We collect personal information about you when you access this website or other websites controlled by us or by a company within our group or when you use any of our products, applications or services (collectively our “Services”). This document also outlines our approach to compliance with the General Data Protection Regulation (GDPR) and all other relevant data-protection legislation. It also sets forth your privacy rights. Please take a moment to familiarise yourself with our privacy practices.
Information we collect and how we use it
We collect and use your personal information for a variety of reasons including:
If you register, purchase or subscribe to one of our Services
To create an account with us
To become a subscriber to The Irish Examiner or to purchase or subscribe to one of our other Services, you will need to create an account with us. You will also need to create an online account if you wish to interact with any of our free online content.
We will use your personal information to carry out our obligations arising from any contract you as our customer have entered into with us. We will also use your personal information to provide you welcome emails to help you get the most out of your subscription, subscriber-only content, and subscriber rewards.
If you cancel your subscription with us, we may use your personal information for direct marketing. We will only do so with your consent. We will generally send you direct marketing by email. We will use your information for a reasonable period of time, not exceeding five months, after your relationship with us has ended. Specifically, we will send you a short series of emails to remind you of the benefits of a subscription with us. You have the right to unsubscribe from receiving such communications from us by following the unsubscribe instructions included at the end of each email communication.
To pay for requested services
We will collect your payment information to pay for any Services you have requested from us. Credit and debit card information is processed directly by PCI-compliant payment providers who perform payment services on our behalf. Occasionally, our employees receive payment information from customers over the phone. When this occurs, the payment information is entered as instructed into the relevant payment system and all other copies are deleted or destroyed immediately.
To facilitate registration through social networks
We may collect your publicly available social media profile details including your name and email address when you sign up for one of our services through a social media account. We may use these details for the purposes of our registration process in order to enter into a contract with you. We may also automatically import your profile photo and membership status of Facebook, LinkedIn and Twitter if you choose to make these details public. Where we do, we do so in pursuit of our legitimate interest in understanding the demographics of our customers and readers.
To place an advertisement
We may process your personal information if you opt to place an advertisement. We only process this information to deliver the advertising service you have requested as per the terms and conditions you accept.
To deliver marketing, promotions and to conduct research
To receive marketing communications
We may periodically send promotional emails about features, events, exclusive offers and competitions to the email address you have provided – we will only do so with your consent. We have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing communications tailored to your interests. You may at any time choose not to receive marketing communications from us by following the unsubscribe instructions included at the end of each email communication.
For competition and promotional purposes
We regularly run competitions or similar promotions. If you choose to enter a competition or promotion, we will use your personal information to administer these promotions and as per the terms and conditions you accept when you enter. In some cases, your competition entry may be shared with the promoter and this will be specified when you enter. If you win a competition, your contact information will be used to notify you as the winner and to award the relevant prize. We will publish your name on our website and indicate the prize you have won.
To deliver our content to you
To participate in a survey or poll
We conduct surveys and polls that we use to produce original research from our readers. Your participation is entirely voluntary. You may consent to the Examiner Group contacting you at the email address provided to participate in this research. We do not track individuals but look at the information in the aggregate. Any opinion you express, therefore, is anonymous.
From time to time, upon completing a survey or poll, we may ask for your email address for competition, promotional or gifting purposes. Participation is entirely voluntary and this information is processed and stored separately from the information you provide us for the survey or poll. Where you provide this information to us, it will be processed only to administer the competition or promotion.
To provide you with an email newsletter
We offer all readers access to a number of email newsletters. We will only send you these newsletters with your explicit consent. We collect and use your information to send you the newsletter(s) you have requested and in some cases to personalise the email we send. You can opt out at any time by unsubscribing at the bottom of each email newsletter communication.
To share our content
We provide tools that enable users of our services to share or forward our content to a nominated email address. If someone else shares our content with you, we may temporarily collect your email address for the purpose of sharing the requested content. We will only use this information to fulfil the sharing request and this contact information is not retained by us.
To recommend content
We may use aggregate information we collect about you to suggest and recommend tailored content. This processing is necessary for the purpose of our legitimate interest in delivering relevant content to our readers. You have the right to object to this processing, and if you wish to do so please contact us at email@example.com
To understand how you use our services
To track how you gain access to or read our content
We collect information relating to your use of our services to track how you gain access to or read our content. We use log-in information, cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services as follows:
When you sign up for or subscribe to one of our services, we will track and aggregate non-personal information previously collected about you through our services with the personal information provided when you register or subscribe. If we link other data with your personal information we will treat that linked data as personal information for as long as it remains combined. We use this information to evaluate your personal preferences and interests, which under the GDPR may constitute as customer profiling. We do so in pursuit of our legitimate interests which are:
- To research and improve the Examiner Group's products, services, and customer communications
- To understand which content you find useful or interesting
- To develop and maintain relationships with our customers and readers
- To deliver relevant content to our readers
- To understand the demographics of our customers and readers
You have the right to object to this processing or change these preferences at any time. If you wish to do so please contact us at firstname.lastname@example.org.
We log technical information that your browser sends us, as well as usage information about the use of our website and services. This may include including a history of the pages viewed, articles, content and products viewed or searched for, and page interaction information, and any phone number used to call our customer service number.
We may log information related to the type of mobile device used, including unique mobile identifies and mobile network information. We also track how our mobile applications are used including but not limited to traffic data, location data, and weblogs.
To measure the effectiveness of our email communications
We use such technologies to determine whether you’ve opened an email communication from us or clicked on a link contained in an email. Collecting information in this manner allows us to gather statistics about the usage and effectiveness of our services and products, including our email newsletters and direct marketing communications, in our legitimate interest.
To support our advertising services
Third-party vendors, including Google, display advertising on our Services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site. This type of behavioral advertising is targeted towards groups of users in an anonymous and aggregated manner as opposed to you as an individual. Such online advertising helps support the content, products and services we provide.
We and third-party vendors use first-party cookies and third-party cookies together to inform, optimise and serve ads based on your browsing activities and interests. Any information we disclose to advertisers and advertising networks is non-personally identifiable.
To deliver recruitment services to you
To use our recruitment services
We may invite you to submit your personal information by applying for a job or becoming a candidate on our “Recruit Ireland” website. Your personal information is used by us to provide our recruitment services to you. Where you consent, we will provide information on job opportunities and match your profile with suitable job vacancies. If you apply for a job posting, you explicitly enable recruiters to see your profile and CV, the personal information you provide to us (including sensitive information) may be shared with third-party recruiters and clients only if you have given your consent to do so. By sending us your personal information or by making a job application on our site, you agree to our recruitment terms and conditions. You may delete your candidate profile entirely if you wish by logging into your account and selecting the delete account option.
To apply for a job with us
If you apply for a job within The Examiner Group, you may provide us with certain personal information about yourself. We will use this information for the purpose of processing and responding to your application, to assess your suitability as a potential candidate and for current and future career opportunities.
To attend one of our events
We host many events throughout the year. These include but are not limited to breakfast briefings, live content events, live lectures, podcast recordings, training, conferences and seminars. If you register for one of our events, we will collect personal information from you. We will use your information to register for the event, process your payment and provide you with information and services associated with the event. In some cases, we make audio or video recordings of these events and we may record information about you as a consequence. We will always inform you if the event is being recorded so that you can choose not to participate if wish. Registration for our events is voluntary. Once you register, however, we process your personal information as per the terms and conditions of that specific event and on the lawful processing ground of contract.
Other: To monitor our premises with CCTV camera surveillance
Our premises at Assumption Road, Blackpool, Cork are monitored by CCTV security cameras. CCTV notices are on display outside our building to inform you of our practices and to give you advance notice of any recording.
We are processing CCTV video surveillance data generally without your consent in pursuit of our legitimate interests to protect the rights, property and safety of the Examiner Group and the rights, property and safety of our employees or others. The CCTV surveillance information we collect may be shared with An Garda Síochána or other third parties where we are required to do so by law.
To correspond with you
If you correspond with us, we will use your contact information to respond to your enquiry. We process this information in pursuit of our legitimate interests to develop and maintain relationships with our customers and readers.
To manage ordinary business needs
We may use your personal information to manage ordinary business needs, including for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention. Our legitimate interest is the effective management of our business.
To verify your identity
To exercise your data rights, we may need to collect additional personal information from you to verify your identify and to process your request.
When you provide professional services to us
You may provide us with your personal information if you provide professional services to us. We process this information so we can administer, manage and pay for the relevant services you provide and as per the terms and conditions of our contract.
Anonymous information we process
The legal basis for processing your information
We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.
To enter into and perform a contract with you
We use your personal information to carry out our obligations arising from any contracts entered into between you and us or to take the necessary steps at your request prior to entering into a contract with us including:
- To provide you with the subscription, services or products you have requested
- To process your payment information
- To authenticate and verify your account
- To provide customer and technical support
- To administer competitions or similar promotions
- To provide our recruitment services to you when requested
- To pay for the professional services you may provide to us
- To send important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service
- To keep you informed of the benefits of your subscription
- To deliver exclusive content and benefits to our subscribers
With your consent, which can be withdrawn at any time
We will, in certain circumstances, rely on your explicit consent to process your personal information. Where we do, you have the right to withdraw your consent at any time. In most circumstances, your consent can be withdrawn by following the unsubscribe instructions included at the end of each email communication from us. You can also contact us at email@example.com and we will be happy to facilitate your request.
To comply with our legal obligations
We may be required to process your personal information to comply with certain legal obligations to which we are subject, including:
- Providing information to an Garda Síochána, the Revenue Commissioners or other Government bodies or agencies when required to do so by law
- If you have exercised one of your data rights, we will retain a copy of all correspondence to demonstrate our compliance with data-protection legislation
- If you have exercised one of your data rights and ask us not to contact you by email at a particular email address, we will need to retain a copy of that email address in order to comply with your no-contact request
- To carry out our statutory audit
Processing based on our legitimate interests
We process your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. We will always ensure there is a fair balance between our legitimate interests and your fundamental right and freedoms.
We process personal information for the following legitimate business purposes:
- To manage our everyday business needs and for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention
- To provide you with a more personalised experience, such as making content recommendations
- Understanding which content you find useful or interesting
- To support our advertising services
- To determine the effectiveness of promotional campaigns, email campaigns and advertising
- To research and improve the Examiner Group's products, services, and customer communications
- To ensure content from our site and mobile applications is presented in the most effective manner for you and for your device
- To develop and maintain relationships with our customers and readers
- To protect you against fraud and to detect, prevent, investigate security or technical issues to ensure our Services are secure
- To protect the rights, property and safety of the Examiner Group or the rights, property or safety of our employees or others
- To understand the demographics of our customers and readers
- To send direct marketing to our subscribers or former subscribers.
When and how your information is shared:
Within our group
With third parties
We may share your personal information with third parties for a number of reasons as outlined below. We do not sell your personal information to anyone and only share it with third parties who are facilitating the delivery or fulfilment of our services and or are working on our behalf. We contractually require that our suppliers protect such information from unauthorised access, use, and disclosure.
Third-party service providers
We may share your personal information with third-party service providers which perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, payment providers, lawyers, providers of security and administration services and other business advisers.
Third-party service partners
We provide certain services and run promotions in conjunction with third parties and we may share your personal information if the service you have requested is fulfilled by them.
We disclose non-personally identifiable anonymous information to third-party advertisers to help them reach the kind of audience they want to target. We share summary aggregate reports for our advertisers to measure the effectiveness of the ads they have served. These advertising parties may combine the information we send with other information that you’ve provided to them or that they’ve collected from your use of their services.
We use services offered by Inskin Media Ltd, 233 - High Holborn, London, WC1V 7DN, UK. Inskin works with limited third-party service providers for reach assessment and broad targeting. To Opt-Out of these services please see http://www.inskinmedia.com/opt-out.html.
Inskin Media may collect information about the adverts that you view while browsing our partners’ websites. Inskin uses IP address for fraud detection and broad geographical targeting and, unique user ID to approximate the number of unique users in our network. For this purpose, most of our data processing takes place within the EU and limited data in the USA. For more information please see http://www.inskinmedia.com/privacy-policy.html.
We may share your personal data with a third-party auditing organisation (ABC) in accordance with our legitimate interests to verify aggregated statistics about circulation and usage of our products or to review our policies, processes and procedures for compliance with relevant standards.
Third-party recruiters and clients
If you apply for a job posting on our “Recruit Ireland” website, or if you explicitly enable recruiters to see your profile and CV in your candidate account settings.
Social networking sites
Data storage and retention
We will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information no longer than is necessary to comply with our business and legal obligations. Where we enter into a legal contract with you, we will hold your personal information for a period of seven years from the date of completion of this contract by reference to the statute of limitation for a legal claim under contract.
We may transfer your personal data outside the European Economic Area (EEA), in which case we take specific steps, in accordance with data protection law, to ensure equivalent protect of your personal information. In particular, for transfers of personal data outside the EEA we rely either on an adequacy decision by the European Commission or on contractual protection approved by the European Commission.
Your data rights
You have several rights under data-protection law in relation to how we use your personal information. You have the right, free of charge, to:
- Request a copy of the personal information we hold about you in a structured, commonly used and machine readable format. We’ve made it easy for you to do so – simply fill out an online Data Access Request form to initiate the process. Before we can provide you with any data, we’ll need to verify your identity and may also need to gather some additional information to clarify the scope of your request.
- Rectify any inaccurate personal information we hold about you
- Withdraw your consent where we have relied upon your consent to process your information
- Erase the personal information we hold about you subject to certain exceptions
- If technically feasible, have your personal information transmitted to another data controller in a machine readable format at your request
- Restrict processing of your personal information in certain circumstances
- Object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes
- Not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature
- Lodge a complaint with the appropriate data-protection authority if you have concerns about how we process your personal data
These rights are in some circumstances limited by data-protection legislation. If you wish to exercise any of these rights please contact us at firstname.lastname@example.org. We will take measures to verify your identify which we will do by reference to copies of acceptable identification documentation supplied by you.
We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.
Consequences of not providing information
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Processing for journalistic purposes
As a news publishing organisation, the Examiner Group processes personal data for the purpose of exercising the right to freedom of expression and information and for journalistic purposes. This processing is exempt from compliance with certain obligations of the GDPR.
- We may process your personal information for journalistic purposes where you submit content to be published online and in our printed publications
- Where you have voluntarily contributed your experience to us and we publish this information
- If we publish a letter you have written to the Editor
- If you participate in one of our discussion forums
It is important to understand that certain rights which you have in relation to your personal information may not apply where that data is processed for journalistic purposes.