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Privacy Policy

Privacy, Cookies and Fair Processing Notice

 Website Privacy Policy

 Introduction

1.1       We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.

1.2       By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

 

  1. Collecting personal information

2.1       We may collect, store and use the following kinds of personal information:

(a)        information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);

(b)       information that you provide to us when registering with our website (including [our email address);

(c)        information that you provide when completing your profile on our website (including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details);

(d)       information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including [your name and email address);

(e)       information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);

(f)        information relating to any purchases you make of our services or any other transactions that you enter into through our website (including your name, address, telephone number, email address);

(g)        information that you post to our website for publication on the internet (including [your user name, your profile pictures and the content of your posts);

(h)       information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and

(i)         any other personal information that you choose to send to us.

2.2       Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

 

  1. Using personal information

3.1       Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

3.2       We may use your personal information to:

(a)        administer our website and business;

(b)       personalise our website for you;

(c)        enable your use of the services available on our website;

(d)       send you goods purchased through our website;

(e)       supply to you services purchased through our website;

(f)        send statements, invoices and payment reminders to you, and collect payments from you;

(g)        send you non-marketing commercial communications;

(h)       send you email notifications that you have specifically requested;

(i)         send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);

(j)         send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);

(k)        provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);

(l)         deal with enquiries and complaints made by or about you relating to our website;

(m)      keep our website secure and prevent fraud; and

(n)       verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).

3.3       If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.

3.4       Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.

3.5       We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.

 

  1. Disclosing personal information

4.1       We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

4.2       We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

4.3       We may disclose your personal information:

(a)        to the extent that we are required to do so by law;

(b)       in connection with any ongoing or prospective legal proceedings;

(c)        in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

(d)       to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and

(e)       to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

4.4       Except as provided in this policy, we will not provide your personal information to third parties.

 

  1. International data transfers

5.1       Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

5.2       Personal data shall not be transferred to a country or territory outside the European Union unless that country or territory ensures an adequate level of protection for the ‘rights and freedoms’ of data subjects in relation to the processing of personal data.

The transfer of personal data outside of the EU is prohibited unless one or more of the specified safeguards or exceptions apply;

  • Binding corporate rules
  • Model contract clauses in place

5.3       Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

5.4       You expressly agree to the transfers of personal information described in this Section 6.

 

  1. Retaining personal information

6.1       This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

6.2       Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3       Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:

(a)        to the extent that we are required to do so by law;

(b)       if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c)        in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

 

  1. Security of personal information

7.1       We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

7.2       We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

 

  1. Amendments

8.1       We may update this policy from time to time by publishing a new version on our website.

8.2       You should check this page occasionally to ensure you are happy with any changes to this policy.

 

  1. Your rights

9.1       You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

  • the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

9.2       We may withhold personal information that you request to the extent permitted by law.

9.3       You may instruct us at any time not to process your personal information for marketing purposes.

9.4       In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

 

  1. Third party websites

10.1     Our website includes hyperlinks to, and details of, third party websites.

10.2     We have no control over, and are not responsible for, the privacy policies and practices of third parties.

 

  1. Updating information

11.1     Please let us know if the personal information that we hold about you needs to be corrected or updated.

 

  1. Google Analytics

12.1   We use a tool called ‘Google Analytics’ to collect information about the use of this site.     Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site.

 

12.2   We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.

 

12.3    Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy . You can prevent Google Analytics from recognising you on return visits to this site by disabling cookies on your browser.

 

  1. Data protection registration

12.1     We are registered as a data controller with the UK Information Commissioner’s Office.

12.2     Our data protection registration number is Z2340694

 

  1. Our details

13.1     This website is owned and operated by Kay Publishing Ltd.

13.2     We are registered in England and Wales under registration number 06979505, and our registered office is at 49 Station Road, Polegate, East Sussex, BN26 6EA                     ]

13.3     Our principal place of business is at PO Box 2237, Pulborough, West Sussex, RH20 9AH

13.4     You can contact us:

(a)        by post, using the postal address;

(b)       using our website contact form;

(c)        by telephone, on 01903 868474; or

(d)       by email, using info@sussexlocal.net

Cookie Policy

This website uses cookies.  By using this site you agree to this policy and consent to the use of cookies in accordance with this policy.

We want to ensure that your use of our website is user friendly, useful and reliable.  Where services are delivered on the internet, this sometimes involves placing small amounts of information on your computer or other device such as your mobile phone.  These include small files known as “cookies”.  We do not use these to identify you personally, or to hold any personal data.

These pieces of information are used to improve services for you through, for example:

Enabling a service to recognise your device so you don’t have to give the same information several times during one task

Recognising that you may already have provided a username and password so that you don’t need to keep repeating these for every web page requested

Measuring how many people are using services so they can be improved and there is enough capacity to ensure they are responsive

Cookies are small files, containing an ‘identifier’ given to your browser by a website which may be stored as text files (letters and numbers) in the cookie directory of your computer.  Cookies are not programmes and cannot collect information from your computer.  They do not damage your computer and are defined as ‘a piece of text stored on a computer by a web browser, a cookie can be used for authentication, storing site preferences, shopping cart contents, the identifier for a server-based session, or anything else that can be accomplished through storing text data’.

Our website may send cookie data to your browser, which may save it if your browser’s preferences allow it to do so.  To protect your privacy your browser only returns a cookie to the website that sent you the cookie and does not send it to any other website.  A website cannot access your cookie directory or information on your computer, instead relevant cookies are included by your browser within each request you make to the website.  A website can only obtain cookie data that your browser sends to it.  Cookies do not contain any information that personally identifies you.  There are two types of cookie used:

Persistent cookies remain on your computer for a specified time and so are saved to your computer’s hard disk. We use persistent cookies to:

  • Identify that a registered user has returned
  • Securely remember your login User ID – if you have asked us to do so
  • Understand how you use our site and obtain information on website usage (as described above)

Session cookies are deleted when you close your browser and are not usually saved to your computer’s hard disk. We use session cookies to:

  • Identify that you have logged in to the site
  • Hold your search criteria while you are carrying out a search of the website
  • Collect information on website usage – as described above

In particular, we use Google Analytics to analyse the use of this website.  This generates statistical and other information about website use by means of cookies, which are stored on users’ computers.  The information generated, relating to our website, is used to create reports about the use of the website.  Google will store this information.  (Google’s privacy policy is available at http://www.google.com/privacypolicy.html).

You do not have to accept cookies and you can change the settings within your browser to accept all cookies, reject all cookies, reject cookies from certain websites, notify you if a site is requesting to set a cookie, and set various other options.  You can also delete cookies already stored on your computer, although this may have a negative effect on the use of websites.  Please see your browsers settings to do so.

Switching off cookies will still allow you to view the majority of content on our website.  However, it will prevent you logging in and so accessing personalised information.  It will also stop us remembering your login User ID, if you ask us to do so, and may restrict your use of our interactive tools and of some services available.

For further information or if you have any questions about the cookies we use or this policy please contact us.

Fair Processing Notice

  1. Scope

All data subjects whose data is processed by Kay Publishing Ltd (The Company)

 

  1. Responsibilities:

The Data Protection Officer / GDPR Owner is responsible for ensuring that this notice is placed in front of potential data subjects prior to The Company collecting/processing their personal data. All Employees/Staff of The Company who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

 

  1. Fair Processing Notice:

The personal data we collect from you will be used for the following purposes:

  • By consenting to this, you are giving us permission to perform those actions.
  • Read more about how and why we use your data here [link].
  • You may withdraw consent at any time by [describe how the user withdraws consent].

 

What is Personal Data?

Under the EU’s General Data Protection Regulation:

Personal Data is defined as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

 

Special Categories of Personal Data:

Certain data are classified under the Regulation as” special categories”:

  • Racial
  • Ethnic origin
  • Political Opinions
  • Religious Beliefs
  • Trade-union membership
  • Genetic Data
  • Biometric Data
  • Health Data
  • Data concerning a natural person’s sex life
  • Sexual orientation
  • Other

 

Consent is required for The Company to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

 

Why does The Company need to collect and store personal data?

In order for us to provide you with a service we need to collect personal data for correspondence purposes and  provision of the service.  We are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

We may pass your personal data on to our service providers who are contracted to The Company in the course of dealing with you.

Our contractors are obliged to keep your details securely, and use them only to fulfil the service they provide you on our behalf. Once your service need has been satisfied or the case has been closed, they will dispose of the details in line with The Company’s procedures.

If we wish to pass your sensitive personal data on to a third party we will only do so once we have obtained your consent, unless we are legally required to do so.

 

How The Company uses your information:

The Company will process – that means collect, store and use – the information you provide in a manner that is compatible with the EU’s General Data Protection Regulation (GDPR).

We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary.

In some instances, the law sets the length of time information has to be kept, but in most cases The Company will use its discretion to ensure that we do not keep records outside of our normal business requirements.

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

 

Using your personal data:

We will use the information you provide for the following purposes:

  • You do not have to agree to this. If you object to the use of your personal data for this purpose, please email role@organisation.com and ask for removal of your details. All our electronic marketing material carries an unsubscribe option, so you can also unsubscribe at any time.’

Document Owner and Approval:

The Data Protection Officer / GDPR Owner is the owner of this document and is responsible for ensuring that this procedure is reviewed in line with the review requirements of the GDPR