Return-Path: Delivered-To: costa4@lisaweb.svrsh.com Received: from lisaweb.svrsh.com by lisaweb.svrsh.com with LMTP id qJarJFXM8WaqGy4AePtdKg (envelope-from ) for ; Mon, 23 Sep 2024 22:15:17 +0200 Return-path: Envelope-to: info@elettroservicegroup.it Delivery-date: Mon, 23 Sep 2024 22:15:17 +0200 Received: from sd97.btc-net.bg ([212.39.90.97]:37579) by lisaweb.svrsh.com with smtp (Exim 4.97.1) (envelope-from ) id 1sspSJ-0000000CsRM-3aii for info@elettroservicegroup.it; Mon, 23 Sep 2024 22:15:17 +0200 Received: (qmail 26917 invoked by uid 605); 23 Sep 2024 20:13:58 -0000 Received: from unknown (HELO cloud-prime-nl0.openstacklocal) (46.10.75.242) by 0 with SMTP; 23 Sep 2024 20:13:58 -0000 Content-Type: multipart/alternative; boundary="===============0883593932==" MIME-Version: 1.0 Subject: Hai vinto un kit di emergenza per auto To: Recipients From: Dipartimento Telepass Date: Mon, 23 Sep 2024 13:13:16 -0700 X-Spam-Status: No, score=1.5 X-Spam-Score: 15 X-Spam-Bar: + X-Ham-Report: Spam detection software, running on the system "lisaweb.svrsh.com", has NOT identified this incoming email as spam. The original message has been attached to this so you can view it or label similar future email. If you have any questions, see root\@localhost for details. Content preview: Gentile cliente Telepass, Speriamo che tu stia bene. Vogliamo farti partecipe di un'opportunità esclusiva: hai la possibilità di ricevere gratuitamente un nuovissimo Kit di emergenza per auto! Basta rispondere a un breve so [...] Content analysis details: (1.5 points, 5.0 required) pts rule name description ---- ---------------------- -------------------------------------------------- 0.0 RCVD_IN_VALIDITY_SAFE_BLOCKED RBL: ADMINISTRATOR NOTICE: The query to Validity was blocked. See https://knowledge.validity.com/hc/en-us/articles/20961730681243 for more information. [212.39.90.97 listed in sa-accredit.habeas.com] 0.0 RCVD_IN_VALIDITY_RPBL_BLOCKED RBL: ADMINISTRATOR NOTICE: The query to Validity was blocked. See https://knowledge.validity.com/hc/en-us/articles/20961730681243 for more information. [212.39.90.97 listed in bl.score.senderscore.com] 0.0 URIBL_BLOCKED ADMINISTRATOR NOTICE: The query to URIBL was blocked. See http://wiki.apache.org/spamassassin/DnsBlocklists#dnsbl-block for more information. [URI: ninoslojainfantil.com.br] [URI: behance.net] [URI: ico.org.uk] [URI: geni.us] [URI: independent.co.uk] [URI: liveramp.com] [URI: transparentadvertising.eu] 0.0 URIBL_DBL_BLOCKED_OPENDNS ADMINISTRATOR NOTICE: The query to dbl.spamhaus.org was blocked due to usage of an open resolver. See https://www.spamhaus.org/returnc/pub/ [URI: ninoslojainfantil.com.br] [URI: mir-s3-cdn-cf.behance.net] [URI: ico.org.uk] [URI: buy.geni.us] [URI: help.independent.co.uk] [URI: liveramp.com] [URI: www.independent.co.uk] [URI: www.transparentadvertising.eu] 0.0 RCVD_IN_ZEN_BLOCKED_OPENDNS RBL: ADMINISTRATOR NOTICE: The query to zen.spamhaus.org was blocked due to usage of an open resolver. 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[212.39.90.97 listed in sa-trusted.bondedsender.org] -0.0 SPF_PASS SPF: sender matches SPF record 0.0 KAM_DMARC_STATUS Test Rule for DKIM or SPF Failure with Strict Alignment 0.2 MARKETING_PARTNERS BODY: Claims you registered with a partner 0.0 HTML_MESSAGE BODY: HTML included in message 0.0 HTML_FONT_LOW_CONTRAST BODY: HTML font color similar or identical to background 0.5 KAM_EU RAW: Prevalent use of .eu in spam/malware 0.8 KAM_INFOUSMEBIZ Prevalent use of .info|.us|.me|.me.uk|.biz|xyz|id|rocks|life domains in spam/malware 0.0 KAM_SHORT Use of a URL Shortener for very short URL X-Spam-Flag: NO You will not see this in a MIME-aware mail reader. --===============0883593932== Content-Type: text/plain; charset="utf-8" MIME-Version: 1.0 Content-Transfer-Encoding: quoted-printable Content-Description: Mail message body = = = Gentile cliente Telepass, Speriamo che tu stia bene. Vogliamo farti partecipe di un'opportunit=E0 = esclusiva: hai la possibilit=E0 di ricevere gratuitamente un nuovissimo Kit= di emergenza per auto! Basta rispondere a un breve sondaggio sulla tua rec= ente esperienza con Telepass. Ti invitiamo a sfruttare questa opportunit=E0, poich=E9 l'offerta scade = tra 24 ore. = Partecipa al sondaggio ora! = Ti ringraziamo per la tua collaborazione e speriamo che tu possa godere app= ieno del tuo nuovo Kit di emergenza per auto. Distinti saluti. = Privacy Policy Contents Introduction What personal information do we collect about you? What do we use your personal information for? Our legal basis for using your personal information How can you access and update your personal information? How long do we keep your personal information for? Who do we share your personal information with? Using children=2019s personal information Will my information be sent overseas? How we may contact you Your data rights Information for California residents Exercising your rights, asking questions and raising concerns Contact details for exercising your rights, asking questions and raising c= oncerns Introduction At The Independent we respect your privacy and are committed to protecting= your personal information. This privacy policy is for visitors to our webs= ites, apps and other digital platforms. It sets out how we collect, use, di= sclose, and protect personal data that we hold about you. It also gives inf= ormation on how to exercise your legal rights. In this policy =2018we=2019 = and =2018our=2019 means Independent Digital News and Media Limited. There are now two ways to read our content. Either you can choose to conse= nt to us using your data to serve you targeted advertising, or alternativel= y we offer the choice to read our content ad free and without advertising t= racking cookies enabled, by paying for a subscription. The majority of The Independent=2019s articles are free to read if you con= sent to us processing your personal data for advertising purposes. That mea= ns when you provide us with your personal data, you allow us to improve you= r experience of our products and services as well as helping to support our= quality independent journalism. You can withdraw your consent at any time by clicking on the =2018Privacy = Settings=2019 in the footer of any page. If you do withdraw your consent, t= he cookie banner will appear again and you will be asked to choose how you = would like to browse The Independent. Personal information is any information that can identify you and can incl= ude: = Your name, email address, and year of birth, home address (if you=2019ve as= ked us to send something to your home address). = Information about your device (your computer, mobile, tablet etc). For exam= ple your unique device ID, advertising ID, type of browser, and IP address.= An IP address is a numerical code which identifies your device. It can pro= vide information about the country, region or city where you are based. = How you browse our websites, such as the pages you visit and links you clic= k on. = Details of products or services you buy, for example a subscription to The = Independent. = Debit or credit card details if you buy a product or service (these are col= lected via a secure third party payment provider and are not held on our sy= stems). = When we refer to =201Cpersonal information=201D in this policy, we are ref= erencing =201Cpersonal data=201D as defined under UK and EU data protection= law, as well as =201Cpersonal information=201D as it is defined under Cali= fornia law. What personal information do we collect about you? We collect your personal information in one of the following ways, in line= with the relevant data protection laws: = Information you give us e.g. when you register for an account, comment on a= n article, purchase a product or service or download one of our apps on you= r mobile device. = Information from your devices when you visit our website or app through the= use of cookies and similar technologies e.g. device type and ID, advertisi= ng ID and IP address. = Information we generate about you e.g. we give you a unique ID to remember = you when you=2019re logged in. = Information we receive about you from other organisations, including social= media logins. = More information about this is set out below. What do we use your personal information for? 1) Personal information you provide directly to us. When you register for an account to read Premium articles. If you want to receive a select number of Premium articles a week you will= need to register for an account. We will ask for your first name, email ad= dress, password and year of birth. Readers under the age of 18 should not r= egister for an account. When you comment on our website If you plan to comment on our website, you will need to register for an ac= count and provide us with a commenting name. When you comment publicly on a= n article on our site, we would recommend you don=2019t share any sensitive= personal information. We are not responsible for the information you choos= e to post online. Please see a link to our Community Guidelines on commenti= ng here. When you take out a subscription or attend an event If you are subscribing to one of our paid-for products, in addition to you= r name, email address, password and year of birth, you will also need to pr= ovide your billing address and payment card information. Your payment detai= ls are not held on our systems. Instead they are handled by a secure, trust= ed third party provider. We may also collect this information if you attend one of our paid-for tic= keted events. If you attend one of our virtual events, we will share your full name, pre= fix and email address with the platform hosting the event. We may share you= r company name but only if you choose to provide this. When you contact Customer Services with a query If you contact our Customer Services team by email, we receive your name, = email address and details of your query. If you telephone us, we receive yo= ur telephone number and name. Please do not provide sensitive information u= nless you=2019re happy for us to use it in response to your query. When you sign a petition When you click on a link to sign a petition relating to an Independent Cam= paign, you will be taken to a third party site. We are not responsible for = the data you share with the third party, and we do not receive any of the i= nformation. Please check the third party=2019s privacy policy for more info= rmation on how they use your data. You may be given the opportunity to opt in for further communications abou= t the petition you have signed, other petitions you may be interested in or= to receive emails from us related to updates or events at The Independent.= We will only process your information in this way where you have given us = your permission. When you purchase products and services from third parties We may also collect information about third party products and services wh= ich you purchase after visiting our website. For example, when you use a vo= ucher code or click on a link to an affiliate site. However when you click = on one of these affiliate links we don=2019t receive any personal data abou= t you, and we cannot link back the purchases to you specifically. Instead w= e receive aggregated, anonymous information such as which products have bee= n bought by our readers and how many of them. 2) Information from your devices Cookies and other online identifiers We collect data about our website=2019s visitors using technology such as = cookies, device IDs, IP addresses and general location or country. This may= include your IP address, information about your browser or operating syste= m and will include your email (only ever in secure =2018hashed=2019, pseudo= nymous form). If you would like to know more about our use of cookies and h= ow to manage them, please read our Cookie Policy. If you have purchased one of our subscriptions, this next section does not= apply to you. If you accept the use of advertising cookies on our website,= then when you use our website and enter your email address on our website = (either to log in, or to sign up for a newsletter, or similar), we may shar= e information that we collect from you with trusted partners. This may incl= ude your IP address, information about your browser or operating system or = your email (only ever in secure =2018hashed=2019, pseudonymous form). Our p= artners use this information to create an online identification code to be = able to recognise you on your devices. This code may be shared with adverti= sing companies to enable interest-based and targeted advertising, that is m= ore relevant to you. This code does not contain any of your directly identi= fiable personal data and will not be used to re-identify you. We and the be= low partners process your data to create this code as joint controllers und= er data protection law. Detailed information on our partners=2019 data processing activities is av= ailable in their privacy policies by clicking below. LiveRamp To opt-out of your data being used by LiveRamp in this way, please visit h= ttps://liveramp.com/opt_out/ Trade Desk To opt out of your data being used by The Trade Desk in this way, please v= isit https://www.transparentadvertising.eu/ When you enter your email address to create an account or sign-up to a new= sletter or marketing, we may also share your email address in a hashed form= with Amazon Publisher Services (APS). APS then links this hashed email to = a profile which they may already hold related to that email address. The ha= shed email will be used in a secure, pseudonymised form within a cookie to = flag to APS whenever you visit The Independent site. APS will use this to d= etermine, in real-time, if any of their business customers want to market t= o a profile similar to yours. If this is the case they may initiate an adve= rt which will appear to you on The Independent website. The APS Privacy Notice can be found here: https://aps.amazon.com/aps/priva= cy-policy/ Please see our Cookie Policy for more information. We are signed up to the latest version of IAB Europe=2019s Transparency an= d Consent Framework (TCF) version 2.2 and comply with its specifications an= d policies. What this means is that we treat the personal information that = we and our partners collect through cookies in a transparent and data priva= cy compliant way. Market research, user testing panel and surveys From time to time we may ask you to participate in reader surveys, to help= us improve our website and offering. Usually these will be anonymous, howe= ver if you choose to be contacted for future market research, we will ask f= or your name and contact information so we can get in touch with you. We wi= ll keep your personal data for only as long as we need it, after which we w= ill delete it. We use a third party survey provider for running our surveys, and we keep = your data in the third party platform for three months to enable us to anal= yse your responses, after which we aggregate your responses and delete your= personal data so it can no longer identify you. We may ask you to attend face-to-face Zoom interviews with us or a partner= that we have commissioned on our behalf. However, participation is volunta= ry and you are free to decline the invitations at any time. We may also sen= d you links to short surveys and your responses to these surveys will be an= onymous. If you agree to be a part of the panel, we will re-contact you aft= er a year to ask if you wish to continue to be a part of the panel and give= you a chance to opt out. We may use the feedback you provide in our surveys or as part of our user = testing panel, as quotes on our website, or in internal and external presen= tations in connection with the research study and our publications. However= where we do this we will ensure that the quote is anonymous =2013 unless y= ou give us your permission to use your name, photograph or screenshots of y= ou during any Zoom interviews. 3) Information we generate about you. When you register for an Independent account, take out a subscription for = The Independent or sign up for one of our newsletters, we assign you a uniq= ue ID number. We use your unique ID to recognise you when you are logged in= . We also use it to ensure we remember your preferences such as which newsl= etter you have signed up to. For readers who have not registered or subscribed, and are browsing our si= te anonymously, we assign you a unique ID number based on your device which= remembers your browsing behaviour. This ID cannot identify you unless you = then register or subscribe, after which we will link your anonymous browsin= g behaviour to your ID. This is so we can offer you a more personalised and= engaging experience when you register or subscribe. We also assign you a unique ID number which remembers your browsing behavi= our. This includes how long you spend on an article, what types of articles= you read (e.g. travel, politics, sports and so on) and how many, as well a= s how often you visit our website or app. This is so we can personalise the= site and our communications to you, and where you have consented to this, = we also deliver tailored advertising that is more relevant to your interest= s. We provide each reader with a cookie ID for analytics purposes, so we can = recognise when you come back on to our site using one of your devices such = as your laptop or mobile phone. We do this so we know how many individuals = come back to our site. 4) Data we receive about you from other organisations. Sometimes we obtain additional information about you from data management = and consumer insight providers, such as Eyeota. The data these companies may hold about you is collected from publicly ava= ilable records, such as the electoral roll, or from other sources where you= have agreed for your information to be shared with third parties. We may then match you with the data that they hold in their database to fi= nd out demographic or household information about you. This ensures that th= e advertising you see is relevant if you consent to this. Social media We can also access limited information from social media activity such as = when you =2018like=2019 the website, share content or follow us on Twitter = or Facebook. When you sign in to our website using Google, we collect your = name and email address. If you sign up for one of our newsletters on Facebo= ok, we receive your email address so we can send you the newsletter you= =2019ve asked for. We may also receive demographic information from social = media sites such as Facebook, including aggregated information on age and g= ender. However this cannot be linked back to you individually. This is used= to tailor the advertising we show you if you=2019ve agreed to receive pers= onalised advertising. We use personal data collected through our sites and apps only when we hav= e a valid reason and the legal grounds to do so. The legal grounds may be o= ne of the following: Consent. If you have given us consent to send you specific newsletters, you can uns= ubscribe from these at any time. You can do this by clicking =2018unsubscri= be=2019 at the bottom of each email (and additionally at the top of emails = if you use Yahoo or Gmail), or by logging into your account and managing yo= ur email preferences. We only conduct market research and send you surveys if you have consented= to this. We will send you push notifications from our apps, and/or send you browser= notifications when you are visiting our app or website, only where you hav= e consented. We will only process your data for marketing purposes to inform you about = our products, services or promotional offers that you might find interestin= g where you have consented to this. Unless you have purchased one of our subscriptions, you will be required t= o provide your consent to us processing your personal data for targeted adv= ertising in order to access our content. The remaining paragraphs of this s= ection apply to such non-subscribers. We may tailor advertising you see on our website based on the type of arti= cles you read, so it is more relevant to your interests. We do this by allo= cating your ID to relevant interest groups or segments based on your readin= g behaviour. For example, if you have read three articles about travel or c= ommented on a travel article in the last 30 days, or if you have visited a = travel website prior to coming onto our website we may place your ID into t= he travel segment, and you will subsequently be shown more travel-related a= dvertising. If your reading behaviour is similar to that shown for our trav= el audience, we may include your ID in our =2018lookalike=2019 travel segme= nt for some campaigns. We will never use any sensitive data (also known as special category data)= for this purpose. Please read our Cookie Policy for more information about= this. We may personalise advertising to you based on the information that you pr= ovide us when you register for an account. For example, we may aggregate yo= ur age (based on year of birth that you provide us when you register) into = groups e.g. 24-35 year olds, if an advertiser would like to target their ad= campaigns to this demographic. As well as using your online browsing behav= iour and your demographic information to personalise the advertising you re= ceive, we may also use this aggregated information for reporting and analyt= ics purposes. For example, to see how well a particular ad campaign has per= formed. We occasionally work with advertising partners to securely match the email= addresses of our registered reader database with their customer databases,= using our data matching service provider. This is so we can show ads to re= aders we and our partners have in common. All data is encrypted before it i= s matched, and neither party can directly identify an individual, nor see o= r access the other party=2019s data. The data match service provider does n= ot have access to any raw, unencrypted data. Generally, this will be conducted at an aggregate audience level to provid= e insights, rather than individual level information, although your informa= tion may be used to generate these insights. These insights might include t= he overlap between our audiences and the client=2019s, and other informatio= n that would be useful to understand for an advertising campaign to be effe= ctive. For readers in California, Colorado, Connecticut, Utah and Virginia, if yo= u click the =201CDo not share/sell my personal information=201D button, whi= ch is in the website footer at the bottom of the home page, we will not rec= ontact you about that choice for at least 12 months. Legitimate interests. Legitimate Interests are ways in which we use personal data that you would= reasonably expect. These include: = Sending you service messages about your subscription or account registratio= n, for example if you have clicked a password reset link. This could be by = email, overlay on the website or push notification (if you=2019ve consented= to receiving app push or web browser notifications). = Granting you access to a subscription. = Dealing with any query or complaint you submit to our Customer Services tea= m. Only provide sensitive data when relevant (such as information about you= r health, race or religion) if you are happy to consent to our using it to = manage your enquiry. = Dealing with, and responding to you about queries in the comment section an= d other user generated content facilities. = Logging and using information about any service errors or interruptions tha= t you have experienced in order to help us create fixes and to make technic= al improvements to our website. = Security and fraud prevention. = Verifying your identity and remembering you (for example when you return to= the website and have already logged in). = Enabling you to share our content with others using social media or email. = Administering competitions and informing you if you have been successful in= any competitions or promotions. = Keeping you updated about our products and services, in line with your comm= unication preferences. = Monitoring the number of Premium articles you read as a registered user on = The Independent website. This is so we can request users subscribe once the= y have read the maximum number of Premium articles over a given period of t= ime. = Monitoring the number of articles you read on The Independent app. This is = so that we can request users subscribe once they have read the maximum numb= er of articles on the app. = Analysing what articles you have read so we can improve our content and mak= e recommendations to you. = Improving the design and style of the website. = Responding to your feedback on our products, services and website and app f= unctionality = Ensuring that we are paid the correct amount of commission by our advertisi= ng partners if you buy a product or service from our website. = Allowing us to measure advertising campaigns, ensure readers do not see the= same advertisements too many times, and ensure advertisements are served i= n appropriate environments for our clients. = Performance of a contract. When you buy a subscription or another product or service from us, we will= need to use your details in order to provide the item to you. For example,= in order to deliver a product to your home, you will need to give us your = name and address. Compliance with our legal obligations. In some cases, we may have a legal or regulatory obligation to use or keep= your personal data. How can you access and update your personal information? If you are a registered user or subscriber, you can update your personal i= nformation by signing in to your account page. In all other cases, please c= ontact Customer Services. You can also ask for a copy of the personal information we may hold about = you, or for your data to be deleted via the above Customer Services form. If you wish to contact us by telephone, our number is 0203 615 2990. How long do we keep your personal information for? We will keep your information only for as long as it is relevant and usefu= l for the purpose for which it was originally collected. If your account appears to have not been used for two years, we will try a= nd contact you to check whether it is still in use and/or we will delete it= . Please note that any comments associated with your account will also be d= eleted. If you do not read the newsletters that you have subscribed to, we will su= ppress your name from the relevant list after six months. If you purchase a subscription, we will retain your data for at least 12 m= onths after your subscription ends in case there are any outstanding billin= g or other customer service issues. A record of a customer service query is retained for at least three years = from the date it was submitted to us. We retain cookie data and corresponding third party data for 13 months fro= m when it was collected from your device. For more information about cookie= s, please read our Cookie Policy. We may need to retain your data for a longer period if there is a legal cl= aim or if we are required to so by any regulation. We may also retain your = personal information to ensure we do not contact you if you have asked us n= ot to. We are fully committed to keeping your personal information safe and we ta= ke measures to protect your personal information from unauthorised access, = disclosure, alteration, or destruction. However, as you will appreciate, no= data transmission or storage system can be guaranteed as 100% secure. Who do we share your personal information with? Sharing with the Group=2019s companies We may disclose your personal information to our sister companies: Indepen= dent Digital News and Media LLC and Evening Standard Limited. Voucher code partner We offer our readers voucher codes in collaboration with Savings United Gm= bH. We and Savings United are both responsible for any personal data you pr= ovide or that we collect while you visit www.independent.co.uk/vouchercodes= . We must both comply with data protection laws. If you have any questions = or concerns about how your data is being used in relation to Voucher Codes,= in the first instance please email: contact@savings-united.com. Advertising partners If you consent to the use of advertising cookies on our website, advertise= rs and advertising agencies sometimes require data to select and serve rele= vant advertisements to you based on your onsite behaviour e.g. whether you= =2019ve clicked on an ad and are re-targeted with another ad from the same = advertiser. We may also provide them with audience demographics about an au= dience who viewed or interacted with a campaign. For more information on what personal data we collect and how we use it, p= lease refer to the sections above =2018What personal information do we coll= ect about you?=2019 and =2018What do we use your personal information for?= =2019. Government or regulatory bodies only if required by law We reserve the right to disclose your personal information to comply with = applicable laws and government or regulatory bodies=2019 lawful requests fo= r information. Our service providers Your personal details may be shared with third party organisations we have= contracted to provide services to us which include processing data. For ex= ample, to send you the emails you have signed up for, to process your payme= nt information when you buy a product or service, or for other purposes as = described in this policy. Only companies who can provide adequate safeguard= s will be used to ensure your data is stored and handled securely. And we h= ave contracts in place with these providers to make sure that they only use= information in ways we have instructed them to, and to protect your data a= nd comply with applicable law. Transfer as part of the sale of our business We may transfer, sell or assign any of the information described in this P= rivacy Policy to third parties as a result of a sale, merger, consolidation= , change of control, transfer of assets or reorganisation of our business. Agencies and authorities because of a legal requirement We may also have to release information because of a legal requirement on = us or pursuant to a court order. Using children=2019s personal information We do not aim our services to children under the age of 13. We do not allo= w children under 18 to register an account with us. Will my data be sent overseas? As you will know, the internet does not recognise national boundaries. Ser= vices on the web are accessible globally so collection and transmission of = personal data is not always confined to one country. You should be aware that by using the website and those of our partners or= any website we link through to, your personal data may be processed in or = transferred to other countries, the USA for example, and you agree to your = personal data being transferred or processed in this way. Your personal data will only be stored or transferred within the UK, EEA, = US or other countries using Standard Contractual Clauses, or other safeguar= ds that have been approved by the relevant regulatory body. If you are located in the UK or the EEA, you may contact us for a copy of = the safeguards which we have put in place for the transfer of your personal= data outside the UK or the EEA. How we may contact you We will contact you in accordance with your preferences. From time to time= we may contact you by email or browser or app push notification to give yo= u service information. For example, if your subscription is changing, or yo= ur payment method has expired. You will not be able to opt-out from receivi= ng these service messages unless you no longer wish to use the services. If we have your permission we may also send you newsletters or emails abou= t our events, subscription benefits or new launches and website development= s. You can manage your preferences and subscriptions to newsletters and email= s by signing into to your Independent account. You can also unsubscribe at = any time by clicking the link in the footer of the email (or also at the to= p of emails if you use Yahoo or Gmail). When you unsubscribe from marketing= emails, we will add your email to a list to make sure we don=2019t send yo= u any marketing information going forward. For more help on managing your a= ccount, visit our help centre. Occasionally we may ask you if you would like to participate in market res= earch or respond to you if you have made a complaint or have logged a query. Your data rights: Right of access =2013 you can ask for a copy of the data that we hold abou= t you. Right of rectification =2013 you can ask us to correct data that we hold a= bout you that is inaccurate or incomplete. Right to be forgotten =2013 you can ask for the data we hold about you to = be erased from our records. Right to restriction of processing =2013 you can ask for us to restrict th= e way we use your data. Right of portability =2013 you can ask for us to transfer the data we hold= about you to another company. Right to object =2013 you can object to us using your data where we are re= lying on a legitimate interest to use it. Right to withdraw your consent =2013 you can withdraw your consent at any = time. Please note that these rights are not absolute and certain may exemptions = apply. For more information about these rights, please visit the ICO=2019s = website at: https://ico.org.uk/for-the-public/. We will respond to your requests within one calendar month as per our stat= utory obligations. We may ask for proof of identity to be able to proceed with your request i= n order to meet our data protection obligations. We do not usually charge f= or making a request, but we may charge a fee in accordance with the relevan= t laws in certain circumstances. Please note the Independent is a media organisation and publisher. This me= ans we may be subject to certain exemptions under data protection law when = we process personal data for the purposes of journalism. These exemptions a= pply to some of the ways the Independent uses personal data. This privacy p= olicy does not cover personal data that the Independent processes for the p= urposes of journalism. Information for California residents Categories of personal information (PI) collected, along with examples of = PI and the purpose of collecting PI are set out below: Identifiers Examples: e.g. name, contact information including email address, postal a= ddress, phone number, online identifiers, IP address. You provide this directly to us when registering or taking out a subscript= ion. We also obtain this from partners, service providers or public sources. Purpose: To register or subscribe to the Independent, to manage your accou= nt; respond to your inquiries or requests and communicate with you; to send= you email newsletters and push notifications if you choose to receive thes= e; running our events; providing customer services; verifying customer info= rmation; administering competitions, customisation of ads to make the adver= tising on our sites more relevant. Internet or other electronic network activity information Examples: Browsing history, search history, geolocation data and informati= on regarding your interaction with website, app, or advertisement =2013 thr= ough use of cookies or similar technologies. Purpose: Personalising our site and advertising to make it more relevant t= o you, marketing and promoting products and services, tailoring our communi= cations to you, improving our understanding of readers to ensure the best c= ontent and services Personal Characteristics Examples: In some circumstances, we may collect PI that is considered prot= ected under U.S. law, such as age and gender. We abide by the legal require= ments imposed under applicable law in regard to such information. You eithe= r provide this to us or we infer it from information we hold about you. Purpose: We use this to serve you advertising campaigns that are more tail= ored to you and for third parties to be able to measure the effectiveness o= f their ads. We also ask for year of birth information as we do not want ch= ildren under the age of 18 to register for an account. Commercial Information Examples: Records of purchase history and transactions. Purpose: Fulfilment of orders, answering customer service queries. Professional or employment-related information Examples: e.g. job title; industry; company =2013 either directly from you= if you choose to provide it or from publicly available sources or service = providers or partners Purpose: To enable us to work and communicate with our industry partners, = recruitment. Inferences from personal information collected Examples: Inferences drawn from any of the personal information listed abo= ve to create a profile or summary about you, reflecting your preferences, c= haracteristics, behaviours. Purpose: Personalising advertising to make it more relevant to you, market= ing and promoting products and services, tailoring our communications to yo= u. Categories of third parties we may disclose personal information to: = Service providers who assist us in operating our business and delivering ou= r services = Advertising and marketing partners = Legal authorities or regulators when required by law or to protect our lega= l rights = We may disclose your personal information to our sister companies: Independ= ent Digital News and Media LLC and Evening Standard Limited. = California Shine the Light Law Subject to certain limitations, California residents may ask us to provide= them with: = A list of certain categories of personal information that we have disclosed= to third parties for their direct marketing purposes during the immediatel= y preceding calendar year, and = The identity of those third parties. = To make this request, California residents may contact us at Customer Serv= ices. For such requests, indicate =201CCA Shine the Light Request=201D in t= he subject field of your request. Your rights under the California Consumer Privacy Act as amended (CCPA) Right to know =2013 you can ask (up to twice in a 12-month period) for the= personal data we may hold about you for the past 12 months. You can also request: = The categories and/or specific pieces of personal information we have colle= cted about you = The categories of sources for that personal information = The purposes for which we use that information = The categories of third parties we disclose your information to, and = The categories of information that we sell or disclose to third parties. = Right to delete =2013 you can ask us to delete the personal data we collec= t about you (with some exceptions, such as if we are legally required to ke= ep the information). Right to opt-out of the sale or sharing =2013 you have the right to opt-ou= t of the sale or sharing of personal data we may hold about you. You can ex= ercise this right at any time by pressing the =201CDo not Sell or Share My = Information=201D link in the footer of every page on our site. If you click the =201CDo not Sell or Share My Information=201D link, we wi= ll not recontact you about that choice for at least 12 months. Right to correct your personal information =2013 you can ask us to correct= inaccurate personal data that we may hold about you. Right to limit the use and disclosure of sensitive personal information co= llected about you =2013 you can ask us to only use your sensitive personal = information for purposes such as providing you with the services you have r= equested. We do not collect sensitive personal information unless you provi= de this to us. Right to non-discrimination for exercising your rights =2013 we will not d= iscriminate against you for exercising any of your privacy rights. We may ask for proof of identity for verification purposes, such as your n= ame, e-mail, phone number and/or account information. We will review the in= formation provided and may request additional information via e-mail or oth= er means to ensure we are interacting with the correct person. To help us r= espond appropriately, please specify that you are making a request under th= e California Consumer Privacy Act or CCPA. You may also use an authorized agent to make requests to exercise your rig= hts under CCPA as described above. We will take steps both to verify your i= dentity, and to verify that your agent has been authorized to make a reques= t on your behalf through providing us with a signed written authorization o= r a copy of a power of attorney. We endeavour to respond to a verifiable request within 45 days of its rece= ipt. If we require more time (up to 90 days), we will inform you of the rea= son and extension period in writing. Please note that some of these rights are not absolute and exemptions may = apply in certain circumstances. Exercising your rights, asking questions and raising concerns If you have any queries or comments about this privacy policy, or you woul= d like to make a request, please contact us using our online form available= here: Customer Services. If you=2019re unhappy with how we=2019ve handled your data or your request= , please get in touch with us in the first instance using our online form: = Customer Services. You may also get in touch with our Data Protection Offic= er. Their contact details are in the table below. If you=2019re still not s= atisfied with our response, you have the right to complain to the Informati= on Commissioner=2019s Office (ICO) whose contact information is also provid= ed in the table below. Contact details Contact Name: Information Commissioner=2019s Office Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United K= ingdom Contact Info: 0303 123 1113; https://ico.org.uk/concerns/ Data Protection Officer (DPO) Contact name: Nicola Mckilligan-Regan Address: Alphabeta Building, 14-18 Finsbury Square, London, United Kingdom= , EC2A 1AH Contact info: dpo@independent.co.uk If you are based in the EEA please contact our EU Representative: EU Representative Contact name: IDNML EU Representative Address: IDNML EU REP c/o Kazient Privacy Experts, 77 Lower Camden Street,= Dublin, Ireland, D02 XE80 Contact info: idnml.eurep@kazient.eu Changes to this privacy policy We may make changes to this policy at any time, and where necessary we wil= l inform you of these changes via email. We will display the date the polic= y was last updated on this page. Last updated =2013 July 2024 = More about user policies --===============0883593932== Content-Type: text/html; charset="utf-8" MIME-Version: 1.0 Content-Transfer-Encoding: quoted-printable Content-Description: Mail message body
 

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Privacy Policy

 

Contents

Introduction

What personal information do we collect a= bout you?

 

What do we use your personal information = for?

Our legal basis for using your personal i= nformation

How can you access and update your person= al information?

How long do we keep your personal informa= tion for?

Who do we share your personal information= with?

Using children=E2=80=99s personal informa= tion

Will my information be sent overseas?

How we may contact you

Your data rights

Information for California residents

Exercising your rights, asking questions = and raising concerns

Contact details for exercising your right= s, asking questions and raising concerns

Introduction

At The Independent we = respect your privacy and are committed to protecting your personal informat= ion. This privacy policy is for visitors to our websites, apps and other di= gital platforms. It sets out how we collect, use, disclose, and protect per= sonal data that we hold about you. It also gives information on how to exer= cise your legal rights. In this policy =E2=80=98we=E2=80=99 and =E2=80=98ou= r=E2=80=99 means Independent Digital News and Media Limited.

There are now two ways to read our conten= t. Either you can choose to consent to us using your data to serve you targ= eted advertising, or alternatively we offer the choice to read our content = ad free and without advertising tracking cookies enabled, by paying for a s= ubscription.

The majority of The Independent<= /EM>=E2=80=99s articles are free to read if you consent to us processing yo= ur personal data for advertising purposes. That means when you provide us w= ith your personal data, you allow us to improve your experience of our prod= ucts and services as well as helping to support our quality independent jou= rnalism.

You can withdraw your consent at any time= by clicking on the =E2=80=98Privacy Settings=E2=80=99 in the footer of any= page. If you do withdraw your consent, the cookie banner will appear again= and you will be asked to choose how you would like to browse The = Independent.

Personal information is any information t= hat can identify you and can include:

  • Your name, email address, and year of bi= rth, home address (if you=E2=80=99ve asked us to send something to your hom= e address). =
  • Information about your device (your comp= uter, mobile, tablet etc). For example your unique device ID, advertising I= D, type of browser, and IP address. An IP address is a numerical code which= identifies your device. It can provide information about the country, regi= on or city where you are based. =
  • How you browse our websites, such as the= pages you visit and links you click on. =
  • Details of products or services you buy,= for example a subscription to The Independent. =
  • Debit or credit card details if you buy = a product or service (these are collected via a secure third party payment = provider and are not held on our systems).

When we refer to =E2=80=9Cpersonal inform= ation=E2=80=9D in this policy, we are referencing =E2=80=9Cpersonal data=E2= =80=9D as defined under UK and EU data protection law, as well as =E2=80=9C= personal information=E2=80=9D as it is defined under California law.=

What personal information do we c= ollect about you?

We collect your personal information in o= ne of the following ways, in line with the relevant data protection laws:

  1. Information you give us e.g. when you re= gister for an account, comment on an article, purchase a product or service= or download one of our apps on your mobile device. =
  2. Information from your devices when you v= isit our website or app through the use of cookies and similar technologies= e.g. device type and ID, advertising ID and IP address. =
  3. Information we generate about you e.g. w= e give you a unique ID to remember you when you=E2=80=99re logged in. =
  4. Information we receive about you from ot= her organisations, including social media logins.

More information about this is set out be= low.

What do we use your personal info= rmation for?

1)    Personal inf= ormation you provide directly to us.

When you register for an account to r= ead Premium articles.

If you want to receive a select number of= Premium articles a week you will need to register for an account. We will = ask for your first name, email address, password and year of birth. Readers= under the age of 18 should not register for an account.

When you comment on our website<= /SPAN>

If you plan to comment on our website, yo= u will need to register for an account and provide us with a commenting nam= e. When you comment publicly on an article on our site, we would recommend = you don=E2=80=99t share any sensitive personal information. We are not resp= onsible for the information you choose to post online. Please see a link to= our Community Guidelines on commenting here.

When you take out a subscription or a= ttend an event

If you are subscribing to one of our paid= -for products, in addition to your name, email address, password and year o= f birth, you will also need to provide your billing address and payment car= d information. Your payment details are not held on our systems. Instead th= ey are handled by a secure, trusted third party provider.

We may also collect this information if y= ou attend one of our paid-for ticketed events.

If you attend one of our virtual events, = we will share your full name, prefix and email address with the platform ho= sting the event. We may share your company name but only if you choose to p= rovide this.

When you contact Customer Services wi= th a query

If you contact our Customer Services team= by email, we receive your name, email address and details of your query. I= f you telephone us, we receive your telephone number and name. Please do no= t provide sensitive information unless you=E2=80=99re happy for us to use i= t in response to your query.

When you sign a petition<= /P>

When you click on a link to sign a petiti= on relating to an Independent Campaign, you will be taken to a third party = site. We are not responsible for the data you share with the third party, a= nd we do not receive any of the information. Please check the third party= =E2=80=99s privacy policy for more information on how they use your data.

You may be given the opportunity to opt i= n for further communications about the petition you have signed, other peti= tions you may be interested in or to receive emails from us related to upda= tes or events at The Independent. We will only process your information in = this way where you have given us your permission.

When you purchase products and servic= es from third parties

We may also collect information about thi= rd party products and services which you purchase after visiting our websit= e. For example, when you use a voucher code or click on a link to an affili= ate site. However when you click on one of these affiliate links we don=E2= =80=99t receive any personal data about you, and we cannot link back the pu= rchases to you specifically. Instead we receive aggregated, anonymous infor= mation such as which products have been bought by our readers and how many = of them.

2)    Information = from your devices

Cookies and other online identifiers<= /EM>

We collect data about our website=E2=80= =99s visitors using technology such as cookies, device IDs, IP addresses an= d general location or country. This may include your IP address, informatio= n about your browser or operating system and will include your email (only = ever in secure =E2=80=98hashed=E2=80=99, pseudonymous form). If you would l= ike to know more about our use of cookies and how to manage them, please re= ad our Cookie Policy.

If you have purchased one of our subscrip= tions, this next section does not apply to you. If you accept the use of ad= vertising cookies on our website, then when you use our website and enter y= our email address on our website (either to log in, or to sign up for a new= sletter, or similar), we may share information that we collect from you wit= h trusted partners. This may include your IP address, information about you= r browser or operating system or your email (only ever in secure =E2=80=98h= ashed=E2=80=99, pseudonymous form). Our partners use this information to cr= eate an online identification code to be able to recognise you on your devi= ces. This code may be shared with advertising companies to enable interest-= based and targeted advertising, that is more relevant to you. This code doe= s not contain any of your directly identifiable personal data and will not = be used to re-identify you. We and the below partners process your data to = create this code as joint controllers under data protection law.

Detailed information on our partners=E2= =80=99 data processing activities is available in their privacy policies by= clicking below.

LiveRam= p

To opt-out of your data being used by Liv= eRamp in this way, please visit https://liveramp.com/opt_out/

Trade Desk

To opt out of your data being used by The= Trade Desk in this way, please visit https://www.transparentadvertising.eu/

When you enter your email address to crea= te an account or sign-up to a newsletter or marketing, we may also share yo= ur email address in a hashed form with Amazon Publisher Services (APS). APS= then links this hashed email to a profile which they may already hold rela= ted to that email address. The hashed email will be used in a secure, pseud= onymised form within a cookie to flag to APS whenever you visit The Indepen= dent site. APS will use this to determine, in real-time, if any of their bu= siness customers want to market to a profile similar to yours. If this is t= he case they may initiate an advert which will appear to you on The Indepen= dent website.

The APS Privacy Notice can be found here:=  https://aps.amazon.com/aps/pri= vacy-policy/

Please see our Cookie Policy for more information.

We are signed up to the latest version of= IAB Europe=E2=80=99s Transparency and Consent Framework (TCF) version 2.2 = and comply with its specifications and policies. What this means is that we= treat the personal information that we and our partners collect through co= okies in a transparent and data privacy compliant way.

Market research, user testing panel a= nd surveys

From time to time we may ask you to parti= cipate in reader surveys, to help us improve our website and offering. Usua= lly these will be anonymous, however if you choose to be contacted for futu= re market research, we will ask for your name and contact information so we= can get in touch with you. We will keep your personal data for only as lon= g as we need it, after which we will delete it.

We use a third party survey provider for = running our surveys, and we keep your data in the third party platform for = three months to enable us to analyse your responses, after which we aggrega= te your responses and delete your personal data so it can no longer identif= y you.

We may ask you to attend face-to-face Zoo= m interviews with us or a partner that we have commissioned on our behalf. = However, participation is voluntary and you are free to decline the invitat= ions at any time. We may also send you links to short surveys and your resp= onses to these surveys will be anonymous. If you agree to be a part of the = panel, we will re-contact you after a year to ask if you wish to continue t= o be a part of the panel and give you a chance to opt out.

We may use the feedback you provide in ou= r surveys or as part of our user testing panel, as quotes on our website, o= r in internal and external presentations in connection with the research st= udy and our publications. However where we do this we will ensure that the = quote is anonymous =E2=80=93 unless you give us your permission to use your= name, photograph or screenshots of you during any Zoom interviews.<= /P>

3)    Information = we generate about you.

When you register for an Independent acco= unt, take out a subscription for The Independent or sign up for one of our = newsletters, we assign you a unique ID number. We use your unique ID to rec= ognise you when you are logged in. We also use it to ensure we remember you= r preferences such as which newsletter you have signed up to.

For readers who have not registered or su= bscribed, and are browsing our site anonymously, we assign you a unique ID = number based on your device which remembers your browsing behaviour. This I= D cannot identify you unless you then register or subscribe, after which we= will link your anonymous browsing behaviour to your ID. This is so we can = offer you a more personalised and engaging experience when you register or = subscribe.

We also assign you a unique ID number whi= ch remembers your browsing behaviour. This includes how long you spend on a= n article, what types of articles you read (e.g. travel, politics, sports a= nd so on) and how many, as well as how often you visit our website or app. = This is so we can personalise the site and our communications to you, and w= here you have consented to this, we also deliver tailored advertising that = is more relevant to your interests.

We provide each reader with a cookie ID f= or analytics purposes, so we can recognise when you come back on to our sit= e using one of your devices such as your laptop or mobile phone. We do this= so we know how many individuals come back to our site.

4)    Data we rece= ive about you from other organisations.

Sometimes we obtain additional informatio= n about you from data management and consumer insight providers, such as Ey= eota.

The data these companies may hold about y= ou is collected from publicly available records, such as the electoral roll= , or from other sources where you have agreed for your information to be sh= ared with third parties.

We may then match you with the data that = they hold in their database to find out demographic or household informatio= n about you. This ensures that the advertising you see is relevant if you c= onsent to this.

Social media

We can also access limited information fr= om social media activity such as when you =E2=80=98like=E2=80=99 the websit= e, share content or follow us on Twitter or Facebook. When you sign in to o= ur website using Google, we collect your name and email address. If you sig= n up for one of our newsletters on Facebook, we receive your email address = so we can send you the newsletter you=E2=80=99ve asked for. We may also rec= eive demographic information from social media sites such as Facebook, incl= uding aggregated information on age and gender. However this cannot be link= ed back to you individually. This is used to tailor the advertising we show= you if you=E2=80=99ve agreed to receive personalised advertising.

We use personal data collected through ou= r sites and apps only when we have a valid reason and the legal grounds to = do so. The legal grounds may be one of the following:

Consent.

If you have given us consent to send you = specific newsletters, you can unsubscribe from these at any time. You can d= o this by clicking =E2=80=98unsubscribe=E2=80=99 at the bottom of each emai= l (and additionally at the top of emails if you use Yahoo or Gmail), or by = logging into your account and managing your email preferences.

We only conduct market research and send = you surveys if you have consented to this.

We will send you push notifications from = our apps, and/or send you browser notifications when you are visiting our a= pp or website, only where you have consented.

We will only process your data for market= ing purposes to inform you about our products, services or promotional offe= rs that you might find interesting where you have consented to this.=

Unless you have purchased one of our subs= criptions, you will be required to provide your consent to us processing yo= ur personal data for targeted advertising in order to access our content. T= he remaining paragraphs of this section apply to such non-subscribers.

We may tailor advertising you see on our = website based on the type of articles you read, so it is more relevant to y= our interests. We do this by allocating your ID to relevant interest groups= or segments based on your reading behaviour. For example, if you have read= three articles about travel or commented on a travel article in the last 3= 0 days, or if you have visited a travel website prior to coming onto our we= bsite we may place your ID into the travel segment, and you will subsequent= ly be shown more travel-related advertising. If your reading behaviour is s= imilar to that shown for our travel audience, we may include your ID in our= =E2=80=98lookalike=E2=80=99 travel segment for some campaigns.

We will never use any sensitive data (als= o known as special category data) for this purpose. Please read our Cookie Policy for more information about= this.

We may personalise advertising to you bas= ed on the information that you provide us when you register for an account.= For example, we may aggregate your age (based on year of birth that you pr= ovide us when you register) into groups e.g. 24-35 year olds, if an adverti= ser would like to target their ad campaigns to this demographic. As well as= using your online browsing behaviour and your demographic information to p= ersonalise the advertising you receive, we may also use this aggregated inf= ormation for reporting and analytics purposes. For example, to see how well= a particular ad campaign has performed.

We occasionally work with advertising par= tners to securely match the email addresses of our registered reader databa= se with their customer databases, using our data matching service provider.= This is so we can show ads to readers we and our partners have in common. = All data is encrypted before it is matched, and neither party can directly = identify an individual, nor see or access the other party=E2=80=99s data. T= he data match service provider does not have access to any raw, unencrypted= data.

Generally, this will be conducted at an a= ggregate audience level to provide insights, rather than individual level i= nformation, although your information may be used to generate these insight= s. These insights might include the overlap between our audiences and the c= lient=E2=80=99s, and other information that would be useful to understand f= or an advertising campaign to be effective.

For readers in California, Colorado, Conn= ecticut, Utah and Virginia, if you click the =E2=80=9CDo not share/sell my = personal information=E2=80=9D button, which is in the website footer at the= bottom of the home page, we will not recontact you about that choice for a= t least 12 months.

Legitimate interests.

Legitimate Interests are ways in which we= use personal data that you would reasonably expect. These include:<= /P>

  • Sending you service messages about your = subscription or account registration, for example if you have clicked a pas= sword reset link. This could be by email, overlay on the website or push no= tification (if you=E2=80=99ve consented to receiving app push or web browse= r notifications). =
  • Granting you access to a subscription. =
  • Dealing with any query or complaint you = submit to our Customer Services team. Only provide sensitive data when rele= vant (such as information about your health, race or religion) if you are h= appy to consent to our using it to manage your enquiry. =
  • Dealing with, and responding to you abou= t queries in the comment section and other user generated content facilitie= s. =
  • Logging and using information about any = service errors or interruptions that you have experienced in order to help = us create fixes and to make technical improvements to our website. =
  • Security and fraud prevention. =
  • Verifying your identity and remembering = you (for example when you return to the website and have already logged in)= . =
  • Enabling you to share our content with o= thers using social media or email. =
  • Administering competitions and informing= you if you have been successful in any competitions or promotions. =
  • Keeping you updated about our products a= nd services, in line with your communication preferences. =
  • Monitoring the number of Premium article= s you read as a registered user on The Independent website. This is so we c= an request users subscribe once they have read the maximum number of Premiu= m articles over a given period of time. =
  • Monitoring the number of articles you re= ad on The Independent app. This is so that we can request users subscribe o= nce they have read the maximum number of articles on the app. =
  • Analysing what articles you have read so= we can improve our content and make recommendations to you. =
  • Improving the design and style of the we= bsite. =
  • Responding to your feedback on our produ= cts, services and website and app functionality =
  • Ensuring that we are paid the correct am= ount of commission by our advertising partners if you buy a product or serv= ice from our website. =
  • Allowing us to measure advertising campa= igns, ensure readers do not see the same advertisements too many times, and= ensure advertisements are served in appropriate environments for our clien= ts.

Performance of a contract.

When you buy a subscription or another pr= oduct or service from us, we will need to use your details in order to prov= ide the item to you. For example, in order to deliver a product to your hom= e, you will need to give us your name and address.

Compliance with our legal obligations= .

In some cases, we may have a legal or reg= ulatory obligation to use or keep your personal data.

How can you access and update you= r personal information?

If you are a registered user or subscribe= r, you can update your personal information by signing in to your account p= age. In all other cases, please contact Customer Services.

You can also ask for a copy of the person= al information we may hold about you, or for your data to be deleted via th= e above Customer Services form.

If you wish to contact us by telephone, o= ur number is 0203 615 2990.

How long do we keep your personal= information for?

We will keep your information only for as= long as it is relevant and useful for the purpose for which it was origina= lly collected.

If your account appears to have not been = used for two years, we will try and contact you to check whether it is stil= l in use and/or we will delete it. Please note that any comments associated= with your account will also be deleted.

If you do not read the newsletters that y= ou have subscribed to, we will suppress your name from the relevant list af= ter six months.

If you purchase a subscription, we will r= etain your data for at least 12 months after your subscription ends in case= there are any outstanding billing or other customer service issues.=

A record of a customer service query is r= etained for at least three years from the date it was submitted to us.

We retain cookie data and corresponding t= hird party data for 13 months from when it was collected from your device. = For more information about cookies, please read our Cookie Policy.

We may need to retain your data for a lon= ger period if there is a legal claim or if we are required to so by any reg= ulation. We may also retain your personal information to ensure we do not c= ontact you if you have asked us not to.

We are fully committed to keeping your pe= rsonal information safe and we take measures to protect your personal infor= mation from unauthorised access, disclosure, alteration, or destruction. Ho= wever, as you will appreciate, no data transmission or storage system can b= e guaranteed as 100% secure.

Who do we share your personal inf= ormation with?

Sharing with the Group=E2=80=99s comp= anies

We may disclose your personal information= to our sister companies: Independent Digital News and Media LLC and Evenin= g Standard Limited.

Voucher code partner

We offer our readers voucher codes in col= laboration with Savings United GmbH. We and Savings United are both respons= ible for any personal data you provide or that we collect while you visit w= ww.independent.co.uk/vouchercodes. We must both comply with data protection= laws. If you have any questions or concerns about how your data is being u= sed in relation to Voucher Codes, in the first instance please email: = contact@savings-united.com.

Advertising partners

If you consent to the use of advertising = cookies on our website, advertisers and advertising agencies sometimes requ= ire data to select and serve relevant advertisements to you based on your o= nsite behaviour e.g. whether you=E2=80=99ve clicked on an ad and are re-tar= geted with another ad from the same advertiser. We may also provide them wi= th audience demographics about an audience who viewed or interacted with a = campaign.

For more information on what personal dat= a we collect and how we use it, please refer to the sections above =E2=80= =98What personal information do we collect about you?=E2=80=99 and =E2=80= =98What do we use your personal information for?=E2=80=99.

Government or regulatory bodies only = if required by law

We reserve the right to disclose your per= sonal information to comply with applicable laws and government or regulato= ry bodies=E2=80=99 lawful requests for information.

Our service providers

Your personal details may be shared with = third party organisations we have contracted to provide services to us whic= h include processing data. For example, to send you the emails you have sig= ned up for, to process your payment information when you buy a product or s= ervice, or for other purposes as described in this policy. Only companies w= ho can provide adequate safeguards will be used to ensure your data is stor= ed and handled securely. And we have contracts in place with these provider= s to make sure that they only use information in ways we have instructed th= em to, and to protect your data and comply with applicable law.

Transfer as part of the sale of our b= usiness

We may transfer, sell or assign any of th= e information described in this Privacy Policy to third parties as a result= of a sale, merger, consolidation, change of control, transfer of assets or= reorganisation of our business.

Agencies and authorities because of a= legal requirement

We may also have to release information b= ecause of a legal requirement on us or pursuant to a court order.

Using children=E2=80=99s personal= information

We do not aim our services to children un= der the age of 13. We do not allow children under 18 to register an account= with us.

Will my data be sent overseas?

As you will know, the internet does not r= ecognise national boundaries. Services on the web are accessible globally s= o collection and transmission of personal data is not always confined to on= e country.

You should be aware that by using the web= site and those of our partners or any website we link through to, your pers= onal data may be processed in or transferred to other countries, the USA fo= r example, and you agree to your personal data being transferred or process= ed in this way.

Your personal data will only be stored or= transferred within the UK, EEA, US or other countries using Standard Contr= actual Clauses, or other safeguards that have been approved by the relevant= regulatory body.

If you are located in the UK or the EEA, = you may contact us for a copy of the safeguards which we have put in place = for the transfer of your personal data outside the UK or the EEA.

How we may contact you

We will contact you in accordance with yo= ur preferences. From time to time we may contact you by email or browser or= app push notification to give you service information. For example, if you= r subscription is changing, or your payment method has expired. You will no= t be able to opt-out from receiving these service messages unless you no lo= nger wish to use the services.

If we have your permission we may also se= nd you newsletters or emails about our events, subscription benefits or new= launches and website developments.

You can manage your preferences and subsc= riptions to newsletters and emails by signing into to your Independent acco= unt. You can also unsubscribe at any time by clicking the link in the foote= r of the email (or also at the top of emails if you use Yahoo or Gmail). Wh= en you unsubscribe from marketing emails, we will add your email to a list = to make sure we don=E2=80=99t send you any marketing information going forw= ard. For more help on managing your account, visit our help centre= .

Occasionally we may ask you if you would = like to participate in market research or respond to you if you have made a= complaint or have logged a query.

Your data rights:=

Right of access =E2=80=93 you can ask for= a copy of the data that we hold about you.

Right of rectification =E2=80=93 you can = ask us to correct data that we hold about you that is inaccurate or incompl= ete.

Right to be forgotten =E2=80=93 you can a= sk for the data we hold about you to be erased from our records.

Right to restriction of processing =E2=80= =93 you can ask for us to restrict the way we use your data.

Right of portability =E2=80=93 you can as= k for us to transfer the data we hold about you to another company.<= /P>

Right to object =E2=80=93 you can object = to us using your data where we are relying on a legitimate interest to use = it.

Right to withdraw your consent =E2=80=93 = you can withdraw your consent at any time.

Please note that these rights are not abs= olute and certain may exemptions apply. For more information about these ri= ghts, please visit the ICO=E2=80=99s website at: We will respond to your requests within o= ne calendar month as per our statutory obligations.

We may ask for proof of identity to be ab= le to proceed with your request in order to meet our data protection obliga= tions. We do not usually charge for making a request, but we may charge a f= ee in accordance with the relevant laws in certain circumstances.

Please note the Independent is a media or= ganisation and publisher. This means we may be subject to certain exemption= s under data protection law when we process personal data for the purposes = of journalism. These exemptions apply to some of the ways the Independent u= ses personal data. This privacy policy does not cover personal data that th= e Independent processes for the purposes of journalism.

Information for California reside= nts

Categories of personal information (PI) c= ollected, along with examples of PI and the purpose of collecting PI are se= t out below:

Identifiers

Examples: e.g. name, contact information = including email address, postal address, phone number, online identifiers, = IP address.

You provide this directly to us when regi= stering or taking out a subscription. We also obtain this from partners, se= rvice providers or public sources.

Purpose: To register or subscribe to the = Independent, to manage your account; respond to your inquiries or requests = and communicate with you; to send you email newsletters and push notificati= ons if you choose to receive these; running our events; providing customer = services; verifying customer information; administering competitions, custo= misation of ads to make the advertising on our sites more relevant.<= /P>

Internet or other electronic network = activity information

Examples: Browsing history, search histor= y, geolocation data and information regarding your interaction with website= , app, or advertisement =E2=80=93 through use of cookies or similar technol= ogies.

Purpose: Personalising our site and adver= tising to make it more relevant to you, marketing and promoting products an= d services, tailoring our communications to you, improving our understandin= g of readers to ensure the best content and services

Personal Characteristics<= /P>

Examples: In some circumstances, we may c= ollect PI that is considered protected under U.S. law, such as age and gend= er. We abide by the legal requirements imposed under applicable law in rega= rd to such information. You either provide this to us or we infer it from i= nformation we hold about you.

Purpose: We use this to serve you adverti= sing campaigns that are more tailored to you and for third parties to be ab= le to measure the effectiveness of their ads. We also ask for year of birth= information as we do not want children under the age of 18 to register for= an account.

Commercial Information

Examples: Records of purchase history and= transactions.

Purpose: Fulfilment of orders, answering = customer service queries.

Professional or employment-related in= formation

Examples: e.g. job title; industry; compa= ny =E2=80=93 either directly from you if you choose to provide it or from p= ublicly available sources or service providers or partners

Purpose: To enable us to work and communi= cate with our industry partners, recruitment.

Inferences from personal information = collected

Examples: Inferences drawn from any of th= e personal information listed above to create a profile or summary about yo= u, reflecting your preferences, characteristics, behaviours.

Purpose: Personalising advertising to mak= e it more relevant to you, marketing and promoting products and services, t= ailoring our communications to you.

Categories of third parties we may dis= close personal information to:

  • Service providers who assist us in opera= ting our business and delivering our services =
  • Advertising and marketing partners =
  • Legal authorities or regulators when req= uired by law or to protect our legal rights =
  • We may disclose your personal informatio= n to our sister companies: Independent Digital News and Media LLC and Eveni= ng Standard Limited.

California Shine the Light Law

Subject to certain limitations, Californi= a residents may ask us to provide them with:

  1. A list of certain categories of personal= information that we have disclosed to third parties for their direct marke= ting purposes during the immediately preceding calendar year, and =
  2. The identity of those third parties.

To make this request, California resident= s may contact us at Customer Services. For such requests, indicate =E2=80=9CCA Shine= the Light Request=E2=80=9D in the subject field of your request.

Your rights under the California Consu= mer Privacy Act as amended (CCPA)

Right to know =E2=80=93 you can ask (up t= o twice in a 12-month period) for the personal data we may hold about you f= or the past 12 months.

You can also request:

  1. The categories and/or specific pieces of= personal information we have collected about you =
  2. The categories of sources for that perso= nal information =
  3. The purposes for which we use that infor= mation =
  4. The categories of third parties we discl= ose your information to, and =
  5. The categories of information that we se= ll or disclose to third parties.

Right to delete =E2= =80=93 you can ask us to delete the personal data we collect about you (wit= h some exceptions, such as if we are legally required to keep the informati= on).

Right to opt-out of the sale or s= haring =E2=80=93 you have the right to opt-out of the sale or= sharing of personal data we may hold about you. You can exercise this righ= t at any time by pressing the =E2=80=9CDo not Sell or Share My Information= =E2=80=9D link in the footer of every page on our site.

If you click the =E2=80=9CDo not Sell or = Share My Information=E2=80=9D link, we will not recontact you about that ch= oice for at least 12 months.

Right to correct your personal in= formation =E2=80=93 you can ask us to correct inaccurate pers= onal data that we may hold about you.

Right to limit the use and disclo= sure of sensitive personal information collected about you = =E2=80=93 you can ask us to only use your sensitive personal information fo= r purposes such as providing you with the services you have requested. We d= o not collect sensitive personal information unless you provide this to us.=

Right to non-discrimination for e= xercising your rights =E2=80=93 we will not discriminate agai= nst you for exercising any of your privacy rights.

We may ask for proof of identity for veri= fication purposes, such as your name, e-mail, phone number and/or account i= nformation. We will review the information provided and may request additio= nal information via e-mail or other means to ensure we are interacting with= the correct person. To help us respond appropriately, please specify that = you are making a request under the California Consumer Privacy Act or CCPA.=

You may also use an authorized agent to m= ake requests to exercise your rights under CCPA as described above. We will= take steps both to verify your identity, and to verify that your agent has= been authorized to make a request on your behalf through providing us with= a signed written authorization or a copy of a power of attorney.

We endeavour to respond to a verifiable r= equest within 45 days of its receipt. If we require more time (up to 90 day= s), we will inform you of the reason and extension period in writing.

Please note that some of these rights are= not absolute and exemptions may apply in certain circumstances.

Exercising your rights, asking qu= estions and raising concerns

If you have any queries or comments about= this privacy policy, or you would like to make a request, please contact u= s using our online form available here: Customer Services.

If you=E2=80=99re unhappy with how we=E2= =80=99ve handled your data or your request, please get in touch with us in = the first instance using our online form: Customer Services. You may also get in tou= ch with our Data Protection Officer. Their contact details are in the table= below. If you=E2=80=99re still not satisfied with our response, you have t= he right to complain to the Information Commissioner=E2=80=99s Office (ICO)= whose contact information is also provided in the table below.

Contact details

Contact Name: Information Co= mmissioner=E2=80=99s Office

Address: Wycliffe House, Water Lane, Wilm= slow, Cheshire, SK9 5AF, United Kingdom

Contact Info: 0303 123 1113; https://ico.org.uk/concerns/

Data Protection Officer (DPO)

Contact name: Nicola Mckilligan-Regan

Address: Alphabeta Building, 14-18 Finsbu= ry Square, London, United Kingdom, EC2A 1AH

Contact info: dpo@independent.co.uk

If you are based in the EEA please contac= t our EU Representative:

EU Representative=

Contact name: IDNML EU Representative

Address: IDNML EU REP c/o Kazient Privacy= Experts, 77 Lower Camden Street, Dublin, Ireland, D02 XE80

Contact info: idnml.eurep@kazient.eu

Changes to this privacy policy

We may make changes to this policy at any= time, and where necessary we will inform you of these changes via email. W= e will display the date the policy was last updated on this page.

Last updated =E2=80=93 July 2024<= /STRONG>

 
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