Privacy Policy

This Privacy & Cookies Policy dated 03/05/2018 replaces our previous policies. Please take the time to review before you continue to use our products and services. This Privacy & Cookie Policy applies to any information you provide to us, including through this website, our mobile apps, communications by email and through social media, by telephone and in person. It also covers any information we receive from third parties. By using our products and services, including browsing our websites, registering or logging in, you agree we may use your information as outlined in this Policy. If you do not wish to have your information used in line with this Policy, you must not use our products and services and not otherwise provide us with your information.

Purpose of this privacy notice

This privacy notice aims to give you information on how Jersey Evening Post Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Jersey Evening Post Limited is the controller and responsible for your personal data (collectively referred to as “company”, “we”, “us” or “our” in this privacy notice). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are: Full name of legal entity: Jersey Evening Post Limited Name of DPO: James Filleul Email address: james@bailiwickexpress.com Postal address: PO Box 582, Jersey JE4 8XQ You have the right to make a complaint at any time to the Office of the Information Commissioner’s (OIC), the Jersey supervisory authority for data protection issues (www.oicjersey.org). We would, however, appreciate the chance to deal with your concerns before you approach the OIC so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Information we may hold about you

• Information you’ve provided to us
• Information about products and services you’ve ordered, enquired about or shown an interest in
• Information provided by other companies who have obtained your permission through their own privacy policies to share information about you, including from specialist data companies
• Information about your interaction with our websites, mobile apps and other products and services, including adverts
• Information we collect using cookies stored on your device about your use of our websites and/or selected third party websites.
• Information we collect or remember using technologies similar to cookies, such as device identifiers on your mobile device.
• Your IP address, which is a number that identifies a specific network device on the internet which allows your device to communicate with websites and apps.
• Technical information from your device relating to the service you receive Information relating to the location of your device.

How we may use your information

By using our websites, apps and other products and services, you agree that we may collect, hold, use or otherwise process your information (including personal information) for the purpose of providing you with those products and services and developing our business which shall include (without limitation):

• Verifying your identity (for example when you return to our websites or mobile apps)
• Personalising the content and advertisements you see on our websites and apps
• Developing the design and style of the our products and services to make improvements
• Understanding more about you, such as your location and demographic information
• Informing you about the latest changes to our products and services
• Informing you of promotional offers that you might find interesting
• Dealing with, and responding to you about, a comment you have submitted for or on our message boards, blogs and other such user generated content facilities
• Enabling you to share our content with others e.g. using “Email a friend” and “Share this article”
• Customer services and support
• Informing you if you have been successful in any competitions or promotions
• Compiling customer reviews
• Conducting market research
• Carrying out statistical, technical and logistical analysis and strategic development
• Communicating with you in relation to your account or service, service updates or other non-marketing communications
• Communicating (and personalising such communication) with you, according to your preferences
• Sending you periodic newsletters about your chosen services
• Sending you direct marketing. This may include communications by post, telephone or email or SMS about us and our business partners’ products and services, events and special offers
• Providing you with personalised services, such as recommendations on our websites, apps and in direct marketing and tailored advertising. This includes where we use cookies or similar technologies in relation to the devices you use, for example to make some of the adverts you see more relevant to you
• Maintaining records of our communications with you if you get in contact with us
• Providing you with location based services such as weather information based on your location and advertising relevant to your location and previous locations
• Providing you with advertising more relevant to your interests and your online behaviour through the use of cookies and similar technologies when you visit our websites and apps
• Blocking disruptive use and ensuring the security of our products and services
• Ensuring the integrity of votes, competitions and polls
• Complying with laws and other circumstances permitted under the Data Protection (Jersey) Law 2005 and from 25th May 2018 The Data Protection (Jersey) Law 2018

How is your personal data collected?

We use different methods to collect data from and about you including through: Direct interactions You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• equest marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources

We may receive personal data about you from various third parties [and public sources] as set out below: Technical Data from the following parties:

• analytics providers such as Google based outside the EU;
• advertising networks such as Taboola based outside the EU;
• Google Adsense advertising
• AddThis (used for sharing content); and

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as: Barclaycard Merchant Services, and Pay360 and Paypal who are based outside the EU.

How we may use your information in specific products or services

Registration

If you’ve registered on our websites or apps, you’ll receive personalised recommendations, newsletters and marketing. These are tailored to you based upon your registration details and other information you provide us, your browsing history interactions with our emails and information we receive from our trusted partners and specialist data companies to help us understand what you might be interested in. This also includes information provided to us from social media sites when you choose to sign in or log in to our websites or apps through your social media account, or when you link your registration with us to your social media account. This information may be collected using cookies and similar technologies. Demographic information from your registration may be used by us for tailored advertising. Please see our Cookie Policy below for more details.

Message boards, blogs and other public forums

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

“Email a friend” and “share this article”

Before you use “email a friend” or “share this article” buttons please make sure that anyone you wish to email or share with are happy for this to occur and expect to receive the email or article. You may only share the details of another person with us where you have their express permission.

Location based services

Where we provide services that utilise your device’s location, such as local weather or news, your location will be determined either from a lookup of your IP address in a “GeoIP” database which lists information provided by your ISP (usually your closest town or parish) or your precise location directly from the device (such as through GPS or Wifi on mobile devices) where you have granted permission for us to access this location information. If you have given us permission to use your location, we may use it for marketing and advertising purposes.

Push and in-app notifications on apps

Where you install one of our apps on your mobile device, this may use push notifications or in-app notifications. These notifications are used for a variety of reasons, for example push notifications may be used to trigger an automatic download of new content (such as a new edition) or to send you an update on new “editorial”, or breaking news message. Please see the app download or install page for each app for more information on how it uses notifications. Within the app, you may be able to select to receive only certain types of notifications.

If you order a product or service from us we may ask for information including your name, e-mail address, delivery and billing address, credit or debit card number and expiry date. Sometimes we may ask for your telephone number to be forwarded to the couriers who may deliver your order. These details allow us to process your orders efficiently

Competitions

If you enter a contest or promotion we may ask for your name, address, e-mail address or telephone number. This is so we can run the contest effectively and tell you if you have won.

Tailored advertising

We use advertising to fund our websites and apps. Some advertising is “contextual” meaning it is shown due to the particular webpage you are presently viewing. Other advertising, known as “online behavioural advertising” is shown to you based upon your likely interests, which are inferred from your device’s browsing history. This information is collected through the use of cookies and similar technologies. You may opt-out of online behavioural advertising at any time, please see our Cookies Policy for details.

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

Other times we will arrange for our customers to be shown advertisements on our own or other websites or apps. These advertisements are tailored to you with information we have obtained from your browsing on our websites and apps and from information about your likely interests that we obtain from our partners and specialist data companies relating to you and to the devices you use where those partners know you are signed in and, where they have your permission to share this information with us in line with their privacy policies.

Where we arrange for our customers to be shown advertisements, we use technological and contractual mechanisms to protect your cookie data and to ensure that your browsing data used for advertising is not used by advertisers or other website owners for other purposes, such as linking online behavioural advertising data with your contact details, unless you have provided the advertiser or other website with your express permission to do this.

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

When you are shown an advertisement, our advertising systems do not know who you are or your contact details (such as your name, email address or postal address).

Demographic information from your registration on our websites and apps (such as your age, gender and city) may be used to tailor the advertising we arrange to be shown. Your demographic information is not shared with advertisers.

Where you have granted permission to access your device’s location to us, our advertising partners or specialist data companies, this location information may be used to tailor the advertising you receive, including showing you certain advertisements when you are in the vicinity of a particular location.

Social media advertising

We may target advertising on social media sites to specifically include or exclude customers who have registered for our products and services. For example, customers who have an outdated version of our app may see an ad for the latest version, or customers who have already subscribed to our newsletters may not see the ad for those newsletters.

How we may share your information

When you purchase goods or services from us we partner with specialist companies to fulfil your order. We usually remain the data controller of your information and the other companies only process data under our instructions and cannot use the information for their own purposes. We will use reasonable endeavours to ensure these third parties process your data securely.

Sometimes we bring you promotions from other companies. Here the other company will use your information as the data controller in line with their own privacy policies. We may also use your information for marketing purposes as a data controller.

For example, financial services offers from Fundit are brought to you in conjunction with our third party financial services partners. If you decide to use their advisory services or set up an account with them, these financial services partners will be the data controllers of your information and will handle your information in accordance with their own privacy policies.

We may share information about you with suppliers that we engage to help us provide the services and/or functionality, e.g. online payment processing. As discussed above, we may share your personal information with other companies within the Guiton Group Limited group of companies.

We may also share personal information about you to third parties, where you have given us permission or where the third party can confirm that they have your permission for us to do this.

We may also provide third parties with certain aggregate statistical data about our customers’ use of our websites and apps, which may include demographic data such as age range and/or geographic location of groups of our customers. This aggregate data does not include contact details (such as the customer’s name, address or email address).

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

We may also share your information as required by law and as contemplated by The Data Protection (Jersey) Law 2005 and from 25th May 2018 The Data Protection (Jersey) Law 2018.

Safeguards and security for your information

We have measures in place to protect the security of your personal information from unauthorised access or use, such as by using encryption technology.

We comply with the Data Protection (Jersey) Law 2005 and from 25th May 2018 The Data Protection (Jersey) Law 2018. For more information on the Data Protection (Jersey) Law 2005 and form 25th May 2018 The Data Protection (Jersey) Law 2018 and your related rights please see the Office of the Information Commissioner’s website www.oicjersey.org

Children & young people

Our websites, apps and other products and services are not aimed at children.

If you are a parent or guardian of a child under 13, please contact us [link to new anchor to “contacting us” section below] if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. In addition to “your choices” outlined in this Policy, we will delete or otherwise cease processing your child’s personal information within a reasonable time.

If you are aged 13, 14 or 15, we request that you seek your parent or guardian’s permission before providing us with your information or using our websites or apps.

Your choices

Please note that our website, apps and other products and services may not work correctly (or at all) if you change your preferences. For your cookie choices, please the Cookies Policy below.

Email & SMS marketing

You can opt out of a particular marketing campaign or newsletter subscription by clicking on the ‘unsubscribe’ link in each email.

You can opt-out of marketing text messages by replying ‘STOP’.

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

Use of your location

You can choose whether to provide us with your precise location from your device through your browser’s “Help” menu, or through the “Location” or “Location Services” in the “Settings” section on your mobile device.

Use of push notifications

You will be prompted to choose whether to receive push notifications the first time you run each app, and you can update your preferences at any time through Settings on your device.