D. How do we share your personal data?
We will never sell, rent or swap your personal data or give it to anyone else for them to use for their own purposes without making that clear to you. There are, however, various ways in which we will share your data, as set out below:
As part of a group of companies commonly owned by Smiths News plc, we share various business operations and processes with our respective businesses. Accordingly, we may share your personal data with these businesses in order to fulfil our contractual obligations to you, or because it is in our legitimate interests to do so (for example, whilst you may order a product from us, the delivery of that product might be fulfilled by another of our businesses). You can see a list of our businesses within our latest Annual Report and Accounts which can be located on the Smiths News website (investor zone) at www.smithsnews.co.uk.
We engage various third parties to provide services to us for specific functions or which are part of our wider supply chain (e.g. our publisher clients) and this will often mean that we need to share your personal data with any of them (it is in our legitimate interests to do so, since we may not have the capabilities to provide these services ourselves and to ensure an orderly performance of any service to you). In each case, we will ensure that these third parties are only allowed to use your personal data in order to provide the relevant services to us and you. We will always make sure that we use organisations that we trust to look after your personal data appropriately and as required by applicable laws.
Some examples of these third parties will include: publisher clients, distribution services, sub-contractor services, credit card processing services, accounts payable and accounts receivable services, order fulfilment, analytics, website management, information technology and related infrastructure provision, customer service, e-mail service providers for sending transactional and marketing emails, auditing, and other similar services.
We may from time to time work with online advertisers, social media platforms and advertising networks to deliver, tailor and measure marketing communications and advertising to you and others, both on the site and elsewhere on the internet (including on social media platforms such as Facebook and Twitter). We also use various Google tools to deliver, measure and tailor our online marketing communications and advertising.
The personal data that these third parties see would never include information such as your bank, credit / debit card or full address details – it relates only to online identifiers such as IP address, data from cookies or similar technologies, or other device related usage information.
Similarly, we may share certain online identifiers with analytics and search engine providers that assist us in the improvement and optimisation of our site.
You can choose not to allow your data to be used to deliver targeted advertising by changing your settings within social media platforms and via Google’s own Ads Settings. You can also contact us in one of the ways specified at section 5 below if you would prefer us not to use your data in this way.
All customer data held by us is considered our property. Accordingly, if we sell or propose to sell our business or part of it, we may need to disclose your personal data to prospective buyers.
Similarly, if there are changes to our structure or if our ownership changes, we may need to disclose your personal data to the new owners or operators of this site or any of our apps as part of that process.
There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime.
There may be occasions where we agree with you that your personal data can be shared with carefully selected third parties (such as the National Federation of Retail Newsagents (NFRN), market survey providers and/or resellers of adjacent fast moving convenience goods) who may offer products or services which may be of interest to you. Where we seek to do so, we will ensure that we have your specific, informed and affirmative consent to do so but please rest assured that your consent may be equally withdrawn at any time, simply follow the instructions given at the time of the marketing communication (e.g. clicking an ‘unsubscribe’ button or contact us in one of the ways specified at section 5 below).
We may share your information such as name and contact details with NewstrAid Benevolent Fund when you make weekly donations to the Charity or when you take part in other fundraising activities, such as participating in the NewstrAid lottery. We rely on the legitimate interest of the Charity in raising funds to support its activities to do so, and provide the option to opt out of making donations or taking part in such other fundraising activities to the Charity by contacting your local Smiths News Customer Services Team or by visiting http://www.newstraid.org.uk/donate/.
4. Security and retention of your personal data
We take the security of your data very seriously. We have implemented various strategies, controls and measures to keep your data secure and keep these measures under close review. In addition, we ensure that any payment transactions will be encrypted using SSL technology, and that all payment card data is protected according to industry approved security controls (the Payment Card Industry Data Security Standard).
There are ways that you can help – for example, where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or any of our apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have a detailed internal retention policy that sets out varying retention periods for different categories of data depending on our legal obligations and whether there is a commercial need, such as answering customer account queries. After a retention period has elapsed, the data is securely deleted.
You can help us keep our records up to date by telling us when your contact details and other personal information changes. If you tell us of any changes (either to your personal information or how you wish us to contact you from time to time) it may take a short while for such changes to take effect but rest assured that we respect your rights and will endeavour to process such changes as soon as possible.
5. Your rights and how to contact us
The law gives you a number of rights in relation to your personal data and our use of it. You have the right:
(a) to ask us not to use your personal data for direct marketing purposes;
(b) to ask to see what personal data we hold about you and to find out about the way that we process the data (and in some circumstances, you can ask us to provide a copy to a third party);
(c) to ask us to correct or update any personal data which is inaccurate;
(d) to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to use it;
(e) to ask us to temporarily stop using your data if you don’t believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it; and
(f) not to be subject to decisions made solely on the basis of ‘automated processing’ (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.
You also have the right to complain about our use of your personal data. You can contact the Information Commissioner’s Office via their website: https://ico.org.uk/concerns/ or by calling 0303 123 1113.
© v5.1 April 2022