We process your personal information when you have an active newspaper, magazine, digital product or app subscription with us, as well as afterwards. This includes collecting your personal information, recording it, storing it, using it, amending it, deleting it and in some circumstances sharing it.
The personal information we process about you and the purposes for which we use it are set out in the table below. We can only use your personal information when we have a good, lawful reason for doing so – our reasons are typically that:
- we need to use your personal information so we can provide you with the newspaper, magazine, digital product or app subscription;
- we have a good business justification to use your personal information, which we think is reasonable and treats you fairly (for example, we might record your calls to us for training and quality purposes). Under data protection law, this is referred to as a ‘legitimate interest’; or
- we need to use your personal information so we can comply with a legal obligation (for example, an obligation to notify you of a product recall)
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Reason for processing your personal information
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Your personal information
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Legal ground(s) for processing
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Our legitimate interest (where applicable)
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To process your order including sending you (or the nominated recipient) your physical purchase
To make your subscription available online or via an app if it is digital-based or includes a digital component
To register and operate your online account
To contact you with information and updates regarding your subscription, including renewal notifications
To notify you of subscriber-related content and events and provide you with access to them
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Name
Email address
Home address
Delivery address (if different)
Phone number(s)
Title
Company/ organisation name
Job title
Purchase details and order history
Login details for your online account or app
If you register using Facebook, Google or Apple we will collect the information you’ve allowed them to share with us
If you connect with our app using your social account and select to allow us to access your basic profile information etc we may access your basic public profile and friend list, including username, email (encrypted) and avatar.
Marketing preferences you’ve indicated to us
Nominated recipient details
Gift message for nominated recipient
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Necessary to perform the contract between us
Necessary for our legitimate interests
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To maintain our subscriber numbers so we can continue to provide you with our products
To remain engaged with you and to bring you additional benefits where possible
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To process your payments (including recurring payments) and collect and recover money owed to us
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Name
Email address
Billing address
Phone number(s)
Bank account or payment card details
If you use a payment service (for example PayPal) we collect the limited information they share relevant to the transaction
Purchase details and order history
Company/ organisation name
Job title
VAT number
If your subscription is purchased via an app store, the app store holds your purchase information not us.
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Necessary to perform the contract between us
Necessary for our legitimate interests
Legal obligation (for example provision of an invoice for VAT registered businesses, or to provide confirmation/receipt of payment/Direct Debit set up)
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To recover debts owed to us
To provide you with order documentation such as order confirmation
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Manage in-App game/puzzle play and provide the functions and features you have registered for including:
game status and rewards
saving your state of play and customise some elements
Access the app across multiple devices
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Email address
In-app username
Game/Puzzle Status
Purchase history
In-app progress, including time, streaks, game play history, rewards, completion rates, hints and puzzle token usage, spend, state of play etc.
Language setting
If you connect with our app using your social account and select to allow us to access your basic profile information etc we may access your basic public profile and friend list, including username, email (encrypted) and avatar
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To send you marketing communications with our suggestions and recommendations about goods and services that may be of interest to you
This includes:
when we provide you with personalised content and/or display tailored messaging to you when you visit our websites or Apps; and
when we may show you our marketing (for example adverts) on other platforms such as Facebook
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Name
Email address
Home address
Delivery address (if different)
Phone number(s)
Purchase details and order history
Marketing preferences you’ve indicated to us
I.P. address and other device identifiers
Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)
Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information
Game/Puzzle Status
In-app progress, including time, streaks, game play history, rewards, completion rates, hints and puzzle token usage, spend, state of play etc.
Language setting
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Necessary for our legitimate interests
Consent
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To promote our products and services
To send direct marketing communications, to make these more relevant to you where possible, and analyse the effectiveness of our campaigns
To remain engaged with you and to bring you additional benefits where possible
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To manage our relationship with you including:
notifying you about changes to our terms or privacy policy;
asking you to leave a review, complete a survey or take part in research;
dealing with any queries, requests or issues you have including those sent from within app; and
confirming when you have completed a particular activity (for example when you have changed personal details associated with your subscription)
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Name
Email address
Home address
Phone number(s)
Login details for your online account or app
Marketing preferences you’ve indicated to us
Purchase details and order history
Payment information
Nominated recipient details
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Necessary to perform the contract between us
To comply with a legal obligation (for example to tell you about a change to our terms that may significantly affect you)
Necessary for our legitimate interests
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To keep our records updated and to learn how our customers use our services
To provide a good level of customer service and deal promptly with your questions, comments or suggestions
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To help us analyse and improve the technical functionality, security and performance of our websites and Apps
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I.P. address and other device identifiers
Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)
Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information
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Necessary for our legitimate interests
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To ensure our websites and apps operate to the high standards you expect
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To help us improve the quality and variety of the content and features we provide in our newspapers, magazines, digital products and apps
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I.P. address and other device identifiers
Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)
Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information
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Necessary for our legitimate interests
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To continuously improve our content and features, as well as develop new ideas that we think our customers will like
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To help us build an understanding of our customers, whether as individuals or as larger groups, so we can identify customers who may have similar interests, preferences and characteristics
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Name
Email address
Home address
Delivery address (if different)
Phone number(s)
Title
Company/ organisation name
Job title
Marketing preferences you’ve indicated to us
I.P. address and other device identifiers may include operating system and device type
Information you provide when you visit our websites or apps (e.g. a record of the pages you visit) and other services you may use to access our websites and apps (e.g. Facebook)
Details of your visit to our Apps such as how you navigate and use our content, and what links or promotional content you click on and other statistical information
Purchase details and order history
Nominated recipient details
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Necessary for our legitimate interests
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To understand the differing needs of different groups of customers, so we can tailor our products and services accordingly. For example, we would like to offer you content based on what we think similar customers are interested in.
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How we obtain your personal information
We collect your personal information directly from you when you take out a newspaper, magazine, digital or app subscription. Sometimes we get your details from a friend, relative or your employer if your subscription has been purchased as a gift or on your behalf. We also analyse how you interact with us, for example when you visit one of our websites or get in touch with a query.
We may obtain your personal information from third parties who process subscription offers, such as isubscribe or magazine.co.uk.
We also obtain some limited information from the app stores you have downloaded our app from. For example, order/purchase history including in app purchase details. We do not receive any payment card details; this is wholly held by the app stores.
Where we need your personal information to enter into or perform a contract with you then if you don’t provide it, we may not be able to process your subscription. For example, if you have requested a printed subscription but you don’t give us the delivery address, we won’t be able to send the newspaper or magazine.
Sharing your personal information with other organisations
As well as using your personal information across DC Thomson, we also share your personal information with other organisations:
- Service providers: We may share your personal information with third-party service providers who perform services on our behalf or for your benefit, such as payment processors, credit referencing providers, providers who process our orders and/or deliver physical products, providers that host our technical infrastructure and those who assist us with hosting and/or delivering our marketing campaigns.
- Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers.
- Business transfers: Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed to an administrator or liquidator or other insolvency professional if we enter financial difficulties so that they can continue to run the business, transfer it to another organisation or wind it up.
- HM Revenue and Customs, regulators and other authorities: We may share your personal information with HMRC and other regulators or authorities in the UK where required to do so by law.
- ABC audit of circulation figures: We may share your personal data with a third-party auditing organisation (ABC) so they can verify aggregated statistics about circulation and usage of our products or review our policies, processes and procedures for compliance with relevant standards. You can view their privacy policy by following this link.
Where we pass your personal information to a third-party service provider, that service provider will usually be a processor, processing your personal information on our instructions. This privacy policy will continue to apply, because we will remain in control of your personal information and be responsible for looking after it.
In some cases, a service provider will be a data controller in their own right with their own privacy policy, which they will make available to you in accordance with their obligations under data protection law.
