Privacy & Cookies

This Policy explains how we protect and handle any personal information you provide to us, including via our websites, our apps, our social media pages/accounts, email, telephone and in person. It also covers any personal information we receive from third parties and provides you with an overview of your rights.

By using our products and services, including browsing our websites, registering, logging in or signing up for newsletters or marketing, you agree that we may use your personal information as outlined in this Policy. There may be occasions when we share responsibility for the processing and protection of your personal data in connection with your use of our products and services as joint controllers with our partners (please see Section 2 Who we are for additional information). In such instances our partners will process your personal data in accordance with their privacy notices.

Arcvox is a group of independent journalists from differing backgrounds based in the United Kingdom (collectively "Arcvox")

This website was built by, published by and is maintained by Premier Digital Group Ltd.

We collect the following information:

Information you have provided to us:

We collect information such as your name, telephone number, address, email address when you create and log into an online account, subscribe to one of our titles, sign up for our newsletter or marketing communications, respond to one of our competitions/promotions or Offers, order or register your interest in one of our products or post a comment under an article, in addition to, where you or your organisation provide us with products or services, the name of your organisation and bank and account details and information relating to a particular transaction.

Subscription Services – Third Parties

If you make a purchase or take out a subscription service via the Arcvox website, we use Third Party companies to support us. These companies provide us with identity, entitlements, and subscriptions management, customer journey / audience conversion and personalisation services. The personal data that Stripe collects on our behalf when you complete a purchase, create an identity that may include your name, email, payment details (from credit/debit card or electronic payment systems, such as Google Pay), password, communication preferences, payment tokens, address information and personal preferences. Stripe will handle your personal data in accordance with their own Privacy and GDPR policies.

This information may be collected via your computer browser, an online web form, a data capture form, an app, by email, by telephone, or by post.

When you visit our website or app, we shall create a unique identifier (“UID”) that allows us to recognise you when you use our website, including if you log in from a different device or platform.

Information from your device:

We collect information from and about the device you are using when you interact with one of our websites, apps or other products/services, including adverts.

This may include:

Device Type: Information about your operating system, hardware, software, browser type in order to tailor the experience to your device (e.g. screen resolution).

Device Operations: Information about your operations and behaviours performed on your device to tailor the experience based on how you or similar users have interacted with our content.

Unique Identifiers: Device IDs, UIDs and Advertiser IDs in order to save your preferences against an identifier to refer to on subsequent pages and to display advertising.

Device Settings: Information from your device’s setting (such as access to your GPS location or other information related to the location of your device) so that we know which version of the website to serve you.

Network/Connections: Your IP address, so that we can recognise your geographical location.

Cookies: Data from cookies or similar technologies placed on your device which tells us about your use of our websites and/or selected third party websites. Some cookies are also placed by third parties. Please see Section 14 on Cookies and other identifiers below for more information about our use of cookies and other similar technologies.

Information collected by the Extension.

Unique identifiers: A unique installation ID or similar identifier is also processed to recognise the Extension you have installed.

Access Data: With regard to each of your visits to our websites and the URLs and domains you visit while the Extension is installed, Arcvox’s web servers record technical information which your browser automatically transmits. This includes the IP address used to connect your computer or mobile device to the internet (including in truncated form), the browser type and version you use, the operating system, date and time of your access, whether Java is on or off, whether cookies are accepted or rejected.

Usage Data: Arcvox collects further information about your visit to our websites and your usage of its services and content and the URLs and domains you visit while Extension is installed. That information includes the full URL clickstream to, through and from the Extension (including date and time), visited sub-pages, information you searched for, response times, length of visits to certain pages, email openings and which banners or links on the website or in an email were clicked on, browsing activity (such as scroll positions, clicks and mouse movements), search queries, the URL of the website you visited immediately beforehand. Arcvox uses such data for a variety of purposes (e.g. to better understand your needs and preferences so that Arcvox can improve the Extension, its other services and their functions and to provide you with more relevant and interest-based contents.

Device Data: In case of Extension, screen size, time zone setting, and geographical identifiers.

Posting comments on articles

When you comment on an article, the information you post and your username are publicly accessible. This information can be viewed and collected by other people. We strongly suggest you avoid sharing any personal details, and especially information that can be used to identify you directly such as your name, age, address and name of employer in your comments. We are not responsible for the privacy of the information you make publicly accessible via the comments section. Please see our Terms of Use for more information.

Information about transactions made

If you purchase anything or make any other financial transactions on this website, we collect information about your purchase and ask for information including your name, email address and delivery address, to be forwarded on to the partners who are responsible for delivering your order. This may include payment information such as your credit/debit card number where we are engaging a third party to process payments on our behalf.

Information from partners

Where you have registered or created an account with our website, we may obtain information about you from other companies who have obtained your permission (through their own privacy policies) to share information about you.

We may overlay demographic and lifestyle data from CACI to help us understand what you might be interested in for insight and marketing purposes (also known as profiling). CACI data are built using a variety of sources, including publicly available data (such as the electoral register and UK Census records) or from surveys and polls where you have given permission for your data to be shared. For more information on these partners and how you can opt-out of having your data shared with us from these sources for profiling purposes, please see the section entitled “Marketing Personalisation” in Section 7 below.

Social media

If you log-in to our websites through a social media site, such as Facebook or Google, you are granting permission to such company to share your user information with us. This will include your name and email address plus any other information you have permitted them to share with third parties. If you remove our website from your Facebook, Twitter or Google account, we shall no longer have access to this information.

We use plugins from social media networks and other platforms on our websites, that may allow you to share content with these networks/platforms or use their services on our websites. For more information, please see Section 7 of this Policy.

Browser pop-up notifications

When you consent to receiving pop-up browser notifications from one of our websites, we collect the following information:

• the URL of the page you were on when you were subscribed;
• your country code;
• your device type;
• your browser name and version;
• whether the notification was shown to you; and
• the topics of the notification you have clicked on or interacted with.

Information about other people

By supplying us with information about someone else, you confirm that they have authorised you to provide us with their information (including sensitive personal data) on their behalf.

We rely on the following legal bases to process your personal data under the UK General Data Protection Regulation (“UK GDPR”) and the EU General Data Protection Regulation (“EU GDPR”).

 Contract: We process some of your data as a necessary part of performing our contractual obligations to you. For example, to ensure that products you buy can be delivered to you, to provide you with access to your digital subscription or to provide a prize to which you have won.

Consent: Some processing activities will only be done where we have sought your prior consent. If we require your consent, we shall provide you with full details of the information that we would like and the reason we need it. Once given, you have the right to withdraw your consent again at any point and we shall be obliged to stop processing your data and delete it unless we can demonstrate that another legal basis applies.

Legal obligation: There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This includes publishing information about competition winners.

Legitimate interests: We process some of your data because it is in our legitimate interests to do so. Where this is the case, we have considered the impact that using your information may have on you and limited our use to only what is strictly necessary. Where we are using this as our basis, we can provide you with an explanation of why the processing is in our interests and you are free to contest this decision if you wish.

Examples of our legitimate interests processing activities include:

• supporting a free press and individual and societal rights to receive information;
• developing, delivering and maintaining relevant and engaging products services and advertising; and
• understanding who our audiences are in order to improve our content and services.

Journalism

We use personal information for journalistic activities to support a free press and to support individual and societal rights to receive information.

Legal basis for these processing activities: Legitimate interests

Message boards, blogs and other public forums

Our websites may provide message boards, blogs and other user generated content facilities. Anything that you share will become public information. You should always be careful when deciding to disclose your personal information. Please see our Terms of Use for more information.

Legal basis for these processing activities: Consent (if requested) or legitimate interests

Comment Moderation

We monitor comments for offensive/objectionable content and disruptive behaviour that breach our Terms.

Legal basis for these processing activities: Legitimate interests

Comment Services

Where we provide you with functionality to comment on an article, you will need to create an account with us to use the comment functionality. We process your registration data and any comments that you voluntarily submit in accordance with our legitimate interests in providing users with the ability to comment on articles. The information you post and your username are publicly accessible and can be viewed and collected by other people. We strongly suggest you avoid sharing any personal details, and especially information that can be used to identify you directly such as your name, age, address and name of employer in your comments. We are not responsible for the privacy of the information you make publicly accessible via the comments section.

Our comments functionality is also subject to our Terms of Use. We will monitor and moderate comments, including for offensive/objectionable content and disruptive behaviour.

Legal basis for these processing activities: Legitimate interests

Delivering services

By using our websites, apps and other products and services, we may process your information, including your name, phone number and email address, for the purpose of providing you with such products and services and managing our relationship with you, which shall include (without limitation):

• carrying out ecommerce activities;
• managing your accounts, entitlements and subscriptions;
• communicating with you in relation to your account or service, service updates or other non-marketing communications;
• delivering customer services and support;
• contacting you when a checkout journey is not completed if you have provided your information;
• dealing with and responding to you about a comment you have submitted on our message boards or other such user generated content facilities;
• ensuring the integrity of votes, competitions and polls;
• maintaining records of our communications with you if you get in contact with us; and
• responding to press complaints submitted both direct to us and via the Independent Press Standards Organisation (IPSO).

Legal basis for these processing activities: Consent (if requested) or legitimate interests or contract

• running competitions effectively and informing you if you have been successful in any competitions or promotions.

Legal basis for this processing activity: Contract or legal obligation

We may also record phone calls or customer enquiries via online chat for quality, training and management purposes.

Legal basis for this processing activity: Legitimate interests or contract

Digital events

 We may use your personal data (such as your name, email address, etc.) to provide you with digital event functionality and content, including recordings, user generated content and chat functionality. This may also include speeches or presentations, chat content, questions, poll results and audio-visual content incorporating your likeness, image or opinions.

This content may be retained and reused by us for later business purposes (for example for reuse at subsequent events or to allow webinar access at a later stage).

Legal basis for processing this data: Consent (if requested) or legitimate interests

Direct marketing, newsletters and browser push notifications

In accordance with your preferences and data protection legislation, we may use your information, including your name, email address, and phone number, to send you direct marketing communications, newsletters and to carry outmarketing analysis.

This may include communications by email, post, telephone, SMS or app notifications about our products and services, events and special offers. This also includes browser push notifications where you have consented to receivingthese. We may also send you periodic emails to inform you about the any changes to our products and services where we have permission to do so.

In relation to email marketing communications, we may send you such communications when we have your consent, or when you are an existing customer who has previously bought or subscribed to a similar product or service from us. You may opt out of email marketing communications when your personal information is first collected as part of that purchase or subscription.

You may also unsubscribe from receiving email marketing or newsletters at any time by clicking the “unsubscribe” link at the bottom of each email. If you unsubscribe from email marketing or newsletters, we shall keep your email address to ensure that we do not send you any marketing in future.

Legal basis for processing this data: Consent (if requested) or legitimate interests

Personalisation / identifying your interests / audience segmentation / audience conversion / ecommerce activities

We use your information, including your UID, to provide you with a greater personalised experience when you visit or use one of our sites or apps, and for insight and marketing purposes.

We make assumptions and draw inferences about your interests based on the kind of articles and content you click on or read.

We use this information to segment our audiences into groups with attributes. This helps us show you more relevant content/adverts and helps our advertisers target more effectively.

Please note you have the right to object to profiling for marketing purposes at any time. If you wish to opt-out of having your personal information profiled for personalisation purposes, you can do so via the Cookie Settings.

Legal basis for this processing activity: Consent (if requested) or legitimate interests

Cookie Matching

Where you have given consent, we check to see if you have a cookie ID when you visit one of our webpages. We are then able to compare the cookie ID we have to see if we know who you are. This allows our automated system to highlight webpages we think you might be interested in. See Section 14 on Cookies for more information.

Legal basis for this processing activity: Consent

Data matching and lookalike audience building

We allow partners to reach audiences on our platforms via data matching where they have appropriate permissions. We use your UID (together with other associated personal data such as email address) to carry out such data matching. This is conducted at an aggregate level or an individual level, depending on how targeted our partners want to reach audiences on our platforms. Your UID is stored with an independent third party data management platform (DMP) who will match UIDs with the data from advertisers with whom we partner. This matching is based on common identifiers (such as email address). This matching is completed using a 'data clean room' where neither we nor the advertiser will have access to each other’s data.

The data overlap between our audiences and these partners is useful to understand if an advertising campaign would be effective.

As part of the matching process, we segment audiences based on predefined attributes. These audiences may be similar to our partners’ existing audiences and are therefore called “lookalike audiences”. For example, a female fashion brand may want to reach “women interested in fashion”. This helps them find the right audiences and we are able to show you more relevant advertising.

You may amend your settings in order to avoid UID matching taking place in the future by contacting us (see Section 17 below) or by adjusting your account settings.

Legal basis for this processing activity: Consent (if requested) or legitimate interests

Tailored advertising

We use advertising to fund our website. Some advertising is ‘contextual’ meaning it is shown due to the particular webpage you are presently viewing. Other advertising, known as “online behavioural advertising” is shown to you based upon your likely interests, which are inferred from your browsing history. This information is collected through the use of cookies and similar technologies or your UID. Such data may have been collected over time and from other websites you have visit prior, who also use Google to display advertising. For more information on controlling your tailored advertising preferences, please see Section 14 on Cookies below.

Sometimes we allow advertisers to show advertisements directly on our website which are tailored to you based upon information they have obtained, such as your browsing history on their own websites.

Other times we shall arrange for our customers to be shown advertisements on our own or other websites or apps. These advertisements are tailored to you with information we have obtained from your browsing on our websites and apps via cookies.

When you are shown an advertisement, our advertising systems do not know who you are or your contact details (such as your name, email address or postal address). We do not share personally idenfifiable information with Google to show you relevant advertisements on this website.

Your IP address may be used, in connection with our legitimate interests to tailor the advertising we arrange to be shown.

We may also target advertising on social media sites to specifically include customers who have registered for our products and services.

Legal basis for this processing activity: Consent (if requested) or legitimate interests

Location based services and advertising

Where we provide services that utilise your device’s location, such as local weather or news, your location will be determined either from a lookup of your IP address in a “GeoIP” database which lists information provided by your ISP (usually your closest town or borough).

Sometimes we can collect the precise location directly from the device (such as through GPS or Wi-Fi on mobile devices) but only where you have granted permission for us to access this location information via your device settings. We use such information to provide you with a more tailored, relevant experiences when using our website, such as showing you local and relavant news articles.

Where you have granted permission to access your device’s location and consented to us to use your data for advertising purposes, this location information may be used to tailor the advertising you receive, including showing you certain advertisements when you are in the vicinity of a particular location.

Legal basis for this processing activity: Consent

Measurement and analytics

We may use certain information (such as the websites that you visit and advertisements you see or click on and emails you interact with) to help us, advertisers and other promotional partners measure the effectiveness and distributions of their advertisements and promotions as well as the effectiveness of our own services and communications. This is done via Google Analytics.

Legal basis for this processing activity: Consent (if requested) or legitimate interests

Surveys and market research

We collect information via online survey units (Pulse Poll) and via our online research community of our readers (Matters Community) to help us better understand our readers and how they engage with the advertising they are shown. We collect this information when you voluntarily contribute or we invite you to contribute to any of our surveys, polls or forum discussions on our websites or online research community, for example when we ask you questions about your behaviour or response to adverts seen. We will also use your responses to our surveys, polls or forum discussions to send you targeted advertising, where we have your permission to do so. How we use data relating to our online survey units is covered by this privacy policy.

Legal basis for processing this data: Consent (if requested) or legitimate interests

Improving our services and products

We may use your information to monitor and improve our products, content and services. This may include (without limitation):

• developing the design and style of our products and services to make improvements;
• carrying out statistical, technical and logistical analysis to inform our strategic development; and
• blocking disruptive use and ensuring the security of our products and services.

If you have registered on our website, we may analyse the information we hold on you in aggregate with our other customers to improve our advertising systems.

Legal basis for this processing activity: Legitimate interests

Disclosures permitted or required by law

Your data will be disclosed where we are obliged to do so by law. We may also disclose your information in order to protect or enforce our rights or the rights of others and for the prevention and detection of crime. Foremost, the courts of the United Kingdom.

Legal basis for these processing activities: Legitimate interests or legal obligation

Receipt of services from suppliers

 If we have engaged with you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our products and services to others.

Legal basis for processing this data: Legitimate interests or contract

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the services you have requested from us. In this case, we may have to cancel the provision of the relevant services to you, in which case we will notify you.

Sharing with third-party partners

Partners: When you purchase goods or services from us, we partner with specialist companies (including payment companies) to fulfil your order and provide certain customer services. This includes vendors on MailShop who you may have bought something from and specialist companies who assist us in obtaining ratings and reviews of product(s) and/or service(s), namely, YouGarden, Clifford James Consultants Limited, KH Direct Ltd, and Aspire Furniture Ltd.

We usually remain the data controller of your information and the other companies only process data under our instructions and cannot use the information for their own purposes. If one of our third-party partners acts as data controller of your personal data (whether or not as a data controller in common with us) we shall let you know before you register for the service.

You can access the privacy policy of Google Ads here.

Legal basis for processing this data: Contract

Service Providers: We may pass your information to our processors – companies that we use to provide services on our behalf, for example for delivery services and prize fulfilment companies. These processors can only use your information in accordance with our instructions and for no other purpose.

Legal basis for processing this data: Contract or consent (if requested) or legitimate interests

 Promotions: Sometimes we bring you promotions in association with other companies. If you enter such promotions, the other company will use the information you submit and we provide to them as a data controller in line with their own privacy policies. We shall let you know the precise arrangement at the time you provide your personal information.

Legal basis for processing this data: Consent (if requested) or legitimate interests

Functionality: We may share information about you with suppliers that we engage to help us provide our services and/or functionality of our websites and apps.

Legal basis for processing this data: Consent (if requested) or contract or legitimate interests

Advertisers: We may provide third party advertisers with reports containing aggregate statistical data about our websites’ and apps’ audience to determine the reach of their target audience. This aggregated information may include demographic data such as age range and/or geographic location of groups of our customers.

This aggregated data does not include contact details (such as names, addresses or email addresses) that can be used to personally identify you or contact you.

Legal basis for processing this data: Consent

Facebook insights data: META INCORPORATED (“Facebook”) provides us with statistics and insights (“Page Insights”) that help us understand the use of our Arcvox Facebook Fan Page When you visit or interact with one of our Facebook Fan Pages, we shall process your personal data as joint controllers with Facebook.

Facebook is primarily responsible for the data processing when you visit one of our Fan Pages. However, we use Page Insights and information you provide via your Facebook profile to define our audiences, customise advertisements and create Fan Pages to match the interests of our visitors.

For further information from Facebook about:

• Page Insights and how to exercise your rights, please see here;
• the determination of the responsibilities within this joint controller relationship please see here;
• the placement of cookies by Facebook when visiting a Facebook Fan Page, please see here; and
• protecting your privacy at Facebook, please see here.

Legal basis for processing this data: Legitimate interests

Social media plugins: Some of our websites use social media plugins to help you share content more easily with your friends.

If you do not click on the respective buttons, no personal data will be collected and stored by the social media company.

If you are logged onto to your Google, Facebook, Twitter, Pinterest or Instagram account, certain user data (including your IP address at the time) may be collected and linked to your social media account information by the respective social media company.

We receive no personal data from the social media companies about which articles you have clicked or seen on our websites. However, we do receive summarised, aggregated statistical reports on the use of these plugins.

Legal basis for processing this data: Legitimate interests

Any organisation who has access to your information in the course of providing services on our behalf will be governed by contractual restrictions and/or technical limitations to make sure they protect your information and comply with applicable data protection legislation.

When transferring your personal data outside the United Kingdom (UK) or the European Economic Area (EEA), we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. Where these organisations are based outside of the UK or the EEA in a jurisdiction that has not been deemed adequate by the EU Commission, we shall, if appropriate, enter into EU Commission approved model clauses with these organisations to ensure appropriate safeguards are in place. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

We sometimes work with other organisations and process data collected by them as Joint Controllers. This means that both we, and the other organisation, have responsibilities to process your data in accordance with relevant Data Protection and Privacy laws.  Where this is the case, you may approach either ourselves, or the other organisation, to fulfil any data subject requests in relation to your data. We will process any personal data under this arrangement in accordance with this Privacy Notice.

In certain circumstances, for example if you are a UK or EEA resident, you may exercise the rights available to you (with some exceptions and restrictions) under the UK or the EU data protection laws as follows:

• Access: If you wish to exercise your right to access a free copy of your data, you can contact us, or our joint controllers, at the contact details provided below at Section 17.
• Portability: If you wish to receive personal data that you have provided to us in a structured, commonly used and machine-readable format, or transmit this data directly to another controller, please contact us, or our joint controllers, at the contact details provided below. Please note that this right applies only to the information that is processed by automated means, on the basis of consent or performance of a contract.
• Deletion: To ask us to delete your personal data, please contact us, or our joint controllers, at the contact details provided below. However, there may be circumstances where we are legally entitled to retain certain data.
• Rectification: If you wish to update or rectify your data, you can do this directly by accessing your account settings.
• Restriction: To request the restriction or suppression of your personal data, please contact us, or our joint controllers, at the contact details provided below.
• Revoke consent for direct marketing: If you wish to object to the processing of your data for direct marketing, you can opt-out by updating your settings or clicking on the ‘unsubscribe’ link in any email or newsletter you receive from us.
• Opt-out of online behavioural advertising: You are able to control whether we and our partners may use your information for online behavioural advertising related purposes when you visit our websites via our Consent Management Platform that appears when you first visit our site.
• Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalisation purposes, you can adjust your account settings or contact us directly at the contact details provided below.
• Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party, please contact us, or our joint controllers, at the contact details provided below stating the nature of and reasons for such objection.
• Complain: You also have the right to lodge a complaint about us with your local supervisory authority, for example the Information Commissioner’s Office in the UK.

Exercising Your Rights

To exercise your rights under the GDPR, please contact us, or our joint controllers, at the contact details provided below in Section 17, indicating the type of right you would like to exercise and that you are making the request under the GDPR. In case of requests for deletion, please note there may be circumstances where we are legally entitled to retain certain data (see Section 13 Data retention and account deletion).

We may seek to verify the identity of the person submitting the request.

Where you are making a request via a third party, we need to be satisfied that the third party making the request is entitled to act on your behalf and may ask the third party to provide evidence of this entitlement. If we are satisfied that the third party has the appropriate authority, we will respond directly to that third party.

This section of the Policy applies solely to visitors, users, and others who are residents of the State of California, describes your California Consumer Privacy Act (“CCPA”) rights and explains how you can exercise those rights.

Under the CCPA you have the right to:

• be informed about the categories and the specific personal information that we may collect, the purposes for collecting that personal information, the categories of third parties to whom we may disclose that personal information and whether we disclose personal information for business purposes or for commercial purposes that would be considered a “sale” under the CCPA.

This information is provided in this Policy.

• request to access a copy of the personal information we have collected about you during the 12 months preceding the request.

Upon receipt of a valid and verifiable request from you, we shall disclose to you both the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting that personal information, the categories of third parties which whom we share that information.

You have a right to receive the above twice per year. If we provide the information electronically, it will be in a in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance from us.

• request that we delete any personal information that we have collected from you unless retention of that information is permitted under applicable law.

• opt-out of the sale of your personal information.

Exercising Your Rights

To exercise your rights under the CCPA, please contact us, or our joint controllers, at the contact details provided below in Section 17, indicating the type of right you would like to exercise and that you are making the request under the CCPA. In case of requests for deletion, please note there may be circumstances where we are legally entitled to retain certain data (see Section 13 Data retention and account deletion).

In order to process your deletion and/or access request, we are required by law to collect certain information about you to verify your identity. For example, if you have an account with us, you can use your account information to verify. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used for the purposes of verifying your identity under the CCPA, and for security or fraud-prevention purposes.

A consumer may use an authorised agent to submit a request on their behalf if the consumer provides the authorised agent written permission signed by the consumer. We may also require that the consumer verify their identity directly with us and confirm that they have provided the authorised agent permission to act on their behalf.

We shall not discriminate against you because you have exercised your rights under the CCPA.

Explicit Notice

We and our advertising partners collect personal information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site. We, and our third-party business partners, use this information to tailor and deliver ads to you on our site, or to help tailor ads to you when you visit others’ sites or use others’ apps. To tailor ads that may be more relevant to you, we and/or our partners may share the information we collect with third parties.

If you access this site from other devices or browsers, visit the link below from those devices or browsers to ensure your choice applies to the data collected when you use those devices or browsers. If you use different browsers, devices or platforms, you will need to opt out on each browser, device or platform.

This section describes your rights under the Brazil general data protection law (“LGPD”) and explains how you can exercise those rights.

This section of the Policy applies to:

• Personal data collected in Brazil;
• Personal data processing activities that are carried out in Brazil;
• Personal data processing activities whose purpose is to process personal data of individuals in Brazil; and/or
• Personal data processing activities whose purpose is to offer or provide goods or services to individuals in Brazil.

In certain circumstances, for example if you are a Brazil resident, you may exercise the rights available to you (with some exceptions and restrictions) under the LGPD. Please see Section 10 above for details of the rights of information, access, portability, deletion, correction, revoke consent for direct marketing and opt-out of online behavioural advertising. Also, see Section 10 above for details of how to exercise your rights. Please include in your request that you are making your request under the LGPD.

We store your data for no longer than necessary in relation to the purpose under which such data was collected. This is determined on a case by case basis and depends on things such as the nature of the data provided, why it was collected, the legal basis we rely upon to process the data, and our relevant legal or operation retention requirements. For example, if you request to delete your account, we still have to retain some data for fraud prevention purposes and financial auditing.

Please note that we evaluate deletion requests against our processing for the purposes of journalism, which includes original content and accompanying comments. When we receive a request to delete your personal data from our organisation, we are prepared to anonymise your comments by removing your email address and alias from your public account profile. In doing so, your comments are disassociated with your public account profile and therefore you are no longer publicly identified as the author of your comments. However, we keep your data because we may receive claims for libel and or/defamation in relation to user comments.

Please see our Terms of Use for more information.

Our websites, apps and other products and services are not aimed at children. We do not intentionally target, or otherwise process information from individuals who are under the age of 16.

We do not create interest segments specifically designed for the purpose of online behavioural advertising to children who are under the age of 16.

You must be at least 16 years of age to consent to online behavioural advertising via your Privacy Settings. If you are aged under 16, please ask for permission from your parent or guardian before giving us your information orusing our website.

If you are a parent or guardian of a child under 16, please contact us, or our joint controllers, if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. We shall delete or otherwise cease processing your child’s personal information within a reasonable time.

In accordance with industry best practice guidelines, we may retain your information for a reasonable amount of time to make sure that we do not contact you in the future.

When you use our website or interact with our emails, we may collect information using cookies or similar technologies. We may also collect information using your email address. For the purposes of this section, we use the word “cookies” for simplicity.

What are cookies and how do they work?

Cookies are small files that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you. This allows websites to tailor what you see on the screen.

Do you use other technologies which are similar to cookies?

Yes, we use the following:

• Web beacons: Our websites, apps and emails often contain small invisible images known as “web beacons” or “tracking pixels”. These are used in a way similar to cookies to:
  • understand when a particular part of a webpage, email or app is viewed;
  • understand how successful an article or an email marketing campaign has been; and
  • verify any clicks through to links or advertisements contained in emails.
• Tracking URLs: These are web links that allows us to measure when a link is clicked on. They help us measure the effectiveness of campaigns and advertising and the popularity of articles that are read.
• Device identifiers: We use device identifiers on mobile devices in the same way as cookies are used on web browsers. A device identifier is a unique number on your device which allow us to remember your device.

We use these similar technologies on websites, emails and apps, for the same purposes and in much the same way as we use cookies on websites. We shall use “cookies” and “websites” below as shorthand for “cookies and similar technologies” on “websites, emails and in apps”.

What do you use cookies for?

Cookies and other online tracking technologies are an important part of the internet. They make using websites much smoother and affect lots of the useful features of websites.

There are many different uses for cookies, but for within our sites, they fall into the following groups:

Cookies that are needed to provide the service you have asked for (Essential / Strictly Necessary)

Some cookies are essential so you can move around our websites and use their features. Without the use of these cookies parts of our websites would not function. For example:

• your username and keeping you logged in during your visit – without cookies you might have to log in on every page you go to; and
• when you add something to the online shopping basket, cookies make sure it is still there when you get to the checkout. 

Cookies that collect information about your choices and preferences (Functional / Preference)

These cookies collect information about your choices and preferences, and allow us to remember things like:

• remembering a location you’ve provided us with so we can show you relevant content to where you are and to provide local weather forecasts;
• if you have filled in a survey, so you’re not asked to do it again; and
• showing “related article” links that are relevant to the page you are looking at.

Cookies used to understand how people use our products and services (Analytics)

We use analytics cookies to gather information about what pages, links and sections of our apps are popular and which ones do not get used so much to help us keep our sites relevant and up to date. They are also useful to be able to identify trends of how people navigate our sites so we can identify improvements to make to the customer journey.

We may combine information collected by analytics cookies with other information that you provide to us. For instance, if you have registered for an account with us, we may combine your contact details other information you provide us with the browsing history from your device collected by analytics cookies (including data collected from before you registered and when you are signed-out).

We may also use this combined information to improve our products and services. For instance, we may analyse this information in aggregate to improve our advertising systems.

Cookies used to show advertising that is relevant to you (Tracking and Advertising)

Some advertising, known as “online behavioural advertising” is tailored to you and uses information collected by first party and third-party cookies based your web browsing activity.

Cookies are placed on your browser to remember the websites you have visited. Also, when you log into your account, we can recognise your UID. Advertising based on what you have been looking at is then displayed to you when you visit websites who use the same advertising networks.

To help us deliver relevant advertising using cookies, we use Google Marketing Platform. Click here to find out more about Google Marketing Platform.

Additionally, to help us deliver relevant advertising using cookies and track audience conversion, we may use Facebook Ads. You can find more information about Facebook Ads here.

We also use these cookies in order to:

• know how many advertisements we serve, how many times these are clicked or hovered over with a mouse cursor, how many advertisements we show to a given user and how many customer actions these generate;
• understand which customers reach a sale or other action page on an advertiser’s site. This allows us to monitor how many sales or actions we achieve for an advertising client, and therefore, how effective our advertising is;and
• protect our advertisers’ brands, we often use a technology that scans the page to ascertain that it is safe from profane, sensitive and potentially brand-negative topics, before serving an ad there. This process is called “ad verification”.

Ad-blockers: We and our advertisers may use information from within our webpages to determine whether you have an ad-blocker enabled. This information may be stored or associated with your device (including through the use of cookies) to re-insert advertisements on our websites and to understand how our customers use ad-blockers. The advertisements that are re-inserted may include those from ad-blockers’ “white lists” or thatpromote our own products and services. We reserve the right to restrict your access to some or all of our website while you have an ad blocker turned on.

Do Not Track: Our websites do not respond to “Do Not Track” browser settings.

Cookies can be controlled using the following instructions:

• Mobile Devices: When using a mobile device, you can opt-out of receiving online behavioural advertising by selecting “Limit Ad Tracking” in the Settings of your Apple iPhone or iPad, or the “Opt out of interest-based ads” in the Settings on your Android device. You may also be able to reset your unique identifier used for online behavioural advertising (referred to as an “ Advertising ID”) in the Settings on your Apple or Android device.
• Online Behavioural Advertising cookies: If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to Your Online Choices.
• You can also visit the trade body representing these advertising platforms where you can control your third-party online advertising preferences by going to the Network Advertising Initiative.
• Browsers: The links below take you to the help sections for each of the major browsers that will tell you how you can manage your cookies:
  • Firefox
  • Internet Explorer
  • Microsoft Edge
  • Chrome
  • Safari (Mac)
  • Safari (iOS)
  • Android
  • Blackberry
  • Windows Phone

Please note that our website, apps and other products and services may not work correctly (or at all) if you change certain preferences. For example, you may not be able to purchase products via our websites. However, you may still be able to place an order via our telephone order line.

Where you use our apps, similar technologies to cookies are used for analytics, it is not presently possible to opt-out of these similar technologies. If you are not happy to be included in our analysis, please do not use our apps.

Please also note that after applying these settings, you will continue to receive advertising, however, it may not be tailored to your likely interests using information collected from cookies and similar technologies on your device.

We reserve the right to make changes to this Policy. Where changes are made, we shall post the revised Policy here with an updated effective date. Please check regularly for any changes to this Policy.

If you have any queries or comments about this Policy or wish to exercise any of your rights under the UK GDPR, the EU GDPR, the CCPA or other laws, we encourage you to contact us.

Alternatively, you can write to us at:

Premier Digital Group Ltd
2 Longboat Lane
Stourport on Severn
Worcestershire
United Kingdom

You can also contact us at: gdpr@arcvox.com