Privacy Policy May 2018

This is the privacy policy of Nantwich News.
In this document, “we”, “our” or “us” refers to Nantwich News.
www.thenantwichnews.co.uk (“We”) are committed to protecting and respecting your privacy.

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR) which comes into force in the UK on May 25, 2018.

For the purpose of the 2018 GDPR Act, the data controller is Nantwich News of Hallams Drive, Nantwich, CW57RN.
Our nominated representative for the purpose of the Act is Pete Leydon.
The data processor is Coderra Ltd, web-hosting and design service, of Nantwich.

Introduction
1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process because we have a contractual obligation with you
When you register with us on our website (eg. to subscribe to emails, add a listing, add a directory listing, or add a comment), or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. provide you with our services
1.3. provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our Analytics performance. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us, [email protected]. However, if you do so, you may not be able to use our website or our services further.

3. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our business
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage  business risk
• protecting your interests where we believe we have a duty to do so

4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us

5. Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
Examples include:
5.1. posting a comment on stories
5.2. posting an event listing
5.3. adding a business directory listing
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at [email protected]

6. Complaints regarding content on our website
Our website is a publishing medium. Anyone may register and then publish information about himself, herself or some other person.
We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

7. Sending a message to our support team
When you contact us, whether by telephone, through our website, social media or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address, so as to be able to track our communications with you to provide a high quality service.

Use of information we collect through automated systems when you visit our website

8. Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
8.1. to track how you use our website
8.2. to record whether you have seen specific messages we display on our website
8.3. to keep you signed in our site
8.4. to record your answers to surveys and questionnaires on our site while you complete them
8.5. to record the conversation thread during a live chat with our support team
8.6. to allow Google Adsense non-personalized adverts to track frequency capping, aggregated ad reporting, and to combat fraud and abuse

[We provide more information about the cookies we use in our cookie policy].

9. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
However, in our Google Analytics reports, we have ‘masked’ all visitor IP addresses so individual users will not be identified.

Non-personalized ads
We use Google Adsense service to display to all users in the EEA only non-personalized ads.
These non-personalized ads are targeted using contextual information rather than the past behaviour of a user.
Although these ads don’t use cookies for ads personalization, they do use cookies to allow for frequency capping, aggregated ad reporting, and to combat fraud and abuse.
Therefore, when you first visit our site and adhere to the consent policy displayed, you are doing so to ensure we meet the new EU ePrivacy Directive.

Disclosure and sharing of your information
10. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.

11. Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties obtain.
Accordingly, this privacy notice does not cover the information practices of these third parties.

12. Data may be processed outside the European Union
Our websites are hosted in the UK.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union:
13.1. the data processor abides by the same binding rules regarding data processing.
13.2. the data protection clauses in our contracts with data processors include approved transfer clause
13.3. we comply with a code of conduct approved by a supervisory authority in the European Union, specifically the United Kingdom
13.4. we are certified under an approved certification mechanism as provided for in the GDPR

Access to your own information

13. Access to your personal information
13.1. At any time you may review or update personally identifiable information published on our website or otherwise that we hold about you
13.2. To obtain a copy of any information that is not provided on our website you may send us a request at [email protected]
13.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

14. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at [email protected]
This may limit the service we can provide to you.

15. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters
16. Use of site by children
16.1. We do not sell products or provide services for purchase by children, nor do we market to children
16.2. We collect data about all users of and visitors to the website regardless of age, and we anticipate that some of those users and visitors will be children.
16.3. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site advertising they find, wherever they visit.

17. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

18. How you can complain
18.1. If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is [email protected]
18.2. You can find further information about our complaint handling procedure by visiting the Contact Us page.
18.3. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
18.4. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

19. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
19.1. to provide you with the services you have requested
19.2. to comply with other law, including for the period demanded by our tax authorities
19.3. to support a claim or defence in court.

20. Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.

21. Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.