Privacy Policy - White Scribbles

About This Policy

This is the main Privacy Policy for White Scribbles LTD ("White Scribbles News") online publications and for certain products & services provided through our websites, apps, newsletters, e-editions and other digital platforms ("our sites"). It applies to all our sites, and brands, regardless of how you access it, but some of them may publish additional or alternative notices, in such instances those take precedence. Please read this carefully, by using our sites you consent to the collection and use of personal data by us as described in this Privacy Policy.

This Policy explains how White Scribbles Ltd. The data controller is committed to protecting your privacy and promise to handle any information you provide us, via our sites, communications by email and through social media, by telephone and in person, is processed safely and securely. It also covers any information we receive from third parties.

Sometimes our sites may embed content from, or link to third party sites and plug-ins; products & services. These sites and plug-ins; products & services have their own privacy policies. If you follow a link to a third party, we encourage you to review and read the privacy policy shown on their sites. Please note that we are not responsible for the privacy practices or the content of such sites and the information practices of those sites are not covered by this Privacy Policy.

By using our services, including browsing our sites, registering or logging in, making a transaction we may use your information as outlined in this Policy. In this notice ‘we’ and ‘our’ means White Scribbles Ltd, Building Sixty Two, York Road, Birmingham, B28 8BB, which operates this platform.

Who We Are

White Scribbles Ltd is a multichannel media company. Our mission statement "Empowering individuals to flourish, remain humble and seize the opportunity, to live in a world with no barriers, because it's a way of life"

Our Promise

Here at White Scribbles, we stay true to our values, therefore, we recognise the importance of taking your privacy seriously. We are committed to protecting your privacy online, as highly as we would with customer information in any of our systems. We will not share your personal information with trusted partners and/or third parties for any marketing or any other purposes without your consent unless where required by law. We will always respect your privacy and any personal communication between you and ourselves, we will always comply with any data protection legislation currently in force.

We like to be clear and transparent and will always tell you what data we’re collecting about you and how we use it. We only share your data with trusted partners and/or third parties, if we have your consent to do so and will never sell your data. We are committed to always follow industry best practices to ensure your data is stored safely and securely. We protect the confidentiality, accuracy and availability of the information we collect about you. We will always give you control over the communications you receive from us. You can choose the types of messages you receive and whether you want to stop receiving any communications.

In summary, depending on your relationship with us, we’ll use your personal information:

To provide our services and/or products;
To help us to monitor and improve the services we offer;
To sell advertising space on our sites and/or personalised adverts. This helps us to keep the site free for people who visit it. Information gathered in this way does not identify you by name;
To provide the interactive features of our sites, such as commenting, forums and competitions;
To manage our business and to comply with the law.
To remember when you visit our sites and track your browsing patterns by using cookies;
Identify your interests to enhance your experience so that we might serve you with products/services that will interest you;
Communicate with you by email, post, telephone, text message, social media or mobile push message to let you know about any of our products, services or promotions (which, in some cases may be provided by third parties) but only according to the permissions you give us;
Ensure materials on our sites and applications are presented in the most effective manner for you and your computer or mobile device;
Collate and log internet addresses to improve our sites and to monitor sites usage.

We hope that you enjoy using our site, safe in the knowledge that we are committed to protecting your privacy.

Security Of Your Personal Data

All information you provide to us is stored on our secure systems. To protect your personal data against unauthorised processing we have implemented multiple security features including but not limited to; physical, electronic and managerial procedures to protect the information we collect. We have controls to prevent accidental loss, damage, destruction or unauthorised access. However, as effective as these measures are, it is worth remembering that no security systems are impenetrable and data transmission over the internet cannot be entirely secure and therefore, we cannot guarantee that the information you supply will not be intercepted while being transmitted to us over the internet. Furthermore, we cannot guarantee the security of your personal data and/or use of our sites, nor can we guarantee the security of our databases.

Where we have given you (or where you have chosen) a password or other data which enables you to access certain parts of our sites, you are responsible for keeping this password and any other log-in details confidential and we recommend that you do not share your password or other log-in details with anyone. You will be responsible for all activity under your username/log-in details. We will keep your personal data for only so long as is necessary or as otherwise required by applicable law.

Information We Collect

Information you’ve provided and your dealings with us:

We collect information about you when you provide it to us, including when you create an online account, subscribe to one of our mailing lists, respond to one of our promotions or giveaways or events, order or register your interest in one of our products and/or services, or post a comment under an article. This could be via any sites or by telephone, or by post. If you telephone us or if we call you, the call may be recorded for quality, training and management purposes. We may also record customer enquiries via online chat for the same purposes. This information is used to provide our services, display advertising and analyse how visitors use our sites.

You may be invited to provide personal information such as your name, e-mail address, year of birth, gender, street address. We may collect payment information, such as your credit card number and expiration date, where appropriate to process a financial transaction you have requested.

This may include:

(i) Enter our competitions and/or giveaways and/or surveys and/or polls and/or quizzes;

(ii) Sign up for marketing communications;

(iii) Pay for a subscription or purchase any other products/services;

(iv) When you contact us via email, social media, our sites or similar technologies or when you mention us on social media;

(v) Information obtained if we carry out a credit search at a credit search referencing agency.

Information from your device:

In addition to the information you provide to us directly, we also collect information indirectly, such as but not limited to; collection of information from and about the device you are using when you interact with one of our sites or other products and/or services, including adverts.

This may include:

(i) Device Type: Information about your operating system, to tailor the experience to your device.

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

(iii) Unique identifiers: Device IDs to save your preferences.

(iv) Device Settings: Information from your device’s setting such as access to your GPS location.

(v) Network: Your IP address, so that we can recognise if you have visited us before.

(vi) Cookies: Data from cookies or similar technologies placed on your device which tells us about your use of our sites and/or selected third party sites. Please see “Cookies Policy” for more information.

Information about transactions made on any platform:

If you purchase anything or make any other financial transactions on any of our sites, we collect information about your purchase and ask for information including your name, e-mail address and delivery address to be forwarded on to the supplier(s) (if any) who are responsible for delivering your order. This does not include payment information such as your credit/debit card number.

Information from other sources (third parties):

If Applicable, where you have registered or created an account with one of our sites, we may obtain information about you from other companies who have obtained your permission (through their own privacy policies) to share information about you. We may receive information about you from publicly and commercially available sources, as permitted by law, for example, we may receive information about you from a social media site if you connect and/or engage with our sites through that site. We also obtain information about you via cookies placed on your device when you visit third party sites.

Post & comments on articles:

When readers enter into a conversation, for example using polls, comments, text messages, email, phone, radio or letters we reserve the right to display this content indefinitely in any relevant context. Any information you post about yourself or others that you submit on social media sites, including but not limited to chat rooms, blogs and forums, will be viewed by other readers. As such, this personal data may be viewed, collected and used by third parties, including search engines, over which we have no control. We are not responsible for the way these other people use this information. We are not responsible for either the information you submit/post or otherwise make available in such public areas or any use that may be made of such information by any third party. When contributing to a discussion, we strongly recommend you avoid sharing any personal details.

Social media details to log in:

If you log-in to our sites or online services through a third party, such as Facebook, you are granting permission to Facebook to share your user information with us. This will include information such as, your name, email address, date of birth, location, plus any other information you have permitted Facebook to share with third parties, under the privacy policy of the third party. If you remove the White Scribbles from your Facebook settings, or if you remove White Scribbles from your Google settings, we will no longer have access to this data.

Information about other people:

By giving us with information about someone else, you confirm that they have authorised and/or appointed you to provide us with their information (including any sensitive personal data) on their behalf. Before you use any sharing article(s) functions, please make sure that anyone you wish to share with are happy for this to occur and expect to receive the article. You may only share the details of another person with us where you have their express permission.

How We May Use Your Information

Delivering, providing and managing services:

By using our sites and other products and services, we may process your information, to provide a better and more personalised overall experience, which shall include (without limitation):

(i) Communicating with you in relation to your account or information about your chosen services, service updates or other communications;

(ii) We may also provide you with help and support where we believe it is required;

(iii) Delivering customer services and support furthermore, help develop and grow;

(iv) Dealing with, and responding to you about a comment you have submitted;

(v) Ensuring the integrity of votes, competitions and polls;

(vi) Maintaining records of our communications with you if you get in contact with us;

(vii) We may use your information for obtaining customer reviews and conducting market research, to improve the products and services we offer;

(viii) Running competitions effectively and informing you if you have been successful in any competitions or promotions;

(ix) We may use your information for the management of our business and improving the operation of our business and that of our business partners, to assess our internal processes and carry out financial checks;

(x) For security and fraud prevention, and to ensure that our sites and apps are safe and secure and used in line with our terms of use.

Communicating with you:

In accordance with your preferences and data protection legislation, we may use your information to send you direct marketing communications. This may include communications by post, telephone, email or SMS about our products and services.

We may also send you regular newsletters about your chosen services, inform you of promotional offers that you might find interesting, and inform you about our products and services, online news stories and surveys.

Personalisation/Identifying your interests:

We may use your information to provide you with a greater personalised experience when you visit/use one of our sites/apps.

We provide personalisation by using data you submit to us, cookies, IP addresses, web beacons, mobile ad identifiers or similar technologies in relation to the devices you use. By doing so, we can provide you with content and/or advertising that we believe is more relevant to your interests. Please see our “Cookies Policy” below for more information about our use of cookies and similar technologies.

We may also overlay demographic and lifestyle data to help us understand what you might be interested in for insight and marketing purposes (also known as “profiling”).

We will not collect special categories of data - such as information about your race, political opinions, religion, health or sexual orientation.

Tailored and targeted advertising:

We use advertising to fund most of our sites. Some advertising is “contextual” meaning it is shown due to the webpage you are presently viewing. Other advertising, known as “online behavioural advertising” is shown to you based upon your likely interests. This information is collected using cookies and similar technologies. For more information, please see our “Cookies Policy” below.

Sometimes we allow advertisers to show advertisements directly on our sites, which are tailored to your individual needs and interests, based upon information they have obtained.

Other times we will arrange for our customers to be shown advertisements on other sites. These advertisements are tailored to your individual needs and interests with information we have obtained from your browsing on our sites via cookies.

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 sites owners for other purposes, such as linking online behavioural advertising data with your contact details, unless you have provided the advertiser or other site with your express permission to do this.

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 sites (such as your age, gender and city) may also be used to tailor the advertising we arrange to be shown. Your demographic information is not shared with advertisers.

We collect information about the devices you use when you visit our sites, and we combine this information to better personalise the advertisements you see when you visit our properties on another device.

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

Location based services and advertising:

Where we provide services that utilise your device’s location, such as local weather or news, your location will be determined either from a lookup of your IP address in a “GeoIP” database which lists information provided by your ISP (usually your closest town) or 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 via your device settings. We use such information to provide you with a more tailored, relevant experiences when using our sites.

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

Measurement and analytics:

We may use certain information (such as the sites that you visit and advertisements you see or click on) to help advertisers and other promotional partners measure the effectiveness and distributions of their advertisements and promotions.

Improving our services and products:

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

(i) Developing the design and style of our products and services to make improvements;

(ii) Carrying out statistical, technical and logistical analysis to inform our strategic development;

(iii) Blocking disruptive use and ensuring the security of our products and services.

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

Message boards, blogs and other public forums:

Our sites 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 T&Cs & discussions & submission, rules & guidelines for more information.

We may monitor, record and store records of calls, email, text messages, social media messages, in person meetings and other communications where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, for evidential purposes, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. We may use your data to comply with legal and regulatory obligations.

Please see the Cookies Policy for further information.

Legal Bases For Processing Your Data

In order to comply with data protection laws, we will only use your personal data where we have a legal ground to do so. The legal basis will typically be one of the following:

Performance of Contract: We process some of your data as a necessary part of performing our contractual obligations to you, for example managing all stages when you apply for products and services.

Consent: For example, where you have provided your consent to receive marketing emails from us. You can withdraw your consent at any point. We will be obliged to stop processing your data and delete it.

Legitimate Interests: We process some of your data because it is in our Legitimate Interests to do so. For example, when we need to understand our readers, promote our services. For some direct marketing communications, subject to appropriate controls and safeguards with your consent.

Compliance: In some cases, we may have a legal obligation to use or keep your personal data.

How We May Share Your Information

Sharing with third-party partners

Service Providers/Business Partners: When you purchase goods or services from us, we partner with companies to fulfill your order and provide certain customer services. We usually remain the data controller of your information and the other companies only process data under our instructions and cannot use the information for their own purposes. If one of our third-party partners acts as data controller of your personal data (whether or not as a data controller in common with us) we will let you know before you register for the service. When you register or book a ticket for a White Scribbles event organised by an event partner, your registration data may be shared with us by the event partner, for event administration purposes.

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

Affiliates: We regularly partner with industry affiliates to bring you special deals on products and services you may find of interest. These providers collect marketing permissions for us and share data back with us about your purchases for us to measure the effectiveness of our marketing campaigns. If you decide to book a holiday with an affiliate, use their advisory services or set up an account, or purchase a financial product, these affiliates will be data controllers of the information you have provided them to administer your relationship with them and will handle your information in accordance with their own privacy policies.

Functionality: We may share information about you with suppliers that we engage to help us provide our services and/or functionality of our sites. Where this happens, your data will be processed in accordance with the suppliers privacy policy. Some of our sites use third party plug-ins from other organisations. These other organisations may receive and use personal data about your visit to our sites. If you browse or view our sites content, information may be connected and/or collected on their site. For more information on how these organisations use personal data, please read their privacy policies.

Advertisers: We may provide third party advertisers with reports containing aggregate statistical data about our customers’ use of our sites to determine the kinds of people viewing their ads and how they are performing. This aggregated information may include demographic data such as age range and/or geographic location of groups of our customers. This aggregated data does not include contact details (such as names, addresses or email addresses) that can be used to personally identify you or contact you.

OBA Partners: To arrange for our customers to be shown tailored advertisements on other sites, we share cookie information we have obtained from your browsing activities on our properties with the partners.

Marketing personalisation: We may match your data with data, to add extra lifestyle and demographic insight information to your account with us which we then use to make our marketing more relevant to you.

Change of Control: We may transfer and/or reveal any of your personal data or other information described in this Policy to third parties because of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business. We will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with our Privacy Policy.

Required by Law: We will disclose your information and co-operate with appropriate bodies and authorities in good faith where we are required to by law, a court order, a regulatory authority, or otherwise, including with the police, trading standards, regulatory authorities or other relevant authorities.

Details Of Transfers

We are based in the UK but the data that we collect from you may be transferred to, and stored with, a organisation who require access to your information while providing services on our behalf will be governed by contractual restrictions and/or technical limitations to make sure they protect your information and comply with applicable data protection legislation. Where these organisations are based outside of the EEA in a jurisdiction that has not been deemed adequate by the EU, we enter into EU approved model clauses with them to ensure appropriate safeguards are in place. We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.

It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. We can provide more information on this please contact us using contact details below.

Why We May Contact You

From time to time we may send you emails, if we have your permission or if we require to do so to complete a contract for example, telling you your subscription is coming to an end and/or to thank you and/or to notify you if you have won a giveaway. If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.

Working Together

Multiple subsidiaries share infrastructure, systems and technology and all fall under the data control of White Scribbles Ltd. These brands work together to understand how our users interact with our products and services, and to share insights to improve our products and services.

Your Rights Under The GDPR

Access: If you wish to exercise your right you will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). You can contact us using contact details provided below. We may make a reasonable charge for additional copies of that data beyond the first copy, based on our administrative costs.
Deletion: You also have the right to ask us to delete your personal data or restrict how we use it, please contact us using contact details provided below. However, there may be circumstances where we are legally entitled to retain it.
Rectification: If you wish to update or rectify your data, please contact us using contact details provided below.
Revoke consent: If you wish to object to the processing of your data for direct marketing or online behavioral advertising purposes, you can opt-out by updating your settings or, for direct marketing, please contact us using contact details provided below.
Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalisation purposes, please contact us using contact details provided below.
Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party please contacting us as using contact details provided below stating the nature of and reasons for such objection.
Complain: You also have the right to lodge a complaint about us with our supervisory authority, the Information Commissioner’s Office. But before you do so, please do contact us first to give us a chance to put matters right. Please contact us using contact details provided below.

If you are contacting us to exercise any of your rights under the GDPR, you will have to provide valid proof of identification. We will deal with your request within one month. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. . However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Using Children’s Personal Data:

We do not aim any of our products or services directly at children under the age of 16 and we do not knowingly collect personal data about children under 16. Some of our products or services may have a higher age restriction and this will be shown. If you are under the age of 16, we request that you do not provide us with your information and do not use our sites.

If you are a parent or guardian of a child under 16, please contact us if you are aware that your child has used our sites or otherwise provided their information to us without your consent. We will delete or otherwise cease processing your child’s personal information within a reasonable time. If you are aged under 16, we request that you seek your parent or guardian’s permission before providing us with your information or using our sites.

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.

How Long We Keep Your Personal Data

In general, we keep your personal data for only as long as we need to, and no longer than necessary in relation to the purpose under which such data was collected. How long we need your personal data depends on the purpose for which it was collected, plus a short additional period in case of problems. How long we keep it therefore varies according to the type of information it is and why we have it, and will range from a few days or weeks to, in some cases, several years. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services.

We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. If you request to delete your account we still have to retain some data for fraud prevention purposes. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.

Cookies Policy

We collect information about you automatically when you visit our sites by using cookies (small text files) and other tracking technology. This Privacy Policy includes our Cookies Policy, for more information about cookies, and other tracking technology including how to turn them off, please see our Cookies Policy. You can find details of our key advertising partners too.

Updates To This Policy

We reserve the right to make changes to this Policy. Where changes are made, we will post the revised Policy on this site, such changes will become effective as soon as they are posted. Please check our Privacy Policy regularly for any changes.

How To Contact Us

If you have any queries or comments about this Policy.
If you have any concerns about how your personal data is used.
If you would like to exercise any of your rights under the GDPR, please contact us by email at:

[email protected] - using subject line: Data Protection Officer

Emails will be dealt with by the Data Protection Officer and will be responded to within 30 days.

If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.

If you have a question about anything else, please see our Contact us page here.

Glossary

Personal Data - Is any information about you by which you can be identified by such as; your name, date of birth, email address, postal address, phone number, mobile number and/or debit card details.
Data Controller - A company that decides how it uses personal information.

Updated to reflect changes resulting from the General Data Protection Regulation. – 27 July 2018.