Introduction & General Terms
This document (“Privacy Policy”), in combination with the Cookies Policy and Competition rules make up our commitment to protecting personal information we hold about our customers, prospective customers, newsletter subscribers, competition entrants, website users or any other data subject whose personal information we hold. Personal information as outlined in this policy is being processed by Project GTO Publishing LLP (“we”, “our”, “us”). You can find out more about us by visiting www.gtopublishing.com. In the event of any part of Project GTO Publishing LLP either being sold or going into receivership, we reserve the right to continue to share your data to third parties in accordance with the latest preferences you have provided. You will be informed should any change of ownership occur, and the new owner will manage your personal information preferences.
Our Commitment to you
We are committed to managing & safeguarding your personal information in accordance with current legislation and best practice. Our aim is to be responsible, relevant and secure when using your data. Whenever you provide personal information we will treat that information in accordance with this Privacy Policy. We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our ‘Legitimate Interests’. We endeavour at all times to keep your data accurate and secure, and to honour your data preferences with regard to receipt of direct marketing e.g. postal communications, email, mobile messaging and telephone calls.
We operate websites that may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, and are also likely to use cookies, and we therefore urge you to review them. They will govern the use of personal information you submit when visiting these websites, which may also be collected by cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
Your personal data will not be disclosed to state institutions and authorities except if required by law or other regulation. Before we release data on this basis, we will ensure that the information is being provided to a genuine and properly authorised investigation.
We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to email all of our registered users to make sure that they are informed of such changes. However, it is your responsibility to check this Privacy Policy before each use of the Website.
What Data we collect
When you send us information, talk to us over the phone, submit an online form or when you visit one of our websites, we may collect both personal and pseudonymous data about you.
Data we collect through your use of our website
When we talk about personal data we mean any information that can identify you as an individual, such as your name and postal address. Pseudonymous data doesn’t identify you as a person but it might be used in aggregate, for instance when you participate in a survey or when we analyse audience interaction with our products and services.
Data you provide to us
When you participate in, access, purchase or sign up to any of our services, activities or online content, such as magazine subscriptions, newsletters, competitions or events, we receive personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, as well as information collected about your use of our services (such as when you enter our sites and how long you stay on them).
Children’s’ Data
If you are the parent or guardian of a child under 13 (“Child” or “Children”), and have provided us with information belonging to a Child, then alongside the Child’s data provided, we may also process limited personal data about you, so we can record your consent to store, process and use this information about the Child to fulfil the service you have purchased or signed up to on their behalf. We may use your contact details to communicate with you about the Child’s use of these products or services. We will never knowingly send marketing communications to a Child under the age of 13. If you believe we have collected personal information about your Child without your consent, you may contact us at contact@gtopublishing.com and request that we remove information about your Child.
Data we buy from a third party
We occasionally purchase data from third party suppliers. The data we purchase is primarily business data. Business data may include but not be limited to a business email address, business job title and business postal address. Such a purchase may result in you receiving communications from Project GTO Publishing LLP regarding your business sector or business interests without you having directly supplied your information to us. We keep clear records of the data suppliers and provide an unsubscribe option at every contact. If you have any queries concerning the use of business data we hold about you please email contact@gtopublishing.com
Data we collect through your use of our websites
We may collect information about how you use our websites or other content online, and the device(s) you use to access the services. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network device on the internet. Anonymous data will be recorded for the purpose of reporting web traffic statistics, advertisement ‘click-throughs’, and/or other activities on our sites. We may receive information about you from any third parties we may partner with through the use of cookie technologies to personalise advertisements for goods and services. For detailed information on Cookies we use please see Cookies and how we use them as well as our Cookie Policy.
How we use your data
We may use the information you share with us and the information we collect through your use of our sites in the ways described below and as described at the time of capture.
Competitions & Prize Draws
We will use the details you have shared to manage your entry to any competition or prize draw. This may include your name, e-mail address and telephone number. We shall use such information to notify you if you are the winner. Your data will be retained for the period of the competition only, and will not be added to any marketing lists unless you have consented to this, and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of your prize.
Newsletters
We will use the details you have shared to send you the newsletter to which you have subscribed. We will not add them to any marketing lists, unless you have consented to this. We will provide a way for you to unsubscribe on every newsletter we send to you. Details you share with us for the purpose of newsletter subscription will never be shared with a third party.
Events
We will use the details you have shared to manage your registration and entry into our event. This may include contact via telephone, email, SMS and post with information relating to the event you have registered to attend. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of the event.
Magazine Subscription
We will use the details you have shared to manage your subscription to our magazine, which includes sending the magazine, managing access to any digital version, taking secure payments, to fulfil any gift that was offered at the time of purchase, to handle any customer query you may have and to contact you via telephone, email, SMS and post with information relating to your magazine subscription. e.g. to notify you of the expiry date of your subscription, that a delivery to you may be delayed or to remind you of a password or to notify you of updates to our Privacy Policy, Cookies Policies or Terms of Use. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with third parties where we have appointed them to manage specific aspects of your magazine subscription.
Customer Services
We will use the information you provide to deliver customer services related to your purchase and to respond to inquiries or requests that you direct to us. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with third parties where we have appointed them to manage specific aspects of your customer care.
Research
We may use the information you provide to invite you to participate in surveys and focus groups about our products, advertisers and services. Participation is always voluntary and the answers you provide are anonymous and aggregated to support our learnings and inform changes we can make to improve our products and services. Your data will not be added to any marketing lists unless you have consented to this and were informed at the point of capture and will only be shared with third parties where we have appointed them to manage research activity on our behalf.
Occasionally we get paid by commercial partners to carry out research on their behalf. In this situation, the data we share with them will be anonymous however we may share your personal data with specific commercial partners where they were named at point of capture and where you agreed to the sharing of your personal data with them.
Direct Marketing
We may use the details you share with us to send you offers and promotions by email, post, telephone or SMS wherever we have legitimate interest grounds to do so and where you have not objected. We will provide a way for you to opt-out of receiving marketing promotions both at the time of data capture and everytime we contact you thereafter. You can also email contact@gtopublishing.com to request your details are suppressed from all promotional campaigns. We won’t use your personal data for marketing purposes at all if you’ve told us not to.
Legitimate Interest
We may process your personal data on the basis of a legitimate interest after carefully considering the balance between your rights and the benefit of the purpose for which we intend to use your personal data. These legitimate interests may include: –
Promoting similar products or services, via direct marketing activity, that we have identified may be of interest to you based on your history of interaction with us and where you have not opted out of receiving such information.
To manage suppression and unsubscribe requests received from you.
To invite you to participate in research surveys about our products or services to help us improve these.
For statistical and data analytics so we can improve the products and services offered to you.
To personalise and improve our services to you by using insight regarding your purchase or communication history with us.
To identify and prevent fraudulent behaviour.
Using your data to help find similar audiences through the use of Facebook’s audience function and Google customer match
Identifying usage trends and determining the effectiveness of our campaigns to improve targeted advertising.
Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights.
Cookies and how we use them
“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We use cookies for a number of reasons:
Strictly Necessary Cookies – These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information
Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Functional Cookies – These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting Cookies – These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media Cookies – These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
Analytics
The GTO Publishing portfolio of websites uses Google Analytics as its primary solution for tracking website visits, interactions and events. GTO uses website analytics data to help improve the way we delivery content and online experiences to visitors.
For full details on how Google processes your data please visit: https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008
Online Advertising
Many of the Project GTO Publishing LLP portfolio of websites show advertising to users. A certain amount of this advertising is tailored to the individual user, as practice known as “Online Behavioural Advertising” which uses cookies to discover general information about the pages you visit. This keeps many of our websites and services you use free of charge. Our advertising delivery systems and partners uses the limited information available to it to serve adverts to you, which it believes are relevant. It does not collect personal information such as your name, email address postal address or telephone number.
From time to time, Project GTO Publishing LLP may share this aggregated data with our advertising partners. This could mean that when you are on other websites you are served advertising based on your behaviour across GTO titles or you may be served advertising based on your behaviour on other sites.
Behavioural retargeting is another form of Online Behavioural Advertising that enables us and some of our advertising partners to show you adverts based on browsing patterns and interactions with the site away from our sites. For example, if you have visited the website of a car dealership you may start seeing adverts from that same dealership site displaying special offers or showing you the products that you were browsing. This allows companies to advertise to website visitors who leave their website without making a purchase.
Links to third party websites
When you click on advertisements or links on any of our sites, you will leave that site and go to a third-party site, which is outside of our control. When we place an advertisement on one of our sites, it does not signify that we are endorsing that advertiser’s product or service. We do not accept responsibility for content, have no control over and our Privacy Policy does not apply to these companies, sites or content and if such third-party sites collect personal data, we cannot control how this data is processed, stored or used. We advise that you read their data collection statements, which accompany any registration and their Privacy Policies before you submit your personal information
How we keep your personal data secure
Project GTO Publishing LLP’s security policies, rules and technical measures have been implemented to protect your personal information from unauthorised or improper use and from accidental loss.
All our employees and data processors that have access to, and are associated with, the processing of your personal information are legally obliged to respect the confidentiality of your data and are bound by contract to do so.
Note that some of our websites provide forums and commenting facilities where you can post information. When you do so, be aware that other visitors may collect any information you make public.
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.
We may also have to share your personal data with third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
How long we keep your personal data for
We will hold your personal information on our systems only for as long as required to provide you with the products and/or services you have requested.
Where you sign up to receive email marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving emails in order to ensure that we continue to honour and respect that request. To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If we decide to change our Privacy Notice we will post these changes on this page so that you are always aware of what information we collect, how we use it and in what circumstances we disclose it.
Cookie policy
What are cookies?
Cookies are small text files which a website may put on your computer or mobile device when you visit a site or page. The cookie will help the website, or another website, to recognise your device the next time you visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way.
Cookies serve many functions. For example, they can help us to remember your username and preferences, analyse how well our website is performing, or even allow us to recommend content we believe will be most relevant to you.
Certain cookies may record personal information – for example, if you click “Remember me” when logging in, a cookie will store your username. Most cookies won’t collect information that identifies you personally, and will instead allow us to collect more general information such as how users arrive at and use our websites.
Types of Cookies and how they are set
There are two types of cookies:
Session Cookies – Stored temporarily in your computer’s memory while you are visiting a website and are deleted when you close your browser.
Persistent Cookies – Stored for a set period on your computer and used to determine whether there has been any contact between us and your computer in the past.
There are two ways cookies set can be on our websites:
1st Party Cookies – cookies that are set by the website domain (or belonging to a sub domain) of the website.
3rd Party Cookies – cookies that are set by another website domain. (e.g. by one of our main technology partners or by an external web services)
What sort of cookies does GTO Publishing use?
Strictly Necessary Cookies – These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information
Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous.
Functional Cookies – These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages.
Targeting Cookies – These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device.
Social Media Cookies – These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit.
Does anyone else use cookies on the Project GTO Publishing LLP websites?
Advertisers sometimes use their own cookies to provide you with targeted advertising. For example, advertisers may use a visitor profile they have built on sites that you have previously visited to present you with more relevant advertisements during your visit to a GTO Publishing website. We believe that it is useful to our users to see advertisements that are more relevant to their interests. We also use or allow third parties to serve cookies that fall into the four categories above. For example, like many companies, we use Google Analytics to help us monitor our website traffic. We may also use third party cookies to help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions and copyright policy.
If you click on a hyperlink from a Project GTO Publishing LLP websites to any third party websites (e.g. if you ‘share’ content from GTO websites with friends or colleagues through social networks), you may be sent cookies from these third party websites. Third party websites have their own privacy and cookie policies which GTO cannot control. Please check the third-party websites for more information about their cookies and how to manage them.
Do we track whether users open our emails?
Our emails may contain a single, campaign-unique “web beacon pixel” to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users, to query whether users who do not open our emails wish to continue receiving them and to inform our advertisers in aggregate how many users have clicked on their advertisements. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should select to receive emails from us in plain text rather than HTML.