Primas Media Ltd are a controller for the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulation 2016/679. This means that we are responsible for, and control the processing of, the personal information you provide to us when using our services and this website in accordance with this privacy policy.

Primas Media Ltd understands that customers care about the use and storage of their personal information and we value your trust in allowing us to do this in a careful and sensible manner. We have created this privacy policy statement in order to demonstrate our commitment to the privacy of our customers.

By using our services, subscribing to our publications, entering our competitions and giveaways, using our websites (including our mobile site), our mobile app, our social media pages and any other Primas Media service, you are acknowledging that we are processing your personal information and, where necessary, consenting to such practices, as outlined in this statement.

Personal information which we collect

We collect personal information about you (and others if their personal information is provided by you) when you:

(a) subscribe to any of our publications;

(b) participate in competitions or promotions;

(c) request a trial subscription;

(d) sign up for our newsletter and other marketing emails (in line with Marketing below);

(e) post material to our website and/or social media page;

(f) complete customer feedback or surveys;

(g) speak to one of our representatives, call centre agents or members of our customer services or PR team;

(h) and/or use our website and customer applications in any other way.

The personal information collected in the above manner may include the following about you (and others if their personal information is provided by you):

(a) full name;

(b) postal address;

(c) email address;

(d) telephone number;

(e) payment details;

(f) geo-location;

(g) machine identifiers (such as IP addresses);

(h) dispute resolution information;

(i) disability and health information;

(j) behavioural data (tags and cookies – see Cookies and Tracking section below);

(k) voice recordings.

 

Personal information provided by third parties

We may receive information about you from other sources (such as the Mail Preference Service), which we will add to the information we already hold about you in order to help us provide our products and services in accordance with your requirements and to ensure that the quality of data we have on your account(s) is maintained properly. We may also obtain information about you from social media providers such as Twitter and Facebook.

 

How we use your information

We will collect personal information:

1) In order to take the necessary steps in preparation of, or to fulfil our obligations under, a contract (such as a subscription to one of our publications):

a) Orders and payments – provide communications about subscriptions, products and services being provided to you (and others if their personal information is provided by you);

b) Update you on matters affecting your subscription – contact you (and others if their personal information is provided by you) in the event of a change that affects a subscription or any data or personal information you have provided us with, such as changes to terms and conditions of your subscription or this privacy policy;

c) Website service communication – provide notifications of any changes to our website or to our services that may affect you (and others if their personal information is provided by you);

d) Customer service communication – provide you with requested information or correspondence, such as an enquiry made by you;

e) To provide assistance in completing subscriptions – send reminder emails to continue with a booking which is in your “basket” on our websites or mobile app but is not paid and completed;

2) with your consent:

a) Marketing communications – create a profile about you for marketing purposes to tailor our communications to you. We may use automated processes to do this;

b) Promotional offers – inform you about promotional offers and other products or services that may be of interest (in line with Marketing communications above);

c) Maintain records indicating your consent to status – to ensure we accurately reflect your wishes when communicating to you;

3) in our legitimate interest* improve our services:

a) Market research – to contact you (and others if their personal information is provided by you) to ask about the experience of using our products as part of a continual programme of customer service improvement. This is not marketing communication and is separate to Marketing communications above.

b) Website customisation – to customise our website and its content to your particular preferences in accordance with the Cookies and Tracking section below;

c) Customer support – monitor calls and help train staff in relation to our customer support and helpdesk function;

d) Product and service improvement – to improve our product and services;

e) Service analysis – to conduct research, statistical analysis and behavioural analysis. This may include providing aggregate statistical information relating to customers, sales, traffic patterns and related site information to reputable third parties.

4) in our legitimate interest* to protect against fraud:

a) Website improvement and fraud prevention – improve our websites, prevent or detect fraud or abuses of our websites and enable third parties to carry out technical, logistical or other functions on our behalf;

b) Security – carry out security checks when allowing you access to our services and to block fraudulent or suspected fraudulent activity.

5) in order to meet our legal obligations:

a) Taxation – ensure we meet our tax and other regulatory obligations;

b) Registration – ensure local jurisdiction regulations are complied with (where registration is necessary in such jurisdictions).

* any reliance on legitimate interest shall not prejudice your interest or fundamental rights and freedoms.

 

Marketing

We may periodically send promotional material to you about new products, special offers or other information which we think you may find interesting based on the profile we have created about you to the email addresses, postal addresses and phone numbers which you have provided.

If these are similar to products, services and bookings previously supplied by us to you, we will assume, under our legitimate interests to promote similar goods and services, that you are willing to receive this information unless you tell us otherwise. Please note that we do not want to send you information that you do not want to receive and you can opt out at any time (please see ‘The right to ask us to stop contacting you with direct marketing’ below for further information).

We will always ask your permission before sending you email marketing information. We do this by asking for your positive confirmation (e.g. by providing a tick or inserting your contact details in the relevant boxes) indicating that you wish to receive marketing and you can opt out at any time (please see ‘The right to ask us to stop contacting you with direct marketing’ below for further information). This ensures you only receive information that you have given us permission to send and are willing to receive.

Our approach to information security

To protect your information, Primas Media Ltd has policies and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in a secure and sensible manner and all systems that can access the information have proportionate and reasonable security measures in place. To achieve this, employees, contractors, sub-contractors and third party suppliers have contracts, with defined roles and responsibilities.

Your rights

In order to process any of the requests listed below, we may need to verify your identity for your security. In such cases your response will be necessary for you to exercise this right.

 

The right to access information we hold about you

At any point you can contact us to request details concerning the information we hold about you, why we have that information, who has access to the information and where we got the information. In most cases you may be entitled to copies of the information we hold concerning you. Once we have received your request we will respond within 30 days.

 

The right to correct and update the information we hold about you

If the data we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.

 

The right to have your information erased

If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.

 

The right to object to processing of your data

You have the right to request that Primas Media Ltd stops processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your data to comply with your other rights.

 

The right to ask us to stop contacting you with direct marketing

You have the right to request that we stop contacting you with direct marketing. On promotional emails we provide an ‘unsubscribe’ link at the bottom of the email which will unsubscribe you from that service. You can also unsubscribe by emailing datacontroller@primasmedia.co.uk

Please note it is not possible to ‘opt-out’ of receiving communication from us which relates to an ongoing service (such as a subscription to one of our publications) which we are still fulfilling (which are not considered marketing for these purposes). This ensures that we can always contact you as a result of circumstances that may affect your dealings with us and in order for us to improve our services going forward.

The right to data portability

You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so.

The right to complain

You can make a complaint to us by emailing datacontroller@primasmedia.co.uk

Consent

In those cases where we need your consent to process your information, we will ask you to make a positive indication (e.g. to tick a box or insert your contact details on the relevant form or web page requiring consent). By actively providing us with your consent, you are stating that you have been informed as to the type of personal information that will be processed, the reasons for such processing, how it will be used, for how long it will be kept, who else will have access to it and what your rights are as a data subject and that you have read and understood this privacy policy.

 

Sharing your information

The information and data we collect is important for Primas Media Ltd and we understand that you care about the use and storage of your personal information and we value your trust in allowing us to do this. We would not want to share this with anyone else unless we have your express consent, we will never disclose, rent, trade or sell your personal information to any third parties for their marketing purposes.

We do disclose or transfer your data or personal information to other companies, data processors or agents employed by us to perform any necessary functions on our behalf (such as hosting and maintaining our website, providing us with data management systems, postal mailing services and support services), but they are bound by similar terms to those set out in our privacy policy and may not use this information for their own purposes.

In the event that Primas Media Ltd or any part of its business is sold to or integrated with another business, Primas Media Ltd may disclose your personal information to the new owners (and their professional advisers on the transaction) to be used by the new owners and their group of companies in the same ways as set out in this privacy policy, including to continue providing you with the same services and marketing information services as are currently provided by Primas Media Ltd.

We may also provide aggregate statistics about our customers, sales, traffic patterns and related site information to reputable third parties in order to better understand our services, website and overall customer satisfaction which may include personally identifying information.

 

Use of cookies

The websites and mobile apps owned by Primas Media Ltd use cookies and tags. A cookie is a small text file that can be stored by your browser on the device you use to access internet and allows the browser to pass small amounts of information about user behaviour on the given website to a web server. Tags are pieces of code that exist on web pages and collect information about usage of the web pages.

At Primas Media Ltd we use our own cookies and tags as well as those from third parties to enable the smooth operation of the websites, such as the use of the basket function or to automatically log you in when you visit (with your permission). We also use cookies/tags to monitor visits to our website and continuously look for places to improve your website experience. Our marketing partners also use cookies and tags to monitor the performance of our advertising. We will never share any personal information about you with these third parties and the cookies and tags used maintain your anonymity.

 

Cookie Consent

The first time you access a Primas Media Ltd website, you will be informed about our use of cookies to improve your site experience. By continuing to browse our website you consent to our use of cookies.

 

Description of cookies

Example

Google Analytics

These cookies give us critical information about various pages on the websites and how our users interact with them. We use this information to improve the performance of our website and the information presented to users

Example

Primas Media website

When you create an account, these cookies allow the website to remember you in order present you with information that is directly relevant to you.

How to reject and delete cookies

Should you wish to reject or block the use of cookies, you can do so at any time, usually by clicking ‘Help’ on your browser. Cookies are specific to individual browsers so if you use more than one browser, you will need to delete cookies on each browser. Please be aware though that by rejecting cookies you may not receive the optimum website experience.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit: www.allaboutcookies.org.

 

Contact details

If you have any queries about this policy, need further information or wish to lodge a complaint you can use the details below to contact us.

Data Protection Officer

Primas Media Ltd

The Pentagon Centre

36-38 Washington Street

Glasgow G3 8AZ

datacontroller@primasmedia.co.uk

 

Changes to this Privacy Policy

We may change this policy from time to time. You should check this policy occasionally to ensure that you are aware of the most recent version that will apply each time you access the website.