This document outlines our approach to compliance with the General Data Protection Regulation (GDPR) and all other relevant data-protection legislation. It also sets forth your privacy rights. Please take a moment to familiarise yourself with our privacy practices.
Who is The College Tribune and how are we contacted?
Data protection officer
1. Information we collect and how we use it
To deliver marketing, promotions and to conduct research
For competition and promotional purposes
We occasionally may 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 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.
To participate in a survey or poll
We conduct surveys and polls that we use to produce original research from our readers. Your participation is entirely voluntary. You may consent to The College Tribune contacting you at the email address provided to participate in this research. We do not track individuals but look at the information in the aggregate. Any opinion you express, therefore, is anonymous.
From time to time, upon completing a survey or poll, we may ask for your email address for competition, promotional or gifting purposes. Participation is entirely voluntary and this information is processed and stored separately from the information you provide us for the survey or poll. Where you provide this information to us, it will be processed only to administer the competition or promotion.
To deliver our content to you
To share our content
We provide tools that enable users of our services to share or forward our content to a nominated email address. If someone else shares our content with you, we may temporarily collect your email address for the purpose of sharing the requested content. We will only use this information to fulfil the sharing request and this contact information is not retained by us. By providing us with your email address, the third party that initiates the sharing request indicates they have your consent to share our content with you.
To recommend content
We may use aggregate information we collect about you to suggest and recommend tailored content. By understanding which content you find useful or interesting, we can recommend more content that you might also like, as well as continuing to produce the most valuable content to meet your needs. This processing is necessary for the purpose of our legitimate interest in delivering relevant content to our readers. You have the right to object to this processing, and if you wish to do so please contact us at firstname.lastname@example.org.
To understand how you use our services
To track how you gain access to or read our content
We collect information relating to your use of our services to track how you gain access to or read our content. We use log-in information, cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services as follows:
- 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 and any phone number used to call our customer service number
- 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
- Details of our mobile applications used including but not limited to: traffic data; location data; weblogs; and other communication data and the resources accessed
- Some of our location-enabled services require your personal GPS location data for the feature to work. If you wish to use a particular feature, you will be asked to specifically consent to your data being used for this purpose. This consent can by withdrawn at any time.
To measure the effectiveness of our email communications
We use such technologies to determine whether you’ve opened an email communication from us or clicked on a link contained in an email. Collecting information in this manner allows us to gather statistics about the usage and effectiveness of our services and products, including our email newsletters and direct marketing communications, in our legitimate interest.
To support our advertising services
Third-party vendors, including Google, display advertising on our Services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site. This type of 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.
The third-party vendors (such as advertising networks) use third-party cookies together to inform, optimise and serve ads based on your browsing activities and interests. When you visit our Site, your browser redirects to the third party vendor and information is transmitted from from your browser to this third party vendor. Any information transmitted to advertisers and advertising networks in this manner is non-personally identifiable.
To deliver recruitment services to you
To apply to write for us
If you apply to write for The College Tribune, you may provide us with certain personal information about yourself. We will use this information for the purpose of processing and responding to your application, to assess your suitability as a potential candidate and for current and future career opportunities.
To correspond with you
If you correspond with us, we will use your contact information to respond to your enquiry. We process this information in pursuit of our legitimate interests to develop and maintain relationships with our customers and readers.
To manage our everyday business needs
We may use your personal information to manage our every business needs, including for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention in our legitimate interest. Our legitimate interest is the effective management of our business.
To verify your identity
To exercise your data rights, we may need to collect additional personal information from you to verify your identify and to process your request.
When you provide professional services to us
You may provide us with your personal information if you provide professional services to us. We process this information so we can administer, manage and pay for the relevant services you provide and as per the terms and conditions of our contract.
2. Anonymous information we process
We use app push notifications to inform you about breaking news, live event coverage and other top stories. We do not process any personal information and cannot establish the identity of the users who have subscribed to receive these notifications. We may occasionally use push notifications to send you marketing material which may be of interest to you. You may receive these notifications based on your location, operating device and/or interests that are derived from your use of our Services. You can control your push notification and location settings directly on your mobile device. It should be noted that iOS devices operate on the basis of opting-in to push notifications whereas Android devices operate on the basis of opting out.
3. The legal basis for processing your information
We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.
To enter into and perform a contract with you
We use your personal information to carry out our obligations arising from any contracts entered into between you and us or to take the necessary steps at your request prior to entering into a contract with us including:
- To provide you with any subscription, services or products you may have requested
- To process payment information should there be any orders or payments you initiate
- To provide customer and technical support
- To administer competitions or similar promotions
- To process live chat information at your request
- To provide any recruitment services to you when requested
- To pay for the services you may professionally provide to us
- To send important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service
With your consent, which can be withdrawn at any time
We will, in certain circumstances, rely on your explicit consent to process your personal information. Where we do, you have the right to withdraw your consent at any time. In order to withdraw your consent, you can contact us at email@example.com and we will be happy to facilitate your request.
To comply with our legal obligations
We may be required to process your personal information to comply with certain legal obligations to which we are subject, including:
- Providing information to an Garda Síochána, the Revenue Commissioners or other Government bodies or agencies when required to do so by law
- If you have exercised one of your data rights, we will retain a copy of all correspondence to demonstrate our compliance with data-protection legislation
- If you have exercised one of your data rights and ask us not to contact you by email at a particular email address, we will need to retain a copy of that email address in order to comply with your no-contact request
Processing based on our legitimate interests
We process your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. Our legitimate business interests do not automatically override your interests. You have the right, free of charge, to object to our use of your personal information for our legitimate interests. If you wish to do so, contact us at firstname.lastname@example.org. Please bear in mind that if you do object, this may affect our ability to carry out certain tasks for your benefit.
Where you object to our use of your personal information for our legitimate interests, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so. We will always ensure there is a fair balance between our legitimate interests and your fundamental right and freedoms.
We process personal information for the following legitimate business purposes:
- To manage our everyday business needs and for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention
- To provide you with a more personalised experience, such as making content recommendations
- To help in understanding which content you find useful or interesting
- To support our advertising services
- To determine the effectiveness of promotional campaigns, email campaigns and advertising
- To research and improve The College Tribune’s products, services, and customer communications
- To ensure content from our site and mobile applications is presented in the most effective manner for you and for your device
- To develop and maintain relationships with our customers and readers
- To better understand and improve the usability, performance, and effectiveness of our Services
- To protect you against fraud and to detect, prevent, investigate security or technical issues to ensure our Services are secure
- To protect the rights, property and safety of The College Tribune or the rights, property or safety of our employees or others
- To understand the demographics of our customers and readers
4. When and how your information is shared
Within our organisation
With third parties
We may share your personal information with third parties for a number of reasons as outlined below. We do not sell your personal information to anyone and only share it with third parties who are facilitating the delivery or fulfilment of our services and or are working on our behalf. We contractually require that our suppliers protect such information from unauthorised access, use, and disclosure.
Third-party service providers
We may share your personal information with third-party service providers which perform services and functions at our direction and on our behalf such as accountants, IT service providers, App developers, printers, payment providers, lawyers, providers of security and administration services and other business advisers.
Third-party service partners
We may provide certain services and run promotions in conjunction with third parties and we may share your personal information if the service you have requested is fulfilled by them. These third parties have their own security and privacy policies. You are advised to review these separately.
We disclose non-personally identifiable anonymous information to third-party advertisers to help them reach the kind of audience they want to target. We share summary aggregate reports for our advertisers to measure the effectiveness of the ads they have served. These advertising parties may combine the information we send with other information that you’ve provided to them or that they’ve collected from your use of their services.
We may share your personal data with a third-party auditing organisation in accordance with our legitimate interests to verify aggregated statistics about circulation and usage of our products or to review our policies, processes and procedures for compliance with relevant standards.
Social networking sites
5. Data storage and retention
We will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information no longer than is necessary to comply with our business and legal obligations. Where we enter into a legal contract with you, we will hold your personal information for a period of seven years from the date of completion of this contract by reference to the statute of limitation for a legal claim under contract.
6. International transfers
We encounter a need transfer personal data outside the European Economic Area (EEA). These countries do not always afford an equivalent level of privacy protection and in such circumstances we take specific steps, in accordance with data protection law to protect your personal information. In particular, for transfers of personal data outside the EEA we rely either on an adequacy decision by the European Commission or on contractual protection approved by the European Commission.
7. Your data rights
You have several rights under data-protection law in relation to how we use your personal information. You have the right, free of charge, to:
- Request a copy of the personal information we hold about you in a structured, commonly used and machine readable format
- Rectify any inaccurate personal information we hold about you
- Withdraw your consent where we have relied upon your consent to process your information
- Erase the personal information we hold about you subject to certain exceptions
- If technically feasible, have your personal information transmitted to another data controller in a machine readable format at your request
- Restrict processing of your personal information in certain circumstances
- Object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes
- Not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature
- Lodge a complaint with the appropriate data-protection authority if you have concerns about how we process your personal data
These rights are in some circumstances limited by data-protection legislation. If you wish to exercise any of these rights please contact us at email@example.com. We will take measures to verify your identify which we will do by reference to copies of acceptable identification documentation supplied by you.
We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.
8. Consequences of not providing information
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
9. Processing for journalistic purposes
As a news publishing organisation, The College Tribune 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 journalistic 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 one of 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. This may mean that we have the right to deny a request to remove personal data for reasons of public importance and journalistic reportage.