Privacy Policy
Your privacy is important to us
Introduction
This is the privacy policy for DC Thomson & Co. Ltd and the companies and brands that form part of the
DC Thomson group (“DC Thomson”). It explains how we use your personal
information when you give it to us, or when we collect it from you as you interact with our brands.
When we say “we” or “us” in this policy, we’re referring to companies and
brands that are part of DC Thomson. Each of our companies is what is known under data protection law
as a ‘data controller’. This means each company is responsible for processing your personal
information in a lawful manner – and where more than one of our companies is involved, they’re jointly
responsible. If you have any questions about how your we use your personal information or wish to exercise
any of your rights, then you should use the contact details below.
To make it easier for you to understand how we use your personal information, we’ve created a single policy
to cover our companies and brands. Our brands page contains information about many of these. We also have a single point
of contact for any questions that you may have in relation to our use of your personal information.
Some brands within DC Thomson have their own separate privacy policies. These include:
Where one of our brands has its own privacy policy, or uses a supplemental privacy policy, then we’ll let
you know about that at the time we collect that information from you.
What Personal information do we collect and how do we use it?
In this policy, ‘personal information’ means personal data about you, from which you can be identified.
It does not include data that can no longer be used to identify you.
The types of personal information we collect and how we use it depend on how you interact with us.
You can find out how we use your personal information by clicking on the sections below that are most
relevant to you:
If you subscribe to one of our newspapers or magazines
We process your personal information when you have an active newspaper, magazine or digital product
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 or digital
product 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)
| Reason for processing your personal information | Your personal information | Legal ground(s) for processing | Our legitimate interest (where applicable) |
| 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 To register and operate your online account To contact you with information and updates regarding your subscription, including renewal To notify you of subscriber-related content and events and provide you with access to them |
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 If you register using Facebook or Google we will collect the information you’ve allowed them to share Marketing preferences you’ve indicated to us Nominated recipient details Gift message for nominated recipient |
Necessary to perform the contract between us
Necessary for our legitimate interests |
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 |
| To process your payments (including recurring payments) and collect and recover money owed to us |
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 Purchase details and order history Company/ organisation name Job title VAT number |
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 |
To recover debts owed to us
To provide you with order documentation such as order confirmation
|
| 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 when we may show you our marketing (for example adverts) on other platforms such as Facebook |
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 (e.g. a record of the pages you visit) and other |
Necessary for our legitimate interests
Consent |
To promote our products and services
To send direct marketing communications, to make these more relevant to you where possible, and To remain engaged with you and to bring you additional benefits where possible |
| 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; and confirming when you have completed a particular activity (for example when you have changed personal |
Name
Email address Home address Phone number(s) Login details for your online account Marketing preferences you’ve indicated to us Purchase details and order history Payment information Nominated recipient details |
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 Necessary for our legitimate interests |
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 |
| To help us analyse and improve the technical functionality, security and performance of our websites |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and other |
Necessary for our legitimate interests | To ensure our websites operate to the high standards you expect |
| To help us improve the quality and variety of the content and features we provide in our newspapers, magazines or digital products |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and other |
Necessary for our legitimate interests | To continuously improve our content and features, as well as develop new ideas that we think our customers will like |
| 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 |
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 Information you provide when you visit our websites (e.g. a record of the pages you visit) and other Purchase details and order history Nominated recipient details |
Necessary for our legitimate interests | 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. |
How we obtain your personal information
We collect your personal information directly from you when you take out a newspaper, magazine or digital
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.
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.
If you visit one of our websites or register for an online account (including ‘free’ accounts)
We process your personal information while you visit one of our websites or register for an online account
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 content, services or events through
our websites or your online account; - 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, or use
your information to contact you about a question you’ve asked or a comment you’ve added to our content).
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 to update
you about how we use your personal information under data protection laws).
| Reason for processing your personal information | Your personal information | Legal ground(s) for processing | Our legitimate interest (where applicable) |
| To register and operate your online account | Name
Email address Home address Phone number(s) Title Company/organisation name Job title Job function Login details for your online account If you register using Facebook or Google we will collect the information you’ve allowed them to Marketing preferences you’ve indicated to us |
Necessary to perform the contract between us | |
| To provide and administer any content or features you’ve registered for (e.g. premium articles or the ability to save articles to read later) To display your comments online |
Name
Email address Home address Phone number(s) Title Company/ organisation name Job title Login details for your online account Personal interests you’ve indicated to us Display name Personal information included in your comments, for example, an indication of your political or Details of your interactions with other users’ comments |
Necessary to perform the contract between us | |
| To moderate comments that you make on our website content | Name
Email address Login details for your online account Display name Personal information included in your comments, for example, an indication of your political or Details of your interactions with other users’ comments |
Necessary for our legitimate interests
|
To ensure that comments posted within our communities do not breach our community standards and to investigate any comments reported to us |
| 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 when we may show you our marketing (for example adverts) on other platforms such as Facebook |
Name
Email address Home address Phone number(s) Title Company/organisation name Job title Marketing preferences you’ve indicated to us Personal interests you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests
Consent |
To promote our products and services
To send direct marketing communications, make these more relevant to you where possible, and To remain engaged with you and to bring you additional benefits where possible |
| 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; and confirming when you have completed a particular activity (for example when you have entered one |
Name
Email address Home address Phone number(s) Title Company/organisation name Job title |
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 Necessary for our legitimate interests |
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 |
| To help us analyse and improve the technical functionality, security and performance of our websites |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To ensure our websites operate to the high standards you expect |
| To help us improve the quality and variety of the content and features we provide through our websites and online accounts |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To continuously improve our content and features, as well as develop new ideas that we think our customers will like |
| 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 |
Name
Email address Home address Phone number(s) Title Company/organisation name Job title Job function Marketing preferences you’ve indicated to us Personal interests you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and Details of your interactions with other users’ comments |
Necessary for our legitimate interests | 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. |
How we obtain your personal information
We collect your personal information directly from you when you visit one of our websites or register for
an online account. Where an organisation (such as your employer) has registered for an online account
and you have been approved as a user of the account, we may collect your personal information from them. We
also analyse how you interact with us, for example when you comment on an article or get in touch with a
query.
We may obtain your personal information from third parties you use to access our websites (e.g. Facebook),
but only the limited information you allow them to share with us.
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 provide the content or features you want. For example, if you don’t give
us your email address, you won’t be able to register for an online account.
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 providers of particular website features (e.g.
the feature that enables you to comment on our newspaper articles), 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.
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.
If you participate in one of our online communities or membership groups
We process your personal information when you use or register for an account on one of our online
communities or membership groups, 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 access to the online community or
membership group through your account; or - 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 or use
your information to contact you about a question you’ve asked). 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, to
update you about how we use your personal information under data protection laws).
| Reason for processing your personal information | Your personal information | Legal ground(s) for processing | Our legitimate interest (where applicable) |
| To register and operate your online account | Name
Date of birth Email address Home or delivery address Company/organisation name Job title Job function Login details for your online account Display name Subscription details |
Necessary to perform the contract between us | |
| To provide and administer any content or features you’ve registered for (e.g. premium content or articles) To display your comments online |
Name
Date of birth Home address Email address Phone number(s) Title Login details for your online account Personal information included in your comments, for example, an indication of political or Details of interactions with other users’ comments |
Necessary to perform the contract between us | |
| To moderate comments that you make on our online communities. | Display name
Email address Login details for your online account Personal information included in your comments, for example, an indication of political or Details of interactions with other users’ comments |
Necessary for our legitimate interests
|
To ensure that comments posted within our communities do not breach our community standards and to investigate any comments reported to us |
| To process your subscription payment and collect and recover money owed to us | Name
Email address Billing address Bank account and payment card details Subscription details |
Necessary to perform the contract between us
Necessary for our legitimate interests |
To recover debts owed to us |
| To send you marketing communications with our suggestions and recommendations about goods and services that may be of interest to you. This includes: when provide you with personalised content and/or display tailored messaging to you when you when we may show you our marketing (for example adverts) on other platforms such as Facebook. |
Name
Email address Marketing preferences you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests
Consent |
To promote our products and services
To send direct marketing communications, make these more relevant to you where possible, and To remain engaged with individuals and to bring them additional benefits where possible |
| 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; and confirming when you have completed a particular activity (for example when you have changed |
Name
Email address Phone number(s) Display name Login details for your online account Marketing preferences you’ve indicated to us Payment information |
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 Necessary for our legitimate interests |
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 |
| To help us analyse and improve the technical functionality, security and performance of our websites |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | We have an interest in ensuring our websites operate to the high standards you expect. |
| To help us improve the quality and variety of the content and features we provide through our online communities and membership groups |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To continuously improve our content and features, as well as develop new ideas that we think our customers will like |
| 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 |
Name
Date of birth Email address Home or delivery address Company/organisation name Job title Job function Billing address Bank account and payment card details Subscription details Details of interactions with other users’ comments Marketing preferences you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | 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. |
How we obtain your personal information
We collect your personal information directly from you when you register for an account on our online
community. Where an organisation (such as your employer) has registered for an online account and you have
been approved as a user of the account, we may collect your personal information from them.
We may also collect personal information that you include in comments you make online. We also
analyse how you interact with us, for example when you visit one of our websites or contact us about
something and how you interact with other users in the online community.
We may obtain your personal information from third parties you use to access our websites (e.g. Facebook),
but only the limited information you allow them to share with us.
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 facilitate your membership. For example, if you don’t give us your email
address, you wont be able to register for an account on one of our online communities or membership groups.
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 a service provider of a customer relationship
management tool, 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.
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.
If you listen to one of our radio stations
We process your personal information when you listen to our radio stations online, register for an online
account, contact us or make a purchase, 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 content through our websites or your
online account; - we have a good business justification to use your personal information, which we think is reasonable and
treats you fairly (for example, to manage our interaction with you as a listener, or to record your calls
to us for training and monitoring 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, should a
regulator ask us to contact our audience).
| Reason for processing your personal information | Your personal information | Legal ground(s) for processing | Our legitimate interest (where applicable) |
| To register and operate your online account | Name
Email address Home address Phone number(s) Date of birth Gender Employment status Login details for your online account Listening preferences you’ve indicated to us Marketing preferences you’ve indicated to us |
Necessary to perform the contract between us | |
| To facilitate your entry into a competition we’re running
To provide you with your competition prize if you’re successful |
Name
Date of birth Home address Email address Phone number(s) Login details for your online account Reasons for you taking part in the competition (if provided), including your competition entry |
Necessary to perform the contract between us
Consent where the particular competition requires it |
|
| To enable you or someone you nominate to take part in our radio shows or features (for example, phone-ins, interviews or pranks) |
Name
Email address Phone number(s) Details of the person you’ve nominated Reasons for you and/or the person you’ve nominated taking part in the show or feature Additional personal information we may request from you that is relevant to your taking part in |
Necessary to perform the contract between us
Consent where the particular show or feature requires it |
|
| 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 when we may show you our marketing (for example adverts) on other platforms such as Facebook |
Name
Email address Home address Phone number(s) Marketing preferences you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests
Consent |
To promote our products and services
To send direct marketing communications, make these more relevant to you where possible, and To remain engaged with you and to bring you additional benefits where possible |
| To process your order including sending you (or the nominated recipient) the item you’ve purchased |
Name
Email address Home address Phone number(s) Purchase details and order history Nominated recipient details Gift message (if applicable) |
Necessary to perform the contract between us | |
| To process your payments and collect and recover money owed to us | Name
Email address Billing address Bank account and payment card details If you use a payment service (for example PayPal) we collect the limited information they share Purchase details and order history |
Necessary to perform the contract between us
Necessary for our legitimate interests |
To recover debts owed to us
To provide you with order documentation such as order confirmation |
| 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; and confirming when you have completed a particular activity (for example when you have changed |
Name
Email address Home address Phone number(s) Purchase details and order history Login details for your online account Marketing preferences you’ve indicated to us |
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 Necessary for our legitimate interests |
To keep our records updated and to learn how our listeners use our services
To provide a good level of customer service and deal promptly with your questions, comments or |
| To help us analyse and improve the technical functionality, security and performance of our websites |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To ensure our websites operate to the high standards you expect |
| To help us improve the quality and variety of the content and features we provide through our websites and online accounts |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To continuously improve our content and features, as well as develop new ideas that we think our listeners will like |
| To help us build an understanding of our listeners, whether as individuals or as larger groups, so we can identify listeners who may have similar interests, preferences and characteristics |
Name
Email address Home address Phone number(s) Date of birth Gender Employment status Purchase details and order history Login details for your online account Listening preferences you’ve indicated to us Marketing preferences you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To understand the differing needs of different groups of listeners, so we can tailor our products and services accordingly. For example, we would like to offer you content based on what we think similar listeners are interested in. |
How we obtain your personal information
We collect your personal information directly from you when you contact us, make a purchase and/or register
for an online account. Sometimes we get your details from a friend or relative if they’ve nominated you to
take part in a feature we’re running or placed a request for you. We also analyse how you interact with us,
for example when you visit one of our websites or contact us about something.
We may obtain your personal information from third parties who have referred you to us and who have your
consent to transfer your personal data to us.
Where we need your personal information to enter into or perform a contract with you then if you don’t
provide it, we won’t be able to process your order or register your account. For example, if you don’t give
us a delivery address if you win a physical competition prize, we won’t be able to deliver the prize.
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, third party sales processor (includes fulfilment services), service 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. - Providers of competition prizes: Where you’re the winner of a competition prize, we may share
your personal details with the provider of the prize to allow delivery, or where you have specifically
agreed that we can do so.
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.
If you participate in one of our competitions
We process your personal information when you participate in one of our competitions (whether in one of our
publications or online), 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 facilitate the competition and provide prizes; or
- 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)
| Reason for processing your personal information | Your personal information | Legal ground(s) for processing | Our legitimate interest (where applicable) |
| To facilitate your entry into a competition we’re running
To provide you with your competition prize if you’re successful |
Name
Date of birth Home address Email address Phone number(s) Login details for your online account Reasons for you taking part in the competition (if provided), including your competition entry |
Necessary to perform the contract between us
Consent where the particular competition requires it |
|
| 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 when we may show you our marketing (for example adverts) on other platforms such as Facebook |
Name
Email address Marketing preferences you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests
Consent |
To promote our products and services
To send direct marketing communications, make these more relevant to you where possible, and To remain engaged with you and to bring you additional benefits where possible |
| 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; and confirming when you have completed a particular activity (for example when your competition entry |
Name
Email address Display name Login details for your online account Marketing preferences you’ve indicated to us |
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 Necessary for our legitimate interests |
To keep our records updated and to learn how our customers use our services
To provide a good level of customer service and dealing promptly with your questions, comments or |
| To help us analyse and improve the technical functionality, security and performance of our websites
|
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To ensure our websites operate to the high standards you expect |
| To help us improve the quality and variety of the content and features we provide through our publications and websites |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To continuously improve our content and features, as well as develop new ideas that we think our customers will like |
| 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 |
Name
Date of birth Home address Email address Phone number(s) Reasons for you taking part in the competition (if provided), including your competition entry Marketing preferences you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | 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 |
How we obtain your personal information
We collect your personal information directly from you when you enter a competition. Sometimes we get
your details from a friend or relative if they have submitted an entry on your behalf. We also analyse
how you interact with us, for example when you visit one of our websites or contact us about something.
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 facilitate your entry to a competition. For example, if you don’t give us
a contact email address or phone number, we won’t be able to contact you if you’re a competition winner.
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 third parties who provide a prize for a
competition (to allow delivery), providers that host our technical infrastructure and those that assist us
with hosting and/or delivering our marketing campaigns. - Third-party brands: Where you have consented to us doing so, we may share your personal
information with a third-party brand in order for them to send you marketing communications about goods or
services that you might be interested in. - 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. - Advertising Standards Agency (ASA), regulators and other authorities: We may share your personal
information with the ASA and other regulators or authorities in the UK where required to do so by law.
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.
If you sign up for one of our events
We process your personal information when you sign up to attend an event, 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 deliver the event;
- 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, to
contact you to advise you of a change to the event venue due to health and safety regulations).
| Reason for processing your personal information | Your personal information | Legal ground(s) for processing | Our legitimate interest (where applicable) |
| To facilitate your event booking and to send you a copy of your ticket and event information either by post or email |
Name
Email address Home or delivery address Phone number(s) Company/organisation name Job title |
Necessary to perform the contract between us
|
|
| To organise and deliver the event and to cater for all our event guests | Name
Date of birth Dietary requirements including allergy information Special access requirements Emergency contact details Additional details of your company/ organisation, where needed for the specific event |
Necessary to perform the contract between us | |
| To process your payments (including recurring payments) and collect and recover money owed to us |
Name
Email address Billing address Phone number(s) Bank account or payment card details Purchase details VAT number Company/ organisation name |
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 |
To recover debts owed to us
To provide you with order documentation such as order confirmation
|
| To send you marketing communications with our suggestions and recommendations about events that may be of interest to you |
Name
Email address Purchase details Marketing preferences you’ve indicated to us |
Necessary for our legitimate interests
Consent |
To promote our products and services
To send direct marketing communications, make these more relevant to you where possible, and |
| 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; and confirming when you have completed a particular activity (for example when you have changed |
Name
Email address Home or delivery address Phone number(s) Purchase details Marketing preferences you’ve indicated to us Payment information |
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 Necessary for our legitimate interests |
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 |
| To help us analyse and improve the technical functionality, security and performance of our websites |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To ensure our websites operate to the high standards you expect |
| To help us improve the quality and variety of the content and features we provide through our websites |
I.P. address and other device identifiers
Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | To continuously improve our content and features, as well as developing new ideas that we think our customers will like |
| 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 |
Name
Date of birth Email address Home or delivery address Phone number(s) Company/organisation name Job title Purchase details Marketing preferences you’ve indicated to us I.P. address and other device identifiers Information you provide when you visit our websites (e.g. a record of the pages you visit) and |
Necessary for our legitimate interests | 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. |
How we obtain your personal information
We collect your personal information directly from you when you book an event. Sometimes we get your
details from a friend, relative, your employer or another third party if someone else is making a booking
for the event 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.
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 event booking. For example, if you don’t provide us with an
email address, we will not be able to send an e-ticket for the event to you.
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, providers of card
validation services, third party ticket sales processors and those service providers who assist us with
hosting our events (for example, the venue and catering team). - 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.
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.
If you place an advert or notice in one of our publications
We process your personal information when you place a notice with us (such as a birth, death or marriage
announcement) or pay us to advertise for you across any of our publications, websites or radio stations, 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 the notice or advertising you have requested;
- we have a good business justification to use your personal information, which we think is reasonable and
treats you fairly (for example, if you represent a business customer that has previously advertised with
us, we may contact you to ask if you would like to re-advertise). 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, to
update you about how we use your personal information under data protection laws.
| Reason for processing your personal information | Your personal information | Legal ground(s) for processing | Our legitimate interest (where applicable) |
| To discuss, design and agree your notice or advertisement | Name
Email address Home or business address Billing address Phone number(s) Title Company/ organisation name Job title |
Necessary to perform the contract between us | |
| To process your payments (including recurring payments) and collect and recover money owed to us |
Name
Email address Billing address Phone number(s) Bank account or payment card details Company/ organisation name Job title VAT number |
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 |
To recover debts owed to us
To provide you with order documentation such as order confirmation
|
| To manage our relationship with you including:
notifying you about changes to our terms or privacy policy; contacting you about your notice or advertisement (e.g. to update you about how an advertising inviting you to place another notice (e.g. on the anniversary of an event) or to re-advertise; dealing with any queries, requests or issues you have |
Name
Email address Home or business address Phone number(s) Title Company/ organisation name Job title Marketing preferences you’ve indicated to us Purchase details and order history |
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 Necessary for our legitimate interests |
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 |
| To help us improve the quality and variety of the services we provide | Home or business address
Company/ organisation name Job title Purchase details and order history |
Necessary for our legitimate interests | To continuously improve our services, as well as develop new ideas that we think our customers will like |
| 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 |
Name
Email address Home or business address Billing address Phone number(s) Title Company/ organisation name Job title Marketing preferences you’ve indicated to us Purchase details and order history |
Necessary for our legitimate interests | 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 advertising options based on what we think similar customers are interested in. |
How we obtain your personal information
We collect your personal information directly from you when you contact us with an enquiry, to place a
notice or to buy advertising.
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 provide the services you want. For example, if you don’t give us your
email address, we will not be able to send you information about how your advertisement is performing.
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, providers that host our
technical infrastructure and those who assist us with hosting and/or delivering your advertising
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.
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.
Sharing your personal information within DC Thomson
However you interact with us, we use your personal information across our companies, brands and departments
in order to:
- provide you with the products or services that you’ve requested
- develop new products or services and improve our existing ones
- help us to better understand our relationship with you, your preferences and the different parts of DC
Thomson that you interact with - anticipate what products and services you and other customers might be interested in
- ensure that your personal information is accurate and up to date
We won’t send you marketing from other DC Thomson companies or brands unless you’ve indicated that you are
happy to receive it.
How long we keep your personal information
We only keep your personal information for as long as
reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying
any legal, regulatory, tax, accounting or reporting requirements. We may keep it for a longer period in the
event of a complaint or if we reasonably believe there’s a prospect of litigation in respect to our
relationship with you.
If you’d like more information on how long we keep your
personal information, please contact us – see the ‘How to contact us’ section below.
Your marketing preferences
You can change your marketing preferences at any time and how
you do this will depend on how you interact with us (for example, whether you subscribe to one of our
newspapers or have bought something from one of our online shops).
You can opt out of marketing whenever you wish, but please note
this won’t affect any service messages that we need to send you in relation to any products or services you
purchase or events you attend. For example, we’ll still send you communications with information about an
event that you’ve registered to attend or to tell you about a change in the price of your magazine
subscription.
We won’t share your personal information with anyone else for
marketing purposes unless you’ve told us you agree to that.
Sending your personal information outside of the UK
We may transfer your personal information within DC Thomson and/or to third parties – see Sharing your
personal information with third parties – which may involve your personal information being
transferred to, stored, or processed in a country other than the one in which it was collected.
If we do so, we’ll comply with applicable law regarding such transfers. Where such transfers require
appropriate or suitable safeguards recognised under privacy laws, we may rely on them. Typically, these may
include:
- Adequacy decision: We may transfer your personal information to countries which the
Information Commissioner’s Office has approved as providing adequate protection to personal information
(for example, the European Economic Area). - Approved contracts: We may be entitled to put in place a contract with the recipient of
your information which requires them to protect that information to the same standards as if the
information were being processed within the country where it was collected. - With your consent: In respect of certain transfers, we’ll obtain your consent to
transfer your personal information outside the UK after first informing you about the possible risks of
such a transfer
The safeguards we use will depend on where the recipient of the personal information is based, what they
are doing, and the personal information being transferred.
You can request more information by contacting us.
Your rights
Under data protection law, you have the following rights:
- A right to receive a copy of the personal information we hold about you and information about how we use
it - The right to update any of the personal information we hold about you if it is no longer correct
- The right to require us to delete or remove your personal information
- The right to require us to stop processing some of your personal information for a particular reason
- The right to withdraw any consent you have provided
- The right, in certain circumstances, to require us to transfer your personal information to another
company
These rights are qualified. This means that depending on what you ask us to do, we may not be able to
comply with your request. If that is the case, we’ll explain why.
Before we can act, we may also ask you to confirm your identity so we can be sure we’re speaking to the
right person. We won’t usually ask you to pay any money to exercise any of these rights, but we’ll tell you
at the time if a fee will apply.
How to contact us
If you want to exercise any of your rights, change any of your choices about how we use your personal
information or just ask us a question, please email us at [email protected].
If you’re unhappy about how we’ve handled your personal information, you can make a complaint to the
Information Commissioner’s Office. Information on how to do this is available at www.ico.org.uk/make-a-complaint but we would appreciate the chance to deal with your
concerns first.
Updates to this notice
We keep this policy under regular review to make sure it is still accurate. This policy was last updated on
30 September 2023