1. What is in this policy?
This policy tells you:
· what information we might collect about you
· how we might use that information
· when we might use your details to contact you
· what information of yours we might share with others
· your rights about the personal information you give us
2. Who are we?
Our services sometimes link to services or adverts run by other companies. These take you away from any P.A.Haddington radio station websites also apps we are on, and these companies have their own privacy and cookie policies. Please remember you should know that we have no control over the content or privacy practices of those other platforms and that the information you give them will follow their policies and rules and not ours. We advise you to check their privacy policies before providing your information to them as this is a safe legal advice as we are not solely responsible for you visiting a third party service.
3. What personal information do we collect?
The information we may collect about you will vary depending on how you interact and engage with us. It may include the following:
a. General identification and contact information
We may collect your name, address, phone number, email address, IP address, user name, password, age, gender, date of birth.
c. Sensitive information
We may collect your racial or ethic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation. e.g. radio discussions or survey answers you have chosen to provide on radio may indicate or tell us such information.
d. Device information
We may collect some technical information from devices (e.g. computer, mobile, TV, tablet, speaker or other voice-enabled devices) and web browsers. This might include IP address, device ID. We will uniquely identify each instance of that use as this helps us to know who is listening to our station.
e. Marketing preferences
We may collect information if you access our services or programmes such as how you use our services and the articles you read.
f. Information if you communicate with any of our stations or website
if you email or otherwise communicate with us, we may collect your name, location and a brief summary of your contribution or opinion. Please note this may include sensitive information (e.g. political opinion, trade union) as above
g. Location information
When you first use Apps we are on, you will be asked if we can use your location in order to offer you services and information that is relevant to your area. We will also have information regarding your general geographic location based on your IP address and the GPS of your mobile device.
h. Information on your activities outside P.A.Haddington’s Radio’s Websites when you comment on P.A.Haddington’s Radio’s Website.
We will not normally collect any sensitive personal information from you (unless you provide it to us as above), and will, in any event, ask for your express consent to hold this information if we need to do so.
Please do not submit such personal information or sensitive information if you do not wish us to collect it.
4. What information do we collect about you from other sources?
We may obtain additional information about you from trusted third parties and public sources:
a. to assist us in our marketing, including Online Behavioural Advertising, and to ensure that you receive adverts and other information that is relevant to you, For example, when you have entered a competition or completed a survey/questionnaire and have agreed that this data may then be shared with others including P.A.Haddington’s Radio’s Website(s) . This information may include details about our users’ demographics, interests and classifications and be used to place users in particular groups or segments for targeting advertising. Some of this information may also have come from publicly available sources.
5. How do we use your Personal Information?
We have to have a valid reason to use your personal information. This is called a “lawful basis for processing”. We process personal information for the following legal basis:
We use your personal data if we have your consent. We rely on consent for the following:
– to enable you to login to your account (If available)
– to answer you when you have contacted us, or to respond to a comment or complaint
– to send you notifications on your device if you have selected them
You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
b. The processing is necessary to fulfil a contract
We may process your data when we need to fulfil a contract with you.
c. Legitimate Interest
We process your data when it is in our legitimate interest to do this and when these interests are not overridden by your data protection rights.
Our legitimate interests include:
– to improve our content, listener experiences by monitoring your use of our radios , websites and working with our third parties to improve the websites and radio station(s) we offer, develop new content eg..
– to ensure the security and integrity of our websites eg..
– to ensure that our Websites and Apps operate effectively
– to protect listeners and other individuals and maintain their safety, health and welfare
– to deal with your requests, complaints and enquiries
d. Necessary to comply with a legal and regulatory obligations
We may process your personal information to comply with our legal and regulatory obligations e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and complying with law enforcement agencies.
6. Who do we share your personal information with?
We may carry out research or analysis, which contains your personal information, via our sites, and share aggregated responses to questions with our partner organisations.
d. Our service providers
We may share your personal data with our external third-party service providers.
These include accountants, auditors, lawyers, other professional advisors, IT systems, support and hosting service providers, printing, advertising, marketing, market research and analysis service providers, website analytics and online behavioural advertising providers, technical engineers, data storage and cloud providers and similar third party vendors and outsources service providers that assist us in carrying out business activities.
e. Government authorities and third parties
f. Other third parties
7. Personal Information relating to children and minors
Our services are not directed towards individuals under the age of 16 unless supervised by an adult .
We do not knowingly use or process the personal information of children under 18 years of age either directly or indirectly.
8. How long do we keep your information for?
We hold personal data for different purposes and the length of time we keep your information will vary depending on the services or products we are providing. We will only keep your data for a reasonable period of time, which is based on the purpose for which we are using your data. Once that purpose has been fulfilled, we will securely delete that data or anonymise your information (so that we, or anyone else, can no longer tell that data relates to you) unless we are required to retain the data longer for legal, tax or accounting reasons.
To determine the period we store personal data, we always stick to these principles:
– we will only keep your information for as long as we need to
– we think about what type of information it is, the amount collected, how sensitive or intrusive it might be and any legal requirements
we design our services so that we do not hold your personal information longer than we have to.
9. International Transfers of Personal Information
Personal information which you supply to us is generally stored and kept inside the European Economic Area.
However, due to the nature of our business and the technologies required, your personal information maybe transferred to a third party service provider outside the EEA. These countries may not have the same data protection laws, including a lower level of protection.
If we do need to transfer your personal information in this way we take steps to ensure your level of privacy including data minimisation, anonymising or pseudonymising data, undertaking due diligence on the recipients and putting in place contractual obligations on them to take care of your data, for example EU model clauses, or in the case of US recipients, a Privacy Shield certification.
However these maybe very unlikely due we keep it within UK & European Economic Area.
10. Your rights in relation to how we use your personal information.
Data Protection laws give you certain rights in respect of your personal information. You have the following rights:
· Right to rectification
The right to have your personal data corrected if it is inaccurate or incomplete. You can also manage some of this yourself if you have registered with us via one or more of our websites.
· Right of access
You have the right to obtain your personal data from us. This is referred to as a data subject access request.
· Right to be erasure (“right to be forgotten”)
You have the right to be forgotten.
· Right to object and opt-out of marketing
You have the right to object to the processing of your personal data. This includes the right to object to direct marketing. You will always be given the opportunity to opt-out of further direct marketing when you receive such communications from us (if available) or you can contact us at email@example.com
· Right to portability
You have the right to move, copy or transfer certain personal information
· Right to restrict processing
You have the right to restrict the use of your information in certain circumstances
· Right to opt-out of automated individual decision-making (including “profiling”)
You have the right not to be subject to a decision based solely on automated processing, including profiling, which significantly affects you or produces legal effects.
If you wish to submit a request in relation to any of your rights above, please contact us at: firstname.lastname@example.org. Please note you will be asked to supply us with proof of identity like full name eg.. before we will be able to provide you with a response.
11. Contact Us and Complaints
The data controller responsible for your personal information is P.A.Haddington .
If you do have any concerns we would like you give us the opportunity to know about them so we would encourage you to contact us first so we can try and to help you: email@example.com
If you do not think we are handling your personal information adequately, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, are available at ico.org.uk.