The NPD Service Data Privacy Notice

Welcome to The Irish News’ privacy notice.

Who We Are

The Irish News Limited (we, us, our or The Irish News) publishes Northern Ireland’s largest selling morning newspaper; The Irish News, and we run the newspaper delivery service website https://newspaperdelivery.me/ which offers a newspaper delivery service for the Irish News and other newspapers (NPD Service).

This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when using or in connection with the NPD Service. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Important information

At The Irish News, we take your privacy seriously and we are committed to protecting your personal data. We aim to be clear about how we use personal data and this privacy notice will inform you how we look after your personal data, what personal data we process and why. It applies to both your visit to our website (regardless of where you visit it from) and when you use the NPD Service and our other services.

At The Irish News we collect different types of information about our users for three main reasons:

1. To provide personalised services unique to individual users;

2. To help us to monitor and improve the services we offer; and

3. If we have permission from the user, or where otherwise allowed by law, to market services to them.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

The Irish News Limited is the controller and responsible for your personal data collected through or in connection with the NPD Service. We are based at 113 – 117 Donegall Street, Belfast BT1 2GE, UK and can be contacted there or through the https://newspaperdelivery.me/ website.

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 or practices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Where you can contact us if you have any questions about how your personal data is processed by us

We have appointed a Data Supervisory Officer 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 Data Supervisory Officer dataprotection@newspaperdelivery.me.

What types of personal data we process, where we get that personal data from

As part of our services, we may need to collect use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We also collect, use and share Aggregated Data such as statistical data for any purpose.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless we have your explicit consent to do so. Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

How we use your personal data

We will only use your personal data when the law allows us to. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please contact us at dataprotection@newspaperdelivery.me if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) to deliver your order which may be done by a third party courier company
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(a) Notify you about information relevant to your purchase with us;
(b) Notifying you about changes to our terms or privacy policy
(a) Identity
(b) Contact
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To make suggestions and recommendations to you about services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have registered with us and confirm that you opt in to receive marketing communications from us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Irish News for marketing purposes. We may share your personal data with third party courier companies but these will only use your personal data to fulfil your order.

Opting out

You can ask us to stop sending you marketing messages at any time (or, withdrawing your consent) by following the opt-out links on any marketing message sent to you or by contacting us at dataprotection@newspaperdelivery.me at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see [Link To Your Cookie Policy.]

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at. dataprotection@newspaperdelivery.me.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we disclose your personal data to and why
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your personal data outside of the UK other than to the European Economic Area.

How we store your data securely

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at dataprotection@newspaperdelivery.me.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

What rights you have in relation to your personal data and how you can exercise these rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Address: Information Commissioner’s Office
3rd Floor, 14 Cromac Place, Belfast, BT7 2JB Tel: 028 9027 8757 or 0303 123 1114 Email: ni@ico.org.uk.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

When we receive a complaint from a person, we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide
You have the right to:

If you wish to exercise any of the rights set out above, please contact us at dataprotection@newspaperdelivery.me.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

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

Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at dataprotection@newspaperdelivery.me.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

External Third Parties means:

If you have any queries about our Privacy Policy, please don’t hesitate to contact us.

This Privacy Notice was last modified 21 April 2020