Rich World

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Privacy Policy

Introduction
This Privacy and Cookie Policy (this Policy) explains how we collect, use, share, disclose or otherwise process personal information we hold about you. Understanding what our audiences prefer allows us to personalise content, show relevant adverts, and generally improve your experience of our products and services.

About Us
Rich World and its subsidiary companies listed below (together “Rich World”, “we”, “our” or “us”) will collect, use, share and disclose or otherwise process your personal information in line with this Policy. The relevant data controller for your data will depend on which product or service you have interacted with or to which title you have subscribed as set out below.

Collection of information
In This Section
You can find out more about how and when collect your personal information.
Registration, Forums, Apps and your Dealings with Us
We collect information about you when you provide it to us: for example, when you fill out our online forms, subscribe to one of our titles, enter a competition being run on one of our radio stations, respond to our promotions, call or text in to the radio studio, register and use one of our apps, enquire about our products and services or participate in a reader forum (which could be on any medium). We may record phone calls or customer enquiries via online chat for quality, training and management purposes.

Information from Devices
We also collect information automatically when you interact with our websites or use our apps. This can include information about your device, including its Advertising ID (e.g. Google’s Advertiser Identification or Apple’s Identifier for Advertisers) and general geographic location. This can be to provide services that have copyright restrictions, to deliver news that is relevant to where you are, tailor advertising to your interests and provide a better experience . We may also collect information from cookies placed on your device. See the section on Cookies for more information about our use of cookies. With your consent, we may also collect the specific location of your device or request access to data from other applications to provide certain services you have requested.

Social Login
If you log in to our websites or online services through a third party site, such as Facebook, that site may pass information to us, such as user ID, name associated with the ID, email address and location, plus other information permitted under the privacy policy for that website. Our websites and apps may also return information about you to that social networking site regarding your log in, such as which Rich World websites and apps you visit and your use of the social media services on those websites and apps.

If you log in with or connect to your account using social media (Facebook, Twitter, etc), the social media service’s use of the shared information will be governed by their privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your Rich World account, and do not participate in social sharing on our websites or apps.

Posts, Comments and Interaction
If you correspond with any of our titles or radio stations, or interact with other customers or audience members or our staff, for example by using polls, comments, text messages, video, email, phone, radio or by post, we may disp

Posts, Comments and Interaction
If you correspond with any of our titles or radio stations, or interact with other customers or audience members or our staff, for example by using polls, comments, text messages, video, email, phone, radio or by post, we may display this content indefinitely in any relevant context, subject to our editorial judgement and your rights as set out in this Policy. This may be anonymised in the case of testimonials or customer service conversations.

If you take part in any reader or listener forums, send us letters for publication, or take part in any radio ‘phone-ins’, then you may be identifiable to others publicly and your comments attributed to you.

Public Information and Posts
Any information about yourself or others that you post on our social media pages, on platforms like Twitter, Facebook and other chat rooms, blogs and forums, will be viewed by others (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in such public areas, and you acknowledge that this may be collected and used by third parties.

Other Sources
We use some methods to make the content and advertising shown on devices that you might use or that may relate to the same household more relevant and useful. These methods may also provide insight reporting as part of their service. As part of this process these methods uses cookies and may receive information about the kind of device you use as well as your IP address, location data, device user agent string or information about websites where your device has previously displayed advertising. By using our sites, you acknowledge that we will process personal data about you for the above purpose and for the profiling of audiences bearing similarities to your data on the basis of our or their legitimate interests.

Our use of several database marketing companies: If you have a subscription to one of our titles, or use one of our products or services, we may check with them to see if they have any relevant lifestyle and demographic insight information about you. This helps us make sure that our marketing is more relevant to you. This is only where you have provided permission or there is a legitimate interest for them and us to do this.

We may also obtain online and offline information about you from other organisations, such as consumer insight providers that have your permission or where there is a legitimate interest in sharing your personal information with us or companies like us. We may combine this with information we collect in accordance with this Policy.

Other organisations that provide products and services to you may also share information with us. For example, they may notify us when you move home or when the payment card you used with us is renewed or replaced, so that we can keep your information accurate and up to date. This also helps ensure that you do not lose access to our products and services.

Our Legal Bases for Using Personal Information

Using Personal Information
In This Section
You can find out more about the legal reasons behind our use of your personal information and when they apply.
With your Consent
There may be some uses of your information where we need to ask for your consent. You will have the right to withdraw that consent at any time, however, if you withdraw consent, we may not be able to provide the product or service you have requested.

Fulfilling a Contract
We also process your personal information in order to fulfil a contract we have with you. For example, we would use your information to provide you with access to your digital subscription or other products you have signed up for or to provide a prize to which you are entitled.

For a Legitimate Interest
We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else.

We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between our legitimate interests and your privacy rights. Our legitimate interests in processing personal data include:

to support a free press, including journalistic activities of societal importance;
to support individual and societal rights to receive information;
to develop, deliver and maintain relevant and engaging products services and advertising;
understanding when our audiences engage with us or other organisations;
to build a clearer understanding of who our audiences are in order to better serve them;
to carry on the business of a commercial organisation; and
to demonstrate that we provide services and products to agreed industry standards.
To Comply with Legal Obligations
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This may include publishing information about prize winners, for example.

In the table below we have listed the main reasons we process your information and the legal bases that are available to us. The specific legal basis we use will depend on the activity the information is used for. Please keep in mind that while we will rely on one legal basis, if that is no longer available to us, we may be able to rely on another.

How We Use Personal Information
Using Personal Information image
In This Section
You can find out more about how we use your information.
To Provide Products and Services and Improve Your Experience
We will use your information to provide you with products and services you have asked for and to manage our relationship with you, including allowing you to interact, comment, and participate in online games, contests and reward programmes.

We may use your information to monitor, improve and protect our products, content, services and websites, both online and offline. We may also provide you with help and support where we believe it is required. For example, if you have provided your contact information, we may contact you when a checkout journey is not completed.

To Personalise Content and Offers
We sometimes make assumptions about your interests based on the way you interact with our products and services and the information we hold about you. For example:

For Rich World subscribers: If we notice that you regularly read the Business section of Rich World website first, then move on to Comments, we may promote articles in those sections or other related content so you get the most out of the product. We might also tailor your Best of Rich World and other communications.

For Rich World readers: If we notice that you have previously booked a Holiday for 10 USD, we may continue to promote holidays to you in the future based on this information.

For Rich World listeners: If we know you are interested in buying a car, we may insert a car advert into a commercial break on the online audio stream you are listening to.

Knowing these preferences also allows us to understand the products, content and services our customers like, letting us focus our efforts on developing those areas. We may also use this information to make decisions about what direct marketing to show you.

“Do Not Track” Browser Settings
If you choose to turn on the “Do Not Track” setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to request that they stop tracking your activity. Currently our websites and apps are not designed to respond to “Do Not Track” signals.

Posts, Comments and Interaction
If you correspond with any of our titles or radio stations, or interact with other customers or audience members or our staff, for example by using polls, comments, text messages, video, email, phone, radio or by post, we may display this content indefinitely in any relevant context, subject to our editorial judgement and your rights as set out in this Policy. This may be anonymised in the case of testimonials or customer service conversations.

If you take part in any reader or listener forums, send us letters for publication, or take part in any radio ‘phone-ins’, then you may be identifiable to others publicly and your comments attributed to you.

Public Information and Posts
Any information about yourself or others that you post on our social media pages, on platforms like Twitter, Facebook and other chat rooms, blogs and forums, will be viewed by others (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in such public areas, and you acknowledge that this may be collected and used by third parties.

Payment Processors
If you use third party payment providers, such as PayPal, to pay for or receive payment from us that site may pass information to us including your name, email address, billing or other address, phone number (if applicable), date of sign-up, the number of payments you have received from verified PayPal users, whether you have been verified to have control of a bank account and any other information you agree they can share.

Advert Delivery
When you visit one of our websites or use one of our apps, advertising networks and other intermediaries select and then display adverts on your device. In the case of some of our radio stations, when listening online, partners insert a relevant audio advert for you to listen to.

How We Share Your Information
In This Section

Sharing with Commercial Partners
We may disclose your personal information to third parties, such as competition partners, for their direct marketing purposes where we have told you about this and you have given permission or there is a legitimate interest to do so.

We may share your personal information with our partners who operate products and services using our brands where you use these services. We will only share your information where we have an appropriate agreement in place with the partner. The information we share will be used in accordance with our partner’s privacy policy, which you should read when you sign up with the partner.

These partners will also pass us the information they collect about you, including your usage and interaction with those products and services, which we will use in accordance with this Policy.

Disclosure to our Processors
We may pass your information to our processors – companies that we use to provide services on our behalf, for example for home delivery services, prize fulfilment agencies, market research or other purposes mentioned in this Policy. These processors can only use your information in accordance with our instructions and for no other purpose.

Data Transfers
When you complete our registration forms or use our services, we may transfer your information to our group companies and processors outside the EEA to countries that may not have data protection rules that provide the same level of protection. However, we only transfer your information where there are appropriate measures and controls in place.

Sale of our business
If we sell part or all of our business, customer information may be one of the transferred business assets. If this happens, your information may be disclosed to any successors of our business for them to use for the purpose set out in this Policy.

Cookies & Similar Technologies
Cookies and Similar Technologies
In This Section
You can find out more about the cookies we use and why. You can also find out more about how to control them.
What are Cookies
Cookies and other online tracking technologies are small bits of data or code that are used to identify your devices when you use and interact with our websites and other services. They are often used for remembering your preferences, to identify popular news stories, to remember you’re logged in and allowing you to comment on stories.

Our legal bases for cookies and similar technologies Placing cookies: in order to place cookies, tags and other technologies on your browser or device, we need to have your permission. We do this by providing a clear notice in the form of a cookie banner that tells you what cookies are used for, as well as providing you with useful information about the technologies we use and a link to this Policy. You’ll need to indicate your acceptance of our use of cookies. On a mobile device this might be by swiping a banner, pressing a button, or using facial recognition.

You are able to opt-out of the use of cookies. For more information, see the section on Managing Cookies.

Using information collected from cookies: where we want to use the information that cookies and similar technologies collect, we either need your consent or a legitimate interest.

What Cookies Do We Use and Why?
Essential Cookies and Similar Technologies
These are vital for the running of our services on our websites and apps. Without the use of these cookies, parts of our websites would not function. For example, Rich World uses cookies to help us identify which of our readers have a subscription in order to access content they are entitled to on the website. We use these cookies to tell if you’re logged in to your account, which allows extra functionality, such as commenting on stories.

Analytics Cookies and Similar Technologies
These collect information about your use of our websites and apps, and enable us to improve the way they work. For example, analytics cookies show us which are the most frequently visited pages on The Sun or The Times websites allowing us to provide the most popular news articles further up the page. They help us record how you interact with our websites, such as how you navigate around pages and from page to page, identifying improvements we can make to the customer journey. They also help identify any difficulties you have accessing our services, so we can fix any problems. Additionally, these cookies allow us to see overall patterns of usage at an aggregated level.

Functional/Preference Cookies and Similar Technologies
These cookies collect information about your choices and preferences, and allow us to remember things like language, your username (so you can log in faster), text size, and location, so we can show you relevant content to where you are. They allow us to customise the services you have accessed. We also use these cookies to provide you with services such as video clips.

Tracking, Advertising Cookies and Similar Technologies
We use these types of technologies to provide advertisements that we think may be more relevant to your interests. This can be done by delivering online adverts based on your previous web browsing activity, known as “online behavioural advertising” (OBA). Cookies are placed on your browser which will remember the websites you have visited. Adverts based on what you have been looking at are then displayed to you when you visit websites which use the same advertising networks.

For example, you may be doing online research to buy a bicycle, and read several articles about bikes on various websites. As you browse those sites a cookie from an advertising network would be placed in your browser. It would remember that you had visited several websites related to cycling. Then, when you visited another website in the same advertising network, the website could show you an advert related to cycling.

We may also use cookies and similar technologies to provide you with adverts based on your location, offers you click on, and other similar interactions with our websites and apps.

To help us deliver relevant advertising using cookies, we use Google products including Google Marketing Platform.

How We Use Cookies and Similar Technologies
Protect our Networks
Cookies and similar technologies help us identify and prevent threats to our sites. They are necessary to protect your information and our business from outside threats.

Allow you to Access our Services
Cookies and similar technologies permit your connection to our websites: our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, other software or hardware information, and your geographic location.

Access Usage of Services
We use information about your usage of our services, websites and apps, such as pages you have visited, content you have viewed, search queries you have run, and advertisements you have seen or interacted with to assess how our services are used.

Provide eCommerce Functionality
Cookies and similar technologies help us provide functionality that you need to navigate our sites, select products and services and purchase them.

Provide Relevant Content
The content on our websites and in our communications with you may be adjusted depending on what we know about the content, products and services that you like. This means we can highlight content and articles that we believe will be of interest to you. We provide personalisation by using cookies, IP addresses, web beacons, URL tracking and mobile app settings.

Selling Third Party Advertising
We sell space on our websites and apps to advertisers. The adverts they display on our websites will often contain cookies. Our advertisers may use cookies or similar technologies to provide you with advertisements that they believe are relevant. They may use browsing data obtained to restrict the number of times you see particular adverts (frequency capping). You may also see adverts from these advertisers on other websites you visit.

Third parties that support our services by serving advertisements or providing other services, such as allowing you to share content or tracking aggregate service usage, may also use cookies and other technologies to collect information relevant to the provision of those services.

We do not control third party cookies or other technologies. Their use is governed by the privacy policies of third parties using such technologies. You should make sure you are aware of how third parties will use cookies by checking the third party’s cookie policy.

Mobile Apps
By downloading our apps, we will require access to the following services on your device: unique identifier (UDID), MAC address or other applicable device identifier and location. Other services may also be required in order for the apps to function. We may use this information to validate free trials. Our apps may also provide push notifications to your device. You may control these through using the tools on your device, such as turning off push notification and location services.

Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalisation available on our websites or apps.

Changes to this Policy
From time to time we make changes to this Policy. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal information. Where necessary, we will notify you of these changes. We will always display clearly when the privacy policy was last amended on the website.

Contact Us
In addition to any general data protection enquiries you may have, you can contact our Data Protection Officer. Please click here.