Introduction
Welcome to the Pressdram Limited ('Private Eye') privacy policy. Private Eye respects your privacy and is committed to protecting your personal data and we want to be very clear and transparent with you about the way that we use your data and the types of information that you share with us. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you contact us or submit material for possible publication. It tells you about your privacy rights and how the law protects you. Private Eye is very serious about protecting your privacy and we will not, under any circumstances, sell data we collect about you through this website to anyone else. Private Eye is the UK's number one best-selling news and current affairs magazine. This policy has been created in order to show our commitment to our customers and readers. This policy describes our general practice and procedure for collecting, using and disclosing information about users.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Private Eye collects and processes your personal data through your use of this website or where you contact us by other means. This includes any data you may provide when you become a subscriber, purchase a product, take part in a competition, contact us, login to manage your subscription, submit an advertisement for our classifieds page, submit ideas or material for possible stories, or give us feedback. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide at any time so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
Controller
Private Eye is the controller and responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy policy). If you have any questions about this privacy policy, please contact us using the details set out below:
Contact details
Our full details are:
Pressdram Limited
Lynton House
7-12 Tavistock Square
London
WC1H 9LT
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance, we are always happy to assist with any data protection queries that you may have.
Changes to the privacy policy and your duty to inform us of changes
We may change this policy from time to time. Although we will strive to ensure that any such changes are small, and we will inform you and, if appropriate, seek your consent if we intend to materially change the way in which we use your data, we recommend that you consult this privacy policy regularly for updates.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Private Eye works closely with third parties, acting as processors, to manage our subscriptions and advertisements on our website.
When you place advertisements on the Private Eye website, you will be directed to a website operated by a third party. Private Eye is not responsible for the type of cookies deployed by this website. Private Eye recommends that users consult the cookies and privacy policies available at www.eyeads.co.uk if they have any questions about the tracking devices used by that website.
When you manage your subscription on the Private Eye website you will also be directed to a website operated by a third party. However that website does not use cookies except as laid out in our cookie policy at www.private-eye.co.uk/cookie-policy.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Submissions Data includes the personal data that you may provide us with and that we may gather in relation to any proposed article, or other journalistic activity, that results from your submission, regardless of whether such submissions are ultimately used by us or others.
We do not aim to collect any Special Categories of Personal Data about you via this website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we aim to collect via this website any information about criminal convictions and offences.
Where special category or criminal offence data is provided to us directly by you or collected from another source for the purposes of journalism we will ensure that we have an appropriate legal basis for processing or can rely on an appropriate exemption under data protection law.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Submissions, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase a product from us;
- subscribe to our publication;
- request marketing to be sent to you;
- submit an advertisement to our classifieds page;
- login to manage your subscription;
- enter a competition, promotion or survey;
- submit material for a possible story; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please refer to our cookies policy for more information. Click here to view our cookies policy.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources (please see below): Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Use of personal data by Private Eye
Private Eye may use and disclose collected information for the purposes below.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- To aggregate and analyse Collected Information.
- For researching, preparing and publishing material for the special purposes of journalism. It may be necessary to share submissions data internally or externally with third party correspondents for these special purposes.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Please note that we may rely on the exemption provided under the Data Protection Act 2018 (“the DPA”)for the special purposes of journalism, arts and literature where we process personal data (including any special category or criminal offence data) that you provide to us, or that we collect for those special purposes.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new Customer | (a) Identity
(b) Contact |
Performance of a contract with you |
| To process and deliver your order including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how Customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how Customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
| To deliver relevant website content to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how Customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, Customer relationships and experiences | (a) Technical
(b) Usage |
Necessary for our legitimate interests (to define types of Customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To investigate, produce and publish stories for journalistic purposes | (a) Identity (b) Contact (c) Submissions |
(a) Necessary for investigating and publishing journalistic material in the public interest (b) Necessary for our legitimate interests (to investigate, produce and publish journalistic material) (c) Under the “special purposes” exemption for journalistic material |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data for marketing purposes.
Opting out
You can ask us to stop sending you marketing communications at any time by contacting us at any time.
Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of service purchase, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
International transfers
We may need to share your personal data with external third parties from time to time. Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a "data subject access request".
- Request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You can also ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- Object to processing of your personal data: where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data: this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data: we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.)
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Where we are not able to determine with any degree of certainty whether the information requested by you relates exclusively to you, our disclosure of such information to you may pose a privacy risk to a third party (for example, where a cookie is associated with a device used by more than one person). We will assess each request to exercise any of the rights listed above individually on its merits and will disclose the requested information where we are satisfied that such disclosure does not represent a privacy risk to any third party.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Special Purposes
The General Data Protection Regulation (“GDPR”) and the DPA require us to use your personal data within the legal framework explained in this privacy policy and in accordance with your rights under the GDPR (which we explain above).
However, the GDPR and the DPA contain an exemption which allows us not to apply aspects of this legal framework and your rights if they are not compatible with the journalistic purposes for which data is processed and there is a public interest in publication. This exemption is known as the “Special Purposes” exemption. Consequently, please be aware that aspects of the legal framework explained in this privacy policy and your rights under the GDPR may not apply where they are not compatible with the Special Purposes.
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