Privacy Policy

• 1. Introduction

  Positive News is the trading name for Positive News Publishing Ltd. This Privacy Notice is to let you know how we handle your personal data. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This Privacy Notice explains how we do this and tells you about your privacy rights and how the law protects you.

  Your personal data is any information relating to you from which you can be identified.

  This notice sets out:

  • how we will process any personal data that we collect from you and what it will be used for,
  • the information that you are entitled to receive from us when we collect your personal data and
  • your rights under the General Data Protection Regulation (GDPR) in connection with the way we handle your personal data.

  This Privacy Notice applies to any personal data which you may provide to us in person, over the telephone, by e-mail, on our website and/or by post.

  This Privacy Notice also applies to any personal data which we may collect from third parties about you and/or which we may collect when you access our website and/or in the course of our relationship.

  You can choose not to give personal data. We may need to collect personal data by law, or under the terms of a contract and/or relationship that we have with you. If you choose not to give us this personal data, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services so we cancel a product or service you have with us.

  Wherever we refer to “processing” of personal data in this Privacy Notice this includes any combination of the following activities: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  This Privacy Notice only applies to personal data collected by or on behalf of Positive News via the company’s website or by any other means. The company’s website may from time to time contain links to and from other websites (partner networks, advertisers and affiliates). If you follow a link to any external website or alternatively reach our website from a third party website, please be aware that these websites will have their own privacy policies, separate from ours, and we therefore do not accept any responsibility or liability for these policies. Please check their policies before you submit any personal data to these websites.

  
  1.1 Data Controller

  For the purposes of the Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679) (together, the data protection legislation), Positive News is the data controller of your personal data.

  
  1.2 Our Promise to You

  We promise:

  • To keep your personal data safe and only process it on valid legal basis
  • To keep our records up to date and delete or correct inaccurate personal data
  • Not to keep your personal data after the purpose has ended
  • Not to sell your personal data
  • To give you ways to manage and review your marketing choices at any time

• 2. Who we are

  Positive News is the inspiring current affairs magazine. Online and in print, we publish quality, independent journalism about progress and possibility.

• 3. Information we collect and how we collect it

  The type of information we may ask you to provide about yourself and therefore collect includes, but is not limited to:

  • Contact Details: Name, address, contact telephone number (mobile and landline), e-mail address
  • Socio-Demographic Details: This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.
  • Contractual Details about the products or services we provide to you.
  • Locational Data we get about where you are, such as may come from your mobile phone or the address where you connect a computer to the internet.
  • Behavioural Details about how you use our products and services.
  • Technical Details on the devices and technology you use.
  • Communications: What we learn about you from letters, emails and conversations between us.
  • Usage Data: Other data about how you use our products and services.

  We may collect personal data from you in the following ways:

  • When you make an enquiry, register your interest or create an account on our website.
  • When you contact us in person, over the telephone, by email or by post
  • At the point of purchasing from us
  • When you become a supporter or co-owner
  • In customer surveys
  • If you take part in our competitions or promotions
  • When you use our website
  • Payment and transaction data

  We may collect your personal data from third parties we work with including:

  • Companies that introduce you to us
  • Social networks
  • Analytics providers

• 4. How we use your Personal Data

  We may use the information you share with us and the information we collect through your use of our sites in the ways described below and as described at the time of capture.

  
  Competitions & Prize Draws

  We will use the details you have shared to manage your entry to any competition or prize draw. This may include your name, e-mail address and telephone number. We shall use such information to notify you if you are the winner. Your data will be retained for the period of the competition only and will not be added to any marketing lists unless you have consented to this. Your data will be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of your prize.

  Newsletters

  We will use the details you have shared to send you the newsletter to which you have subscribed. We will not add your details to any marketing lists, unless you have consented to this. We will provide a way for you to unsubscribe on every newsletter we send to you. Details you share with us for the purpose of newsletter subscription will never be shared with a third party.

  Events

  We will use the details you have shared to manage your registration and entry into our event. This may include contact via telephone, email, SMS and post with information relating to the event you have registered to attend. Your data will not be added to any marketing lists unless you have consented to this. Your data will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of the event.

  Magazine Subscription

  We will use the details you have shared to manage your subscription to Positive News magazine, which includes sending the magazine, managing access to any digital version, taking secure payments, to fulfil any gift that was offered at the time of purchase, to handle any customer query you may have and to contact you via telephone, email, SMS and post with information relating to your magazine subscription. E.g. to notify you of the expiry date of your subscription, that a delivery to you may be delayed or to remind you of a password or to notify you of updates to our Privacy Policy, Cookie Policy or Terms of Use. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with third parties where we have appointed them to manage specific aspects of your magazine subscription.

  Supporters

  We will use the details you have shared to manage your support for Positive News, which includes taking secure payments, to handle any queries you may have, to contact you via telephone, email, SMS and post with information relating to Positive News and to invite you to attend events such as the Annual Inspiration Meeting (AIM). We will not add your details to any marketing lists, unless you have consented to this. We will provide a way for you to opt-out on every communication we send to you. Details you share with us for the purpose of supporting the magazine will never be shared with a third party.

  Co-owners

  We will use the details you have shared to manage your community shares in Positive News Limited (of which we, Positive News Publishing Ltd, are a wholly-owned subsidiary), which includes taking secure payments, to handle any queries you may have, to contact you via telephone, email, SMS and post with information relating to Positive News and to invite you to attend events such as the AIM. We will not add your details to any marketing lists, unless you have consented to this. We will provide a way for you to opt-out on every communication we send to you. Details you share with us for the purpose of supporting the magazine will never be shared with a third party.

  Customer Services

  We will use the information you provide to deliver customer services related to your purchase and to respond to inquiries or requests that you direct to us. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with third parties where we have appointed them to manage specific aspects of your customer care.

  Research

  We may use the information you provide to invite you to participate in surveys and focus groups about our products, advertisers and services. Participation is always voluntary and the answers you provide are anonymous unless explicitly stated otherwise, and aggregated to support our learnings and inform changes we can make to improve our products and services. Your data will not be added to any marketing lists unless you have consented to this and were informed at the point of capture and will only be shared with third parties where we have appointed them to manage research activity on our behalf.

  Occasionally we get paid by commercial partners to carry out research on their behalf. In this situation, the data we share with them will be anonymous, however, we may share your personal data with specific commercial partners where they were named at point of capture and where you agreed to the sharing of your personal data with them.

  Direct Marketing

  We may use the details you share with us to send you offers and promotions by email, post, telephone or SMS wherever we have legitimate interest grounds to do so and where you have not objected. We will provide a way for you to opt-out of receiving marketing promotions both at the time of data capture and every time we contact you thereafter. You can also amend your contact preferences in your online account if you have one set up, or email [email protected] to request your details are suppressed from all promotional campaigns. We won’t use your personal data for marketing purposes at all if you’ve told us not to.

  Legitimate Interest

  We may process your personal data on the basis of a legitimate interest which may include promoting similar products or services via direct marketing activity, to manage suppression and unsubscribe requests received from you, to identify and prevent fraudulent behaviour, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns.

  Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights. Find out more about your rights and how to exercise in paragraph 8 below.

  Cookies and how we use them

  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We use cookies for a number of reasons:

  Strictly Necessary Cookies – These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

  Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

  Functional Cookies – These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

  Targeting Cookies – These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

  Social Media Cookies – These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

  For more information on how we use cookies please read our Cookie Policy.

  Analytics

  The Positive News website uses Google Analytics as its primary solution for tracking website visits, interactions and events. Positive News uses website analytics data to help improve the way we deliver content and online experiences to visitors.

  For full details on how Google processes your data please click here.

  Online Advertising

  Positive News does not currently show advertising to users on its website but reserves the right to do so. Our websites may show advertising to users. A proportion of this advertising may be tailored to the individual user, a practice known as “Online Behavioural Advertising” which uses cookies to discover general information about the pages you visit. Our advertising delivery systems and partners uses the limited information available to it to serve adverts to you, which it believes are relevant. It does not collect personal information such as your name, email address postal address or telephone number.

  From time to time, Positive News may share this aggregated data with its advertising partners. This could mean that when you are on other websites you are served advertising based on your behaviour across our or other sites.

  Behavioural retargeting is another form of Online Behavioural Advertising that enables us and some of our advertising partners to show you adverts based on browsing patterns and interactions with the site away from our sites. This allows companies to advertise to website visitors who leave their website without making a purchase.

  If you want to opt out of receiving Online Behavioural Advertising this does not mean that you will no longer receive advertising when you are using our sites. It just means that the advertising you see will not be customised for you. If you would like more information about online behavioural targeting and how to opt out of it, please visit www.youronlinechoices.com or you can also visit www.networkadvertising.org.

  Links to third party websites

  When you click on links or advertisements on any of our sites, you will leave that site and go to a third-party site, which is outside of our control. When we place an advertisement on one of our sites, it does not signify that we are endorsing that advertiser’s product or service. We do not accept responsibility for content we have no control over and our Privacy Policy does not apply to these companies, sites or content and if such third-party sites collect personal data, we cannot control how this data is processed, stored or used. We advise that you read their data collection statements, which accompany any registration and their Privacy Policies before you submit your personal information.

  Using our websites from outside the UK

  We use servers located in the EEA to store data. When you submit your details and in whichever country you are situated you agree to the data being transferred to the EEA and processed under the terms of Regulation (EU) 2016/679 (GDPR) including any implementing data protection legislation in the UK. If you are not in agreement please do not add your personal details on the website. Positive News makes no representation or warranty that the content and materials on the Website are appropriate or available for use in locations outside of the United Kingdom. Those who choose to access the Website or use the services from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent applicable.

  Change of purpose

  We will ask for your consent before using personal data for a purpose other than those set out in this privacy policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like further information on purpose compatibility, please contact us.

• 5. Sharing your Personal Data

  Positive News has formed partnerships with carefully selected companies that we share data with in order to carry out the activities described in the section ‘How we use your Personal Data’. When we share data with third parties we will ask them to confirm that their security measures are adequate to protect your personal data.

  Your personal data may be transferred outside the UK and the European Economic Area. Some countries have adequate protection of personal data under their laws but where this is not the case we will be responsible for ensuring that appropriate security and privacy safeguards are in place, either by requiring the recipient to have signed up to a recognised international framework of data protection or by contractual obligations.

• 6. Protecting your information

  We will seek to keep your personal data secure by taking appropriate technical and organisational measures against unauthorised or unlawful processing and against accidental loss, destruction or damage.

  Only authorised personnel and third parties will have access to your personal data.

  If logging on to our website it is your responsibility to protect log in details. You must treat these as confidential and must not share or disclose your log in details to any other party.

• 7. Personal data retention

  We may retain information about you, including personal data, for the period necessary to fulfil the purposes for which it was first collected unless a longer retention period is required or permitted by law. In determining data retention periods, we take into considerations contractual obligations, legal obligations and the expectation and requirements of our customers. When personal data is no longer needed, we will securely delete or destroy it.

• 8. Your Rights

  Under the GDPR and current UK data protection you have the rights shown below:

  8.1 Right of Access

  You have the right to access your personal data, including us providing to you without charge, a copy (which may be in electronic form) of any of your personal data that we are holding or using (referred to as “processing”) or that third parties are processing on our behalf.

  We will also provide to you, if you request it, the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed, including recipients in countries outside the UK or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • if the personal data was not collected from you, any information available to us as to the source of it;

  8.2 Right to Removal or Correction of Personal Data and to Restrict Processing

  You have the following rights under GDPR:

  • a right to request us to correct inaccurate or incomplete data (“Right to rectification”).
  • a right to request us to delete any of your personal data. In certain we may wish to retain data and if GDPR allows us to do so we will inform you of our grounds. (“Right to erasure” or “Right to be forgotten”).
  • a right to request us to stop or to restrict any aspect of the processing of your personal data. In certain circumstances we may wish to continue and if GDPR allows us to do so we will inform you of our grounds (“Right to restriction of processing”).
  • In each case we will tell you what action we are taking and we will also notify any third party to whom the data has been disclosed.

  
  8.3 Rights Concerning Automated Processing and Profiling

  You have the following rights under GDPR over automated decisions and profiling.

  • You can object to an automated decision, and ask that a person reviews it.
  • You can object to the use of your personal data in profiling or direct marketing.

  
  8.4 Right to Data Portability

  You have the right to receive from us the personal data that you have given us in a structured, commonly used and machine-readable format (“Right to data portability”) and/or to have the data sent by us directly to another party. Please note that this right only applies in certain circumstances, which is when we held the data on grounds of your consent or to perform a contract with you or for steps preparatory to such a contract and we were processing that data by automated means.

  8.5 Exercising your rights

  If you wish to exercise any of these rights or simply wish to find out what information, if any, we hold that relates to you, you must make your request in writing by sending an email to [email protected] or a letter to The Privacy Team, Positive News, 24 Greencoat Place, London, SW1P 1RD.

  You can help us to process your request quickly by providing us with information that will help us identify records we hold that relate to you. For example, your name, address, email address, telephone number, or in the case of information captured via cookies, the IP address of the device you have used.

• 9. Changes to this Privacy Notice

  Any changes we may make to this Privacy Notice in the future will be posted on this website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Privacy Notice.

• 10. Complaints

  Please let us know if you are unhappy with how we have processed your personal data. You can contact us on the contact details at the “Contact Us” link on our website or by writing to the Data Protection Lead at the address given below.

  You have the right to lodge a complaint with the Information Commissioners Office (ICO) which is the UK supervisory authority for the processing of personal data. Further details are available on the ICO’s website.

• 11. Contacting us

  If you have any questions, or want more details about how we process your personal data, or if you wish to exercise any of your rights you can contact us on the contact details at the “Contact Us” link on our website or by writing to the Data Protection Lead at the address given below.

  You can contact our Data Protection Lead at:

  POSITIVE NEWS
  24 Greencoat Place
  London
  SW1P 1RD
  United Kingdom

  or by email to [email protected]