1. Information About Us
CMNL Limited is registered in Ireland under Company Number 585944, Registered address:(Market Square, Navan, Co Meath (VAT number: IE3424944EH). We are publishers 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.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) The right not to 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.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11 and we will endeavour to respond to your request within a month. If we are unable to deal with your request within a 30 we may extend this period by a further two months and we will contact you to explain why.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Data Commissioner’s Office.
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 CMNL Limited, however 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.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this will vary according to your relationship with us). :
• Email address;
• Telephone number;
• Business name;
• Job title;
• Payment information;
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
a) ADVERTISER CONTRACT: To become an advertiser in one of our publications 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 of these services/products, 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. We retain your information for a period of no longer than 18 months after your relationship with us has ended unless we have a legal reason to retain it for a longer period.
b) SUBSCRIBER CONTRACT: To become a Subscriber to any of our Online publications or to purchase to one of our other online 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. 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.
c) To keep you informed of the benefits of our products and services
d) To develop and maintain relationships with our customers
e) For personalising and tailoring our services for you.
f) To implement customer-retention and win-back strategies
g) 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.
h) To deliver marketing and promotions and conduct research
i) 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 immediately after the closing date with exception of the winner(s) data which will be kept for a period of no longer than 30 days.
j) For Web/Online Subscribers- 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
k) For Web/Online Subscribers- To Deliver online content to you. We 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 instances we personalise the email we send. You can opt out at any time by unsubscribing at the bottom of each email newsletter
l) For Web/Online Subscribers- To understand how you use our services:
i. 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 email@example.com.
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.
ii. 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.
m) For Web/Online support to 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 behavioural 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.
n) To comply with our legal and regulatory obligations
We may be required to process your personal information to comply with certain legal obligations to which we are subject, including:
i. Providing information to an Garda Síochána, the Revenue Commissioners or other Government bodies or agencies when required to do so by law
ii. 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
iii. 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
iv. 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:
o 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
o To support our advertising services
o To develop and maintain relationships with our customers and readers
o To protect you against fraud and to detect, prevent, investigate security or technical issues to ensure our Services are secure
o To protect the rights, property and safety of CMG or the rights, property or safety of our employees or others
o To understand the demographics of our customers and readers
o To send direct marketing to our subscribers or former subscribers.
o) Other Purposes:
i. 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
ii. 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
iii. To verify your identity: To exercise your data rights, we may need to collect additional personal information from you to verify your identity and to process your request
iv. 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 in order that we can administer, manage and pay for the relevant service you provide and as per the terms and conditions of our contract.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
• Advertiser Personal Information; Name, Address, Contact name, phone number, email addresses, will be retained for up to 18 months post final transaction. Credit & Debit Card Details – will be destroyed immediately after use- please refer to Section 6g above.
• Digital Subscriber Personal Information; Name, Address, Contact name, phone number, email addresses, will be retained for up to 30 days post contract. Credit & Debit Card Details – will be destroyed immediately after use- please refer to Section 6g above
• Supplier Personal Information; Name, Name, Address, Contact name, phone number, email addresses, and banking details will be retained for up to 18 months post final transaction.
• Competition Applicants Personal Information; Name, Name, Address, Contact name, phone number, email addresses, will be retained as outlined in Section 6i above.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the Republic of Ireland. This means that it will be fully protected under the GDPR
9. Sharing of My Personal Data?
a) Internal Sharing: We may share your personal data within the Newspaper Titles of CMNL Limited.
b) Third Party Service Providers: We may also sometimes contract with parties to supply services to you on our behalf or facilitate operation of our contract with you. These services may include payment processing, credit vetting, legal and IT services. In some cases, those third parties may require access to some or all of your personal data that we hold. The following are a list of some of these suppliers and services supplied.
o Evalon Limited (ROI):- Credit Card processing services
o Vision Net Limited (ROI):- Credit Vetting services
o Evad IT Solutions Limited (ROI):- IT system services
o Larkin & Tynan Solicitors (ROI):- Litigation services
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. If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
c) Digital Service Services- 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.
d) Digital Services- Third-party Web advertisers
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.
e) Digital Services- Social networking sites
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will will respond to your subject access request within 30 Days. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of <<insert name>>)]:
Email address: email@example.com
Telephone number: 0449346700
Postal Address: Data Protection Liaison, CMNL Limited, c/o Westmeath Examiner, Blackhall place, Mullingar, Co Westmeath