Last Updated October 2020

Introduction 

This privacy notice is for visitors to our websites, apps, social media and all other digital platforms (Ad Sales Limited). It sets out how we, Ad Sales Limited (Registered Company number 03604596) use the personal data that we hold about you and sets out information on how to exercise your legal rights with regards to this data. In this notice ‘we’ and ‘our’ means Ad Sales Limited and its associated publications which operates this platform.  

Personal data can include: 

• Your name, address, year of birth or title 

• Debit or credit card details 

• Information about your devices, such as IP address 

• How you browse our websites 

• Details of products or services you have shown interest in. 

What data do we process about our visitors? 

If you register for an account on our website in order to comment on an article or advertise a classified listing, you will be agreeing to the use and secure storage of your full name and email address. 

If you contact our Editorial or Sales team, we will need your name and contact information as well as full details of your query.  

We collect data about our website’s visitors using technology such as cookies, device IDs, IP addresses and location data. This can include information about your location, the type of device you are using and your online browsing history.  This cookie notice is for visitors to our websites, apps and other digital platforms. It sets out how we use cookies. 

What are cookies? 

For almost any modern website to work properly, it needs to collect certain basic information on its users. To do this, a site will create files known as cookies – which are small text files – on its users’ computers, tablets or mobile devices. These cookies are designed to allow the website to recognise its users on subsequent visits, or to authorise other designated websites to recognise these users for a particular purpose. 

We can also access information from social media activity such as when you ‘like’ the website, share content or follow us on Twitter.  When you sign-in to the website using social media you grant permission to the social network to share some of your details with us. Depending on the network this will include basic account information such as name, email address, date of birth and any other details you choose to share according to your particular social media account settings. 

We may also collect information about third party products and services which you purchase after visiting the Website. For example, when you use a voucher code or click on a link to an advertiser’s site. 

What do we use this data for? 

  • Verifying your identity (for example when you return to the website and have already logged in). 
  • Personalising the advertising you see on the website so that it is more relevant to you.   For more information on how we use your cookie data please see our Cookie Notice. 
  • Improving the design and style of the website. 
  •  Sending you service messages about your subscription or account registration, for example if you have clicked a password reset link.  This could be by email, overlay on the website or push notification. 
  • Dealing with, and responding to you about, a comment you have submitted for or on our message boards, blogs and other such user generated content facilities. 
  • Enabling you to share our content with others using social media or email. 
  • Communicating (and personalising such communication) with you through our scheduled newsletters, but only those you have consented to receive. 
  •  Conducting market research. 
  • Granting you access to a subscription. 
  • Dealing with any query or complaint you submit to our customer services team.  

How we may contact you 

From time to time we may contact you by email to give you service information.  For example if your subscription is coming to an end, or your payment method has expired. 

If we have your permission we may also send you newsletters or emails about our events, subscription benefits or offers. 

Occasionally we may ask you if you would like to participate in market research, or respond to you if you have made a complaint or have logged a query. 

What is our legal basis for processing personal data? 

Consent. 

We will only use your personal data for advertising and marketing, personalisation of content and services, analytical purposes (such as, understanding who our readers are and how they browse our websites) and to track eCommerce purchases if we have your specific consent to do so.  This includes the use of data provided by you for profiling purposes so we can improve our products and services. 

If you have given us consent to send you specific newsletters, you can unsubscribe from these at any time by clicking unsubscribe at the bottom of each email, or by logging into your account and managing your email preferences. 

Legitimate interests. 

The legitimate interest pursued by us to analyse our website traffic in order to maintain the service, for example monitoring successful page loads or error messages. 

Performance of a contract 

When you purchase a subscription or buy another product from us, we will need to process your details in order to supply the item to you, this will typically be a name and email address but may include other information required in the processing of your purchase. 

How can you access and update your personal information? 

If you are a registered user or subscriber, you can update your personal information by signing in to your account page or through your social network provider. In all other cases, please contact customer services. 

You can ask for a copy of the personal information we may hold about you, or for your data to be deleted via customer services. 

If you wish to contact us by email our email is webdev@indyonline.co.uk 

How long do we keep your personal information for? 

We will keep your information only for as long as it is relevant and useful only for the purpose for which it was originally collected. 

Please note that if your account appears to have not been used for 12 months, we will try and contact you to check whether it is still in use and/or we will delete it.  Please note that any comments associated with your account will also be deleted. 

If you purchased a subscription, we will retain your data for at least 12 months after your subscription ends in case there are any outstanding billing or other customer service issues.  

A record of a customer service query is retained for at least three years from the date it was submitted to us. 

We retain cookie data and corresponding third party data for 13 months from when it was collected from your device. 

We may need to retain your data for a longer period if there is a legal claim or if we are required to so by any regulation. 

Who will we share your personal information with? 

We may disclose your personal information to our sister companies: Sunday Independent, Cornwall Today, Truro Voice, St Austell Voice, Newquay Voice, Bodmin Voice as we operate a single group known as Independent Media Limited. 

Advertisers and advertising networks sometimes require data to select and serve relevant advertisements to you and others. We may provide them with aggregate cookie information about our users with certain attributes (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in the UK who are interested in travel). 

We reserve the right to disclose your personal information to comply with applicable laws and government or regulatory bodies’ lawful requests for information. 

Your personal details may be shared with third party organisations we have contracted to provide services to us which include processing data.  For example, to send you the emails you have signed up for. Only companies who can provide adequate safeguards will be used to ensure your data is stored and handled securely.  

We may also have to release information because of a legal requirement on us or pursuant to a court order. 

We may transfer, sell or assign any of the information described in this Privacy Notice to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business. 

Using children’s personal data 

We do not aim our services to children. 

Will your data be sent overseas? 

As you will know, the internet does not recognise national boundaries. Services on the web are accessible globally so collection and transmission of personal data is not always confined to one country. 

You should be aware that by using the website and those of our partners or any website we link through to, your personal data may be processed in or transferred to other countries, and you agree to your personal data being transferred or processed in this way. 

Your personal data will only be stored or transferred within the UK, EU or US under the EU-US Privacy Shield, or using other safeguards that have been approved by the relevant regulatory body. 

Your rights: 

Right of access – you have the right to request a copy of the data that we hold about you. 

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete. 

Right to be forgotten – you can ask for the data we hold about you to be erased from our records. 

Right to restriction of processing – you can ask for us to restrict the way we process your data. 

Right of portability – you have the right to have the data we hold about you transferred to another organisation.  

Right to object – you have the right to object to our processing your data where we are relying on a legitimate interest in order to process it. 

Right to withdraw your consent – you have the right to withdraw your consent at any time. 

Please note that these rights are not absolute and certain exemptions apply.  

Exercising your rights, asking questions and raising concerns: 

In the first instance, please submit your request using webdev@indyonline.co.uk 

You may also lodge a complaint directly with the supervisory authority or our Data Protection Officer using the contact information in the table below. 

  Supervisory authority contact details 
Contact Name: Information Commissioner’s Office 
Address Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF United Kingdom 
Contact info: 0303 123 1113 https://ico.org.uk/make-a-complaint/