Your privacy matters
Who we are and how to contact us
Celtic Media Group (CMG) are publishers and printers of regional newspaper titles across Ireland including; The Anglo Celt, The Connaught Telegraph, The Meath Chronicle, The Offaly Independent, The Westmeath Examiner and The Westmeath Independent.
This document outlines our approach to compliance with the General Data Protection Regulation (GDPR) and all other relevant data-protection legislation. It also sets forth your privacy rights. Please take a moment to familiarise yourself with our privacy practices.
Data protection contact
We have appointed a Data Protection Contact and they will be your initial point of contact for all data-protection inquiries. They can be reached by email at email@example.com or by phone at +353-44-934-6700.
Information we collect and how we use it
We collect and use your personal information for a variety of reasons including:
If you register, purchase or subscribe to our Services
- To create an account with us
To become a subscriber to any of the CMG publications or to purchase to one of our other Services, you will need to create an account with us. We will use your personal information to carry out our obligations arising from any contract you as our customer have entered into with us, including sending important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service. We may notify you by phone, post, email, SMS text or through other digital media depending on the content of the notification and your preferred contact mechanism.
If you cancel your subscription with us, we may use your personal information for direct marketing (provided you have not objected to us using your details in this way). We will generally send you direct marketing by email. We will use your information for a period of no longer than 30 days after your relationship with us has ended.
Specifically, we will send you a short series of emails to remind you of the benefits of a subscription with us. You have the right to unsubscribe to receipt of these emails at any time. We rely on the lawful processing ground of our legitimate interests which are:
- To keep you informed of the benefits of a subscription.
- To develop and maintain relationships with our customers
- To implement customer-retention and win-back strategies
- To pay for the Services you have requested from us
We will collect your payment information to pay for any Services you have requested from us. Credit and debit card information is processed directly by PCI-compliant payment providers who perform payment services on our behalf.
Occasionally, our employees receive payment information from customers over the phone. When this occurs, the payment information is entered as instructed into the relevant payment system and all other copies are deleted or destroyed immediately.
- To place an advertisement
We may process your personal information if you opt to place an advertisement. We only process this information to deliver the advertising service you have requested as per the terms and conditions you accept.
- To deliver marketing, promotions and conduct research
- To receive marketing communications
We may periodically send promotional emails about features, events, exclusive offers and competitions to the email address you have provided – we will only do so with your consent.
We have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing communications tailored to your interests. You may at any time choose not to receive marketing communications from us by following the unsubscribe instructions included at the end of each email communication.
- For competition and promotional purposes
We regularly run competitions or similar promotions. If you choose to enter a competition or promotion, we will use your personal information to administer these promotions and as per the terms and conditions you accept when you enter. In some cases, your competition entry may be shared with the promoter and this will be clearly specified when you enter.
If you win a competition, your contact information will be used to notify you as the winner and to award the relevant prize. We will publish your name on our website and indicate the prize you have won. All competition information is destroyed strait after the closing date with the exception of the winner(s) which will be kept for a period of no longer than 30 days.
To deliver our content to you
- To provide you with an email newsletter
We offer a number of ezines to non-subscribers.
We will only send you these with your explicit consent. We collect and use your information to send you the ezine(s) you have requested and in some cases to personalise the email we send. You can opt out at any time by unsubscribing at the bottom of each email newsletter communication.
To understand how you use our services
- To track how you gain access to or read our content
We collect information relating to your use of our services to track how you gain access to or read our content. We use log-in information, cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services as follows:
When you sign up for or subscribe to one of our services, we will track and aggregate non-personal information previously collected about you through our services with the personal information provided when you register or subscribe.
You have the right to object to this processing, and if you wish to do so please contact us at firstname.lastname@example.org.
We log technical information that your browser sends us including: the internet protocol (IP) address; browser type and version; time-zone setting; access time; browser plug-in types and versions; operating system; and platform and device type
We log usage information about the use of our website and services, including: a history of the pages viewed and other actions taken, including the full Uniform Resource Locators (URL) clickstream to, through and from our site; articles, content and products viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
Technical information, including: the type of mobile device used; unique mobile identifies, such as the devices IMEI number; mobile network information; the mobile operating system; the type of mobile browser used; and the time-zone setting.
- To measure the effectiveness of our email communications
We use such technologies to determine whether you’ve opened an email communication from us or clicked on a link contained in an email. Collecting information in this manner allows us to gather statistics about the usage and effectiveness of our services and products, including our email newsletters and direct marketing communications, in our legitimate interest.
To support our advertising services
Third-party vendors, including Google, display advertising on our Services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site. This type of behavioral advertising is targeted towards groups of users in an anonymous and aggregated manner as opposed to you as an individual. Such online advertising helps support the content, products and services we provide.
We and third-party vendors use first-party cookies and third-party cookies together to inform, optimise and serve ads based on your browsing activities and interests. Any information we disclose to advertisers and advertising networks is non-personally identifiable.
- To correspond with you
If you correspond with us, we will use your contact information to respond to your enquiry. We process this information in pursuit of our legitimate interests to develop and maintain relationships with our customers and readers.
- To manage our everyday business needs
We may use your personal information to manage our every business needs, including for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention in our legitimate interest. Our legitimate interest is the effective management of our business.
- To verify your identity
To exercise your data rights, we may need to collect additional personal information from you to verify your identify and to process your request.
- When you provide professional services to us
You may provide us with your personal information if you provide professional services to us. We process this information so we can administer, manage and pay for the relevant services you provide and as per the terms and conditions of our contract.
Anonymous information we process
The legal basis for processing your information
We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.
To enter into and perform a contract with you
We use your personal information to carry out our obligations arising from any contracts entered into between you and us or to take the necessary steps at your request prior to entering into a contract with us including:
- To provide you with the subscription, services or products you have requested
- To process your payment information
- To authenticate and verify your account
- To provide customer and technical support
- To administer competitions or similar promotions
- To pay for the services you may professional provide to us
- To send important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service
With your consent, which can be withdrawn at any time
We will, in certain circumstances, rely on your explicit consent to process your personal information. Where we do, you have the right to withdraw your consent at any time. In most circumstances, your consent can be withdrawn by following the unsubscribe instructions included at the end of each email communication from us. You can also contact us at email@example.com and we will be happy to facilitate your request.
To comply with our legal obligations
We may be required to process your personal information to comply with certain legal obligations to which we are subject, including:
- Providing information to an Garda Síochána, the Revenue Commissioners or other Government bodies or agencies when required to do so by law
- If you have exercised one of your data rights, we will retain a copy of all correspondence to demonstrate our compliance with data-protection legislation
- If you have exercised one of your data rights and ask us not to contact you by email at a particular email address, we will need to retain a copy of that email address in order to comply with your no-contact request
- To carry out our statutory audit
Processing based on our legitimate interests
We process your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. Our legitimate business interests do not automatically override your interests. You have the right, free of charge, to object to our use of your personal information for our legitimate interests. If you wish to do so contact us at firstname.lastname@example.org.
Please bear in mind that if you do object, this may affect our ability to carry out certain tasks for your benefit. Where you object to our use of your personal information for our legitimate interests, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so. We will always ensure there is a fair balance between our legitimate interests and your fundamental right and freedoms.
We process personal information for the following legitimate business purposes:
- To manage our everyday business needs and for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention
- To support our advertising services
- To develop and maintain relationships with our customers and readers
- To protect you against fraud and to detect, prevent, investigate security or technical issues to ensure our Services are secure
- To protect the rights, property and safety of CMG or the rights, property or safety of our employees or others
- To understand the demographics of our customers and readers
- To send direct marketing to our subscribers or former subscribers.
- When and how your information is shared
Within our group
With third parties
We may share your personal information with third parties for a number of reasons as outlined below. We do not sell your personal information to anyone and only share it with third parties who are facilitating the delivery or fulfilment of our services and or are working on our behalf. We contractually require that our suppliers protect such information from unauthorised access, use, and disclosure.
Third-party service providers
We may share your personal information with third-party service providers which perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, payment providers, lawyers, providers of security and administration services and other business advisers.
Third-party service partners
We provide certain services and run promotions in conjunction with third parties and we may share your personal information if the service you have requested is fulfilled by them. These third parties have their own security and privacy policies. You are advised to review these separately.
We disclose non-personally identifiable anonymous information to third-party advertisers to help them reach the kind of audience they want to target. We share summary aggregate reports for our advertisers to measure the effectiveness of the ads they have served. These advertising parties may combine the information we send with other information that you’ve provided to them or that they’ve collected from your use of their services.
Social networking sites
If you are a member of a social media site and logged in, the interfaces configured on our Services allow the social media site to connect your site visit and browsing behaviour to the personal data held on your social media site.
CMG can use this information on an aggregate basis to place ads that are based on your interests on these social media sites. These practices are governed by the privacy statements of these social networking sites and you are advised to review these separately.
Data storage and retention
We will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information no longer than is necessary to comply with our business and legal obligations. Where we enter into a legal contract with you, we will hold your personal information for a period of seven years from the date of completion of this contract by reference to the statute of limitation for a legal claim under contract.
Your data rights
You have several rights under data-protection law in relation to how we use your personal information. You have the right, free of charge, to:
- Request a copy of the personal information we hold about you in a structured, commonly used and machine-readable format
- Rectify any inaccurate personal information we hold about you
- Withdraw your consent where we have relied upon your consent to process your information
- Erase the personal information we hold about you subject to certain exceptions
- If technically feasible, have your personal information transmitted to another data controller in a machine-readable format at your request
- Restrict processing of your personal information in certain circumstances
- Object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes
- Not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature
- Lodge a complaint with the appropriate data-protection authority if you have concerns about how we process your personal data
These rights are in some circumstances limited by data-protection legislation. If you wish to exercise any of these rights please contact us at email@example.com. We will take measures to verify your identify which we will do by reference to copies of acceptable identification documentation supplied by you.
We will endeavor to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.
Consequences of not providing information
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Processing for journalistic purposes
As a news publishing organisation, CMG processes personal data for the purpose of exercising the right to freedom of expression and information and for journalistic purposes.
This processing is exempt from compliance with certain obligations of the GDPR.
- We may process your personal information for journalist purposes where you submit content to be published online and in our printed publications
- Where you have voluntarily contributed your experience to us and we publish this information
- If we publish a letter you have written to the Editor
- If you participate in our discussion forums
It is important to understand that certain rights which you have in relation to your personal information may not apply where that data is processed for journalistic purposes.