Privacy

Our privacy policy.

Information Gathering 

We are Sports Publications Ltd a company incorporated in England and Wales. Our company number is 03841670 and our registered office is at Unit 2 Arena Park, Tarn Lane, Scarcroft LS17 9BF (“we”/ “our” / “us”). We are committed to ensuring that your privacy is protected. We will continue to comply with the provisions of the Data Protection Act (“DPA”) until midnight at the start of 25 May 2018, after which we will comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implementing laws, regulations and secondary legislation as amended or updated from time to time in the UK, and any successor legislation to the GDPR and the DPA (together “Data Protection Legislation”). We are the data controller of data you pass to us pursuant to this policy.

We take issues relating to users of our website extremely seriously. We will respect your personal information at all times. This privacy and cookie policy together with our website terms and conditions set out how we collect personal information from you and how the personal information you provide will be processed by us. By visiting our website, you accept and consent to the practices described in this policy. If you do not consent, please do not submit any personal data to us.

What information do we hold and how will we use it?

We may collect and process the following data about you:

  • Information you give us: You may give us information about you by completing enquiry forms on the website, by signing up as a member, by requesting our email newsletters, by entering competitions via the website, by taking part in Fantasy Golf, payments or surveys or by corresponding with us by phone, email or otherwise. The information you give us may include your name, email address, address / location and phone number. We will retain this information while we are corresponding with you or fulfilling an order you have placed with us. We will retain this information for 1 year.
  • Information we collect about you: We may collect the following information from you when you visit our website:
  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug in types and versions, operating system and platform; and
  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the Site (including date and time), products you viewed or searched for, page response times, website errors, length of visits to certain pages, page interaction information, methods used to browse away from the page and any phone number used to call our customer services number.

We will retain this information for 1 year.

  • Information we receive from other sources: This includes information we receive about you when you use other websites operated by us or other services we provide. This information may include your name, email address, postal address and phone number. We will retain this information for 1 year.

Use made of the information

Provided that we have obtained your consent to the extent we are required to under the Data Protection Legislation, we may use the information we receive and/or collect about you to:

  • fulfil our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested or to sign you up as a member;
  • manage your entry into competitions;
  • manage your entry into Fantasy Golf or surveys;
  • send you newsletters and marketing information if you have consented to us doing so;
  • notify you of products and services we offer that are similar to those you have purchased or enquired about;
  • notify you of other products and services we feel may interest you, or permit third parties to do so if you have consented to us doing so;
  • notify you of changes to our services and publications; and
  • monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website.

We collect and process much of your personal information on the grounds of legitimate interests, which include some or all of the following:

  • where the processing enables us to enhance, modify, personalise or otherwise improve the website, our services and communications for the benefit of our customers;
  • to identify and prevent fraud;
  • to enhance the security of our network and information systems;
  • to better understand how people interact with our websites;
  • administer the website and carry out data analysis, troubleshooting and testing; and
  • to determine the effectiveness of promotional campaigns and advertising.

If we require your personal data for fulfilment of a contract with you (for example to provide your membership or publications you have requested), we may be unable to fulfil the contract without your personal data.

If we are unable to rely on legitimate interests or any other ground set out in the GDPR to process your personal data, we will obtain consent from you to the processing.

If we obtain consent from you to do so, we may provide your personal details to third parties so that they can contact you directly in respect of services and/or products in which you may be interested.

You have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent, or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information) from us please let us know by contacting us via the following webpage http://uploadlibrary.com/SportsPubEditorial/preference-centre/index.html . Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit. Withdrawal of your consent won’t affect any processing we have carried out in respect of your personal data prior to you withdrawing consent.

If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by clicking the “Unsubscribe” option in any email we send to you and providing the details requested or by contacting us here and we will take steps to ensure that this information is deleted as soon as reasonably practicable.

We will not share, sell or distribute any of the information you provide to us (other than as set out in this policy) without your prior consent, unless required to do so by law.

We will use all reasonable measures to safeguard your data but please note we cannot guarantee that any information transmitted over the internet is completely secure.

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may share your information with selected third parties including:

  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • providers of competitions you have entered into where you have consented to the provider contacting you – they will only send you one email;
  • third parties who may wish to contact you in respect of services and/or products they offer or sell which may be of interest to you, provided we receive your consent to such disclosure; and/or
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and analytics and search engine providers that assist us in the improvement and optimisation of the website

Please note that we may need to disclose your personal information where we:

  • sell any or all of our business or assets or we buy another business or assets in which case we may disclose your personal data to the prospective buyer or seller;
  • are under a legal duty to comply with any legal obligation or in order to enforce or apply our terms and conditions; or
  • need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisations and/or governmental bodies for the purposes of fraud protection and credit risk reduction.

Payments

We do not store your payment details anywhere on our system. They are only taken during the checkout process to complete payment. Where the payment is for a third party your payment details will not be passed on.

Cookies

When you visit www.nationalclubgolfer.com, the pages that you view are downloaded to your machine. An item called a cookie is also downloaded to your machine.

Almost all websites do this: cookies allow website publishers to carry out a variety of actions, such as determining whether you are a frequent visitor or a first-time viewer. This enables us to make your repeated visits to NationalClubGolfer.com more convenient.

On a repeat visit, Sports Publications looks for the cookie left on your last visit.

We use the following cookies

  • Strictly necessary cookies. These are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
  • Analytical/performance cookies.These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose

All cookies expire after 1 year.

Users have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time.

By selecting the latter you may be ineligible to receive certain personalised services that require the use of cookies.

For further information on how to control cookies on your machine consult your specific browser help screen.

Email Security 

National Club Golfer will not pass your e-mail address to a third party without your explicit permission.

When we want your permission to do this, we will provide a tick box enabling you to give this permission (or ‘opt in’).

Your Rights

Your rights in respect of your data

There are a number of rights available to you under GDPR:

Access to your information

You can ask us to confirm that we process your personal data and provide access to and copies of the information we hold about you by contacting Tom Irwin.  We will process your request to access your information and provide this information to you free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge if you request more than one copy of the same information.

We will provide the information you request as soon as possible and in any event within one month of receiving your request, unless there are extenuating circumstances. If we need more information to comply with your request, we’ll let you know.

Rectification of your data

If you believe personal data we hold about you is inaccurate or incomplete, or any of the information you provide to us changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database.  If you wish to make any changes to your information, please contact us here.

We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate for us to do so in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.

Right to be forgotten

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

  • where we no longer need your personal data for the purpose for which we collected it;
  • where we have collected your personal data on the grounds of consent and you withdraw that consent;
  • where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
  • where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR);
  • where the personal data has to be deleted to comply with a legal obligation; and
  • where the personal data we process relates to the offer of online services to a child.

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know

To request that your information is deleted, please contact us via the following webpage t.irwin@sportspub.co.uk

Right to restrict / object to processing

In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:

  • if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
  • if you have objected to us processing the data (see below) – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
  • if the processing is unlawful; or
  • if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.

You are entitled to object to us processing your personal data:

  • if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
  • for direct marketing purposes (including profiling); and/or
  • for the purposes of scientific or historical research and statistics.

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.

If you wish to restrict or object to the processing of your information, please contact us here.

Data Portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies:

  • to personal data you provide to us;
  • where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
  • where we carry out the processing by automated means.

We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.

If you have any complaints about our use of your personal data, please contact us. You are also entitled to report any concerns which you may have to supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office. You can call the ICO on 0303 123 1113 or get in touch via other means as set out on the ICO website at https://ico.org.uk/concerns/.

If you have any queries or comments on our privacy policy, please contact us here or you can email Tom Irwin. We always welcome your views about our website and our privacy policy.

Fair Processing Notice

When we process your personal data we are required to comply with the Data Protection Act 1998 (“DPA”) until 25 May 2018, and in substitution from 25 May 2018, the General Data Protection Regulation 2016 (“GDPR”) (the DPA and GDPR are together referred to as the “Data Protection Legislation”).

Your personal data includes data all the information we hold that identifies you or is about you, including but not limited to your name, email address, postal address, date of birth, location data and in some cases opinions that we document about you.

Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We are therefore required to comply with the Data Protection Legislation to make sure that your information is properly protected and used appropriately.

This fair processing notice provides information about the personal data we process about you, why we process it and how we process it.

Our responsibilities

Sports Publications Limited (“Sports Publications”) is the data controller of the personal data you provide. We have appointed Matthew Beedle our digital marketing executive as privacy officer and they will have day to day responsibility for ensuring we comply with the Data Protection Legislation and dealing with any requests we receive from individuals exercising their rights under the Data Protection Legislation.

Why do we process your personal data?

We process your personal data in order to fulfil the contract we have entered into with you, to receive services or goods from you, and/or to provide services, products or the subscription you have requested from us. We may also process your personal data to respond to any queries or comments you submit to us, including via our websites.

We may need personal data from you to be able to enter into a contract with you and provide you with all the information you need. If we do not receive that personal data from you, we may be unable to fulfil our obligations to you.

We process most of your information on the grounds of our legitimate interests (i.e. processing that is necessary to continue our relationship with you and to provide you with products, services or your subscription or to receive products or services from you), fulfilment of our contract with you or to comply with a legal obligation.

If none of the grounds set out above applies, we will obtain separate consent from you to the processing of your personal data. You can withdraw your consent at any time. This won’t affect the lawfulness of any processing we carried out prior to you withdrawing your consent.

Who will receive your personal data?

We only transfer your personal data to the extent we need to. Recipients of your personal data include:

  • Sports Publications Ltd
  • NationalClubGolfer.com
  • Lady-Golfer.com
  • Pure360
  • Pipedrive
  • Google Drive

We don’t transfer your personal data outside of the EEA

How long will we keep your personal data?

We will retain your personal data for 1 year. We retain your information for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times. Following the end of the 1year period, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to send you marketing communications, any information we use for this purpose will be kept until you withdraw your consent, unless we have other legitimate reasons to retain the data.

What are your rights?

You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website. These rights apply for the period in which we process your data.

  1. Access to your data

You have the right to ask us to confirm that we process your personal data, as well as access to / copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair processing notice.

We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.

We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.

  1. Rectification of your data

If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.

  1. Right to be forgotten

In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:

  • where we no longer need your personal data for the purpose for which we collected it;
  • where we have collected your personal data on the grounds of consent and you withdraw that consent;
  • where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
  • where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR); and
  • where the personal data has to be deleted to comply with a legal obligation.

There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.

  1. Right to restrict processing

In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:

  • if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
  • if you have objected to us processing the data – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
  • if the processing is unlawful; or
  • if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
  1. Data portability

You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:

  • where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
  • where we carry out the processing by automated means.

We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.

  1. Right to object

You are entitled to object to us processing your personal data:

  • if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
  • for direct marketing purposes (including profiling); and/or

In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.

Automated decision making

Automated decision making means making a decision solely by automated means without any human involvement. This would include, for example, an online credit reference check that makes a decision based on information you input without any human involvement. It would also include the use of an automated clocking-in system that automatically issues a warning if a person is late a certain number of times (without any input from HR, for example).

We don’t carry out any automated decision making using your personal data.

Amazon Affiliates

We are a participant in the Amazon Services LLC Associates Programme, an affiliate advertising programme designed  to provide  means for us to earn fees by linking to Amazon.co.uk and affiliated sites.

***Please read all of this Privacy Policy as well as the Terms and Conditions very carefully prior to commencing use of this web site and on each and every occasion that you use this web site in the future to check for updates.

ADD COMPANY INFORMATION:

THIS SITE IS OWNED AND OPERATED BY SN&CK MEDIA LIMITED.

SN&CK MEDIA LIMITED IS A COMPANY REGISTERED IN ENGLAND UNDER THE NUMBER 6120966

The registered address is 70 Rosebery Avenue, London, EC1R 4RR

Our data protection number is XXXXX.

SN&CK MEDIA LIMITED IS LIMITED COMPANY WHO BUILDS COMMUNITIES OF FANS, WE OWN OR MANAGE THE FOLLOWING SITES: LINK TO SITE LIST. 

SN&CK MEDIA WILL process personal information only in strict compliance with the Data Protection Act 2018 (as amended), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other associated data protection legislation. Your visiting this web site constitutes acceptance of and consent to the practices set out in this Privacy Policy. If you do not agree with any of the terms as set out in this Privacy Policy then you should cease using this web site immediately.

SN&CK MEDIA reserves the rights to change this Privacy Policy at any time by posting an updated version on the web site. The date that the web site was last updated is shown at the bottom of this web page. Your continued use of this site after an updated version is posted constitutes your acceptance of and consent to the practices set out in this Privacy Policy as modified.

WHAT DATA WE COLLECT

We collect both non-personal and personal data on an ongoing basis.

Personal: 

  • IP address
  • Email address
  • Telephone number
  • Address 
  • Demographic details
  • Behavioural data (what you are interacting with on our site)
  • Device data (e.g. Phone, desktop, tablet) 

Non-personal:

  • Web browser details, operating system data, date and time stamps.

We collect your personal data in various ways:

  • directly from you, when you sign up for our services and when you browse our sites 
  • personal data we generate about you, e.g. personal data we use to authenticate you, or personal data in the form of your IP address or your preferences
  • personal data we collect from third parties, e.g. personal data that helps us to combat fraud or which we collect, with your permission, when you interact with your social media accounts

Your personal information is not collected from you automatically, simply as a result of your accessing this web site. It is only collected on a voluntary basis, resulting from your own input of this information. The only information that is collected automatically when you access this web site is the IP address of the computer that you are using. For more information on IP addresses, please see below.

We will also collect information on our server logs from your browser including your IP address, web-browser details, operating system details, and your activities whilst on the Website together with information about other websites that you have visited either before or after you have entered onto the Website.

If you register your personal details with this web site, it is only known SN&CK Media Limited and the companies it owns, data processors who are contracted to SN&CK MEDIA only where there is specific need to process the data, THE OTHER WEBSITES WITHIN THE SN&CK MEDIA GROUP and IF YOU EXPLICITLY CONSENT, THIRD PARTY PARTNER BRANDS. If you choose to register, SN&CK MEDIA will request information such as your name, email address, address, telephone number or other contact details as required. This information will then be held by SN&CK MEDIA as it is necessary for SN&CK MEDIA to carry out the services for which you registered. SN&CK MEDIA also use this information to improve the function of the web site and to prevent any abuse to the web site. This information will not be kept indefinitely, only for the statutory period allowed under the Data Protection Act 2018 (as amended).

SN&CK MEDIA will also keep any correspondence you send whether by email or standard mail. This correspondence will not be kept indefinitely, only for the statutory period allowed under the Data Protection Act 2018 (as amended).

HOW IS YOUR DATA USED?

We use personal data collected through our sites and apps only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.

The legal ground may be one of the following:

  • Consent: For example, where you have provided your consent to receive marketing emails from us. You can withdraw your consent at any time. In the case of marketing emails you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email or by emailing gdpr@snack-media.com
  • Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a product from us and we need to use your contact details and payment data in order to process your order and deliver your product.
  • Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
  • Our legitimate interests: Where it is necessary for us to understand our readers, promote our services and operate our sites and apps efficiently for the creation, publication and distribution of content online. Examples of when we rely on our legitimate interests to use your personal data include:
  1. when we analyse what content has been viewed on our sites, so that we can understand how they are used and improve our content
  2. to carry out marketing analyses to better understand your interests and preferences so that we can make our marketing more relevant to your interests and preferences. This includes when we promote our own products and services. For example, we look at what you have viewed on our sites or what products have bought. You can opt out from having your personal data used for marketing analyses by emailing gdpr@snack-media.com
  3. to show you personalised advertising by identifying your interests and to create “segments” of particular types of audiences so that we may show you advertisements that may be more relevant to your interests and the ‘’segments’’ you may be in. These ‘’segments’’ are also used to inform the building of custom audiences so that we can identify our audience across third party websites, such as social media platforms like Facebook. 
  4. for internal administrative purposes related to when you use our services – such as our accounting and records – and to make you aware of any changes to our services
  5. to collect and log IP addresses to improve the website and monitor website usage
  6. to personalise our services (for example, so you can sign in) by remembering your settings, and recognising you when you sign in on different devices
  7. enabling you to share our content with others using social media or email
  8. when responding to your queries and to resolve complaints
  9. for security and fraud prevention, and to ensure that our sites and apps are safe and secure and used in line with our terms of use

WHO WE SHARE YOUR DATA WITH

We use third-party advertising companies to serve ads when you visit our Web site. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you.  If you would like more information about this practice and to know your choices about not having this information used by these companies, please see: http://www.networkadvertising.org/managing/opt_out.asp


All the information that SN&CK MEDIA sites collect via the web site or correspondence is used to help SN&CK MEDIA understand more about who uses the web site and to help improve the web site and the services that it offers. It will also help SN&CK MEDIA to send communications to you that may be of interest.

We do share information about users with third parties order to promote, sell or enhance the products and services we provide but we only disclose such information in an aggregated or anonymised form so that the information is incapable of identifying you as an individual, unless you have given us prior consent to do so. We take the privacy of our users very seriously, we do not rent, sell or share your personal data with other people without gaining your consent to do so. However, in limited circumstances, your personal data may be passed to a third party in any one of these circumstances without explicit consent:-

  • If SN&CK Media Limited have a duty to do so or if the law allows or requires SN&CK Media Limited to do so;
  • If SN&CK Media Limited or its assets are sold to or purchased by another company or person;
  • To affiliated businesses or subsidiary or parent companies of SN&CK Media Limited.
  • If SN&CK Media Limited wishes to or is required to pass on your information to a third party in these limited circumstances, it will send an email notice and give you the opportunity to opt-out.

SN&CK Media Limited may use the personal information that you have provided to contact you by any of the methods which you input. If you have provided us with your email, you will be added to SN&CK Media newsletter database and you will receive content, news and additional information about new services, features or products  from the site your signed up via in the SN&CK Media group and other sites within SN&CK Media group. If you do not want to be contacted in this way then please click where indicated when you are completing any of the online forms where you initially input your personal details, by changing your personal details on the [“personal details”] page when you are logged on to the web site, or by contacting SN&CK Media Limited via the contact page at any time after submitting your personal details.

As the Internet is a global network, there may be instances when your personal data travels across international borders. This may include transfers outside the EU and the EEA. If you do voluntarily input any personal information via this web site or send correspondence, then in doing so you are authorising SN&CK Media Limited to transfer your personal data in this way.

Where we embed the Dugout video player into our website, Dugout and SN&CK Media Limited are joint data controllers in respect of the initial collection of information about your device collected by Dugout for advertising and analytics purposes. In terms of the division of data protection obligations in respect of this processing, SN&CK Media Limited provides notice and obtains your permission for the collection of the device data, but SN&CK Media Limited and Dugout are otherwise responsible for their own compliance with data protection legislation. Further information on how Dugout processes your information; including how Dugout enables you to exercise your data protection rights, can be found in the Dugout Privacy Policy https://dugout.com/privacy-policy

LiveRamp

When you log into our website, we may share information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with our partner LiveRamp. LiveRamp uses this information to create an online identification code for the purpose of recognizing you on your device. This code does not contain any of your identifiable personal data and cannot be used to re-identify you. We place this code in our cookie and allow it to be used for online and cross-channel advertising. It may be shared with our  advertising partners and other third party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc). These third parties may in turn use this code to link demographic or interest-based information you have provided in your interactions with them. You have the right to express a choice regarding our sharing of this data with LiveRamp for the above purposes, of the creation of this code, or of our sharing of the code with our advertising partners.

When you use our website, we share information that we may collect from you, such as your email (in hashed, de-identified form), IP address or information about your browser or operating system, with our partner, LiveRamp Inc and its group companies (‘LiveRamp’). LiveRamp may drop a cookie on your browser or directly in our emails and match your shared information to their on- and offline marketing databases and those of its advertising partners to create a link between your browser and information in those other databases. Similarly, when you use our mobile apps, we may also share hashed and de-identified email addresses, mobile device ID, location data, and advertising identifiers with LiveRamp, which uses that information to create a link between your mobile device and its databases. This link may be shared by our partners globally for the purpose of enabling interest-based content or advertising throughout your online experience (e.g. cross device, web, email and in app etc.) by third parties unaffiliated with our website. These third parties may in turn link further demographic or interest-based information to your browser. You have the right to exercise your rights under GDPR including opting out of LiveRamp’s Cookie or Mobile Identifiers and can easily do so by clicking on this link: https://your-rights.liveramp.uk/home

Other parties include:

If you choose to enter a competition and promotion on a website owned and operated by SN&CK Media which co-branded with another brand/partner, we will also provide the data to that brand/partner. In this case we make it known to you at the point you submit your personal data and you withdraw your consent at any point after. 

From time to time, our marketing communications may feature content from third party brands. We will not share personal data with these brands, without your explicit consent.

HOW AND WHY WE SHARE YOUR PERSONAL DATA

With consent, we use data to:
– analyse user cohorts and behaviours across our website; we build aggregated audiences around key attributes and behaviours.
– facilitate targeted advertising on sites owned by SN&CK Media limited to provide relevant advertisements to you and to make effective use of advertising inventory.

We facilitate the above functions by using advertising technology providers:

Lotame

With consent, we use data to:
– analyse user cohorts and behaviours across our website; we build aggregated audiences around key attributes and behaviours.
– facilitate targeted advertising on sites owned by SN&CK Media limited to provide relevant advertisements to you and to make effective use of advertising inventory.

We facilitate the above functions by using advertising technology providers:

LOTAME  data management platform, for the purpose of gaining audience insights and enabling consented audience data to be activated through our advertising platforms. Lotame uses cookies and other identifiers to track online behavioural, demographic and technographic data; they don’t receive information such as your name and email. Lotame can also receive anonymous data segments that FLW sends, such as user IDs associated with people who have been registered members for a certain length of time. Lotame stores data on average for 9 months, and in special cases for up to 18 months. Lotame’s privacy policy: https://www.lotame.com/about-lotame/privacy/lotames-products-services-privacy-policy/.

MARKETING SERVICE PROVIDERS

We will share your data with the Marketing Services Providers listed below, who will use it for a variety of direct marketing, testing, research & product development purposes. Marketing Services Providers carry out data profiling. They will combine your data with data they get from other sources (including public sources) and use it to create “predictive models”. Marketing Services Providers use these models to try to predict behaviour and preferences (e.g. how likely you are to buy a holiday online or take a particular type of holiday) or likely circumstances (e.g. whether you are eligible for a particular credit card).

Marketing Services Providers will also try to match and then link your data with data that they receive about you from other sources, to make sure that the data they hold about you is correct (e.g. to check whether you have recently moved address).

They share your data, including the profiled data they have created about you, primarily to:

  • help organisations better understand the likely characteristics of their customers (and find others like them);
  • improve the relevancy and appropriateness of an organisation’s marketing to its customers (e.g. offers, its products and services); and
  • help them communicate with their customers more effectively offline and online. This may mean that you receive tailored advertising via direct mail or when you visit a website.

ESB CONNECT LIMITED
ESB Connect provides email marketing and customer acquisition service. They provide the CRM and Email marketing platform which we utilise to send our email. ESB Connect acts as a data processor in all circumstance and will process the data under our instructions. If you explicitly consented, ESB Connect LTD under the brand Opt-me-in.com will also act as a data controller. To view their privacy policy, please see here: http://privacy.esbconnect.com/

DOES SN&CK MEDIA LIMITED USE COOKIES OR WEB BEACONS?
Like many web sites, this web site does use cookies. This enables SN&CK Media Limited to provide you with a more personalised service.

Cookies are small text files that are transferred from a web site by your web browser and stored on your computer. The cookie is then used by that web site to remember who you are from your last visit to that web site. The information that the cookie holds will typically consist of the domain name of where the cookie came from, how long the cookie will remain on your computer before it expires and a unique value assigned to the cookie which is made up of a randomly generated number. A Cookie may also contain your “log in” information that will allow you to log in automatically when visiting the web site. Cookies are not computer programs, they cannot read any information from your hard drive and they do not disseminate viruses.

You can set your web browser to reject cookies, though please be aware that the SN&CK Media Limited web site may not function correctly if you do this.

For more information about cookies, including how to disable them, please go to www.allaboutcookies.org.

Some of the web pages of the web site may contain “clear gifs” or “web beacons”. These are used to count the number of users who access those pages and only collect information relating to the time, date and the page that was visited. They do not carry any personal information and are only used to track how effectively certain aspects of the web site are performing.

HOW WE MAY CONTACT YOU

Service communications

From time to time we may send you service emails, SMS or direct mail, for example, telling you the privacy policy has been updated.

Marketing communications and editorial newsletters

Where you have given us your email address and or phone number, we may send you marketing communications containing news and content we think may interest you. This from time to time may contain offers from brands we partner with.

If you have given us explicit consent to do so, we may additionally send you communication purely featuring content from brands and partners we work with which we believe is relevant to you, in this case your permission would have been gained. Depending on your marketing preferences, this may be by email, phone, SMS or post.

You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email or via emailing gdpr@snack-media.com

Market research

Sometimes we may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by emailing gdpr@snack-media.com

Responding to your queries or complaints

If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.

IP ADDRESSES
The IP address of the computer you use to access this web site is automatically provided by your browser each time you view the web site. If you provide any personal information via this web site then the IP address of the computer you are using at the time you provide this information will be stored by SN&CK Media Limited. IP addresses may be used by SN&CK Media Limited for various reasons, including but not limited to differentiating between users from different geographical locations or to help with technical problems that may relate to certain groups of IP addresses.

CUSTOMER AND CITIZEN DATA RIGHTS

As prescribed within data protection regulations, you have specific rights connected to the provision of your personal data to SN&CK Media using this website. These include your rights to request we:

  • confirm to you what personal data we may hold about you, if any, and for what purposes
  • change the consent which you have provided to us in relation to your personal data
  • correct any inaccurate or incomplete personal data which we may hold about you
  • provide you with a complete copy of your personal data for you to move elsewhere
  • stop the processing of your personal data, whilst an objection from you is being resolved
  • permanently erase all your personal data promptly, and confirm to you that this has been done (there may be reasons why we may be unable to do this). Please note that the right to erasure is not an absolute right and should you wish to be removed from marketing lists, your email/telephone/address will be held on file as suppression to ensure we honour your unsubscribe request.

If SN&CK Media does not address your request, or fails to provide you with a valid reason why we have been unable to do so, you have the right to contact the Information Commissioner’s Office to make a compliant. They can be contacted via their website (www.ico.org.uk) or by telephone 0303 123 1113.

HOW SECURE IS MY PERSONAL INFORMATION?
The security of your personal information is very important to SN&CK Media Limited and it takes all steps it deems reasonably necessary to ensure such security. However, the transmission of data over Internet cannot be guaranteed to be completely secure and failsafe. As such, SN&CK Media Limited is not able to warrant or guarantee the complete security of any personal information that you provide and it is important that you are aware that providing any such information is done so entirely at your own risk.

FURTHER INFORMATION
If you would like to update your personal information held by SN&CK Media Limited or you have any dispute regarding the use and storage of your personal information by SN&CK Media Limited or you have any comments or questions on this Privacy Policy please contact SN&CK Media Limited via the contact page.

gdpr@snack-media.com

SN&CK Media Limited
70 Rosebery Avenue,
London,
EC1R 4RR

Your right to complain about our processing

If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website.

Any questions?

If you have any questions or would like more information about the ways in which we process your data, please contact Tom Irwin.

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