as Instagram, Facebook, TikTok, X (previously known as Twitter) or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services.

Please refer to their privacy policies, with regard to your personal data and their services:

https://about.instagram.com/safety Instagram safety

https://privacycenter.instagram.com/policy/ Instagram privacy policy

https://www.facebook.com/privacy/policy/ Facebook

https://www.tiktok.com/legal/page/eea/privacy-policy/en TikTok

https://twitter.com/en/privacy X (yes, even though it is now called ‘X’)

https://www.linkedin.com/legal/privacy-policy LinkedIn

https://policies.google.com/privacy?hl=en-GB YouTube

5. How we use your personal data

We use your personal data only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.

Legal grounds for using your personal data may be one of the following.

• Consent
We will use your personal data because we have asked for your consent, which you can withdraw at any time. For example, when you ask to receive our email newsletter. Or when you contact us directly.

• Performance of a contract with you (or to take steps to enter a contract with you)
We will use your personal data if we need to perform a contract with you. For example, where you have purchased advertising, we will need to use your contact details, details to appear in the advert and payment data. Or we may contact you directly via social media or email if you enter competitions, prize draws, or respond to surveys.

• Compliance with law
In some cases, we may have a legal obligation to use or keep your personal data. We will comply with legal requests where disclosure is required or permitted by law (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant and valid request in writing).

• Our legitimate interests
We may process your personal data where it is necessary for our legitimate interests in a way that might be expected as part of running The Fleet News and in a way which does not materially impact your rights and freedoms.

For example, it is in our legitimate interests for us to maintain relationships with contributors; to understand our readers; to promote our publication, our advertisers and the ways you can support us; to analyse how our website or app is used to improve content and functionality; to back up our systems and databases; and to operate our website and app efficiently for the creation, publication and distribution of news, information, media and related journalistic content both online and in print.

We may also process your personal data where it is necessary for our legitimate interests for internal administrative purposes; to inform you of any changes to our publication or services, such as updates to our terms and conditions; to enable you to share our content with others using social media or email; to respond to your queries and to resolve complaints; for security and fraud prevention, and to ensure that our website and app are safe and secure and used in line with our terms of use; and to contact you directly via social media or email if you send us emails or engage with The Fleet News on social media or contact us.

6. Security of the data we hold

We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. Unfortunately, sending any information, including your personal data, via the internet is not absolutely or completely secure. We cannot guarantee the security of any personal data sent via the internet and as such you provide it at your own risk.

We use WIX to store and process your contact details and to send out email newsletters, marketing and communications to you, under our and their privacy policies terms, which are fully compliant with UK data protection law. For such purposes, WIX serves and shall be considered as a “Data Processor” and not “Data Controller”. The Fleet News remains the “Data Controller”. Any data stored outside of WIX (for instance as a backup) is in password-secured files. Details can be found in WIX’s privacy policy - https://www.wix.com/about/privacy

Access to all data is strictly controlled, with only a limited number of The Fleet News personnel having access. All access is through secure login.

7. Sharing your personal data

• We will never sell your personal data.

• Service Providers
We may share your personal data with third-party service providers to enable us to:
– Store and secure data
– Process forms or payments
– Deliver website or platform or publishing operations
– Email or contact you
– Analyse our website or app
– Use fraud detection
– Market and advertise our publication, products or services
– Provide customer service

• Law Enforcement, Legal Requests and Duties
We may disclose or otherwise allow access to your Personal Data as described in this Privacy Policy pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.

• Protecting Rights and Safety
We may share your Personal Data as described in this Privacy Policy if we believe in good faith that this will help protect the rights, property or personal safety of The Fleet News, its staff and contributors, any of our readership, or any member of the general public, with or without notice to you.

• In connection with a change in control or ownership of the business
Should The Fleet News or Fleet News South East Limited undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event.

8. International data transfers

The information we collect about you, as described in this privacy policy, may be accessed, processed, stored in or transferred to countries that may not have the same data protection laws as the country in which you reside.

Your data is only accessed, processed, stored or transferred outside the UK where The Fleet News has verified that appropriate standards and safeguards are in place.

9. How long we keep your personal data

We keep your personal data for only as long as we need to, generally for as long as The Fleet News is active.

How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to respond to your feedback or answer your queries and as a result may keep your personal data whilst you still use our product or services.

Where you contribute material to us, for example written stories, photographs or illustrations, we will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation and/or acceptance.

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.

We may also need to keep your personal data for accounting purposes, for example, where you have paid for advertising or made a financial contribution or donation.

If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data.

However, when you unsubscribe from our email newsletter and/or marketing communications, we will retain your email address to ensure that we do not send you any further newsletters or marketing in the future.

10. How we may contact you

• Service communications
Occasionally we may email you, for example, to tell you of a change to our publication or thank you when you contribute or place advertising with us.

• Marketing communications and editorial newsletters
If we have your permission, or you have not opted out, we may email you materials we think may interest you, such as new offers and updates.

• Email Newsletters
If you have given your consent and confirmed that you are 13 years old or older, we will email our Newsletter to you. You can manage your subscription to these email newsletters by using the links in the email newsletter.

• Market research
We may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by using the link in the survey.

• Responding to your queries or complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.

• Advertising sales
We may contact you by phone, email or in person to offer you the opportunity to support our publication by taking out print and/or online advertisements for your company, products or services.

11. Cookies and similar technologies

We use cookies, pixels and other similar technologies (collectively referred to as “cookies”) to help provide, protect and improve our website, app and services. Cookies help us to provide you with the best web experience we can. Cookies are small text files that are placed on your computer, tablet or mobile phone when you browse websites. The information does not usually directly identify you personally.

There are two types of cookies you may encounter when using our website:
• First party cookies - Necessary or Essential or Functional Cookies enable our website or app to work properly; Non-Essential Cookies provide information about the usage of our site
• Third party cookies - these are found in third-party apps and services if used on our website. Third parties will have their own cookies and cookies policies.

Cookies help us:
• Make our website work as you would expect.
• Remember your settings during and between visits.
• Improve the speed and security of our website.
• Allow you to share pages with social media networks like Instagram, Facebook, X (previously known as Twitter), TikTok and LinkedIn.
• Continuously improve our website design, functionality and content for you.

Most web browsers allow some control of most cookies through your web browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit https://ico.org.uk/for-the-public/online/cookies/

We may from time to time embed videos from YouTube (which is owned by Google), Vimeo or other video platform on our website. These video services or platforms may place cookies on your computer, tablet or mobile phone, particularly if you are logged into a Google or YouTube, or Vimeo, account.

To find out more, please visit:

https://www.youtube.com/howyoutubeworks/user-settings/privacy/ YouTube, which is owned by Google

https://policies.google.com/technologies/cookies?hl=en Google

https://vimeo.com/cookie_policy Vimeo

12. Your privacy and data protection rights

You have legal rights with regard to your personal data that we hold about you and you can contact us with regard to the following rights in relation to your personal data:

• You have the right to receive a copy of the personal data we hold about you.
• You have the right to correct the personal data we hold about you.
• Where applicable, you may also have a right to receive a machine-readable copy of your personal data.
• You also have the right to ask us to delete your personal data or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request.
• Where applicable, you have the right to object to processing of your personal data for certain purposes.
• Where you have provided us with consent to use your personal data, you can withdraw this at any time.

If you would like to exercise any of your rights outlined above, please email:

editor@thefleetnews.com

or write to:

Data Protection, The Fleet News, 71-75 Shelton Street, Covent Garden, London WC2H 9JQ.

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

We may need you to provide valid identification to verify your identity to proceed with a request. If you provide us with proof of identity containing information that does not match our records, we may request further proof of identity from you. This is a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it.

There is no fee to obtain a copy of your personal data (or to exercise any of the other rights). However, for any further copies requested by you, we may charge a reasonable fee based on administrative costs.

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