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Privacy Policy

Effective from: 22nd May 2020

Overview

This website (iNotices.ie) is operated by Independent News & Media.

When visiting an Independent News and Media (INM) site or using one of our services, you are trusting us with your information. We know that this is a big responsibility and we work hard to protect your information and put you in control.

At INM we seek to maintain the privacy, accuracy, and confidentiality of all data (including your personal data) that we collect and use as part of our services.

We will use your personal data only for the purposes described below and in full compliance with the GDPR Data Protection Legislation.

The purpose of this privacy statement is to explain how INM, in our capacity as a data controller, collect and use your personal information.

As Ireland’s largest media company, INM reaches millions of people each week across print and online. INM is a group of companies that has a number of online sites and services including iNotices.ie, Independent.ie and BelfastTelegraph.co.uk. Information about the companies in our group can be found here.

This Privacy Statement applies to:

Other sites in the INM group such as Independent.ie and BelfastTelegraph.co.uk have their own privacy statement.

Site Function:

We use analytics providers in order for us to understand our audience, the content that appeals to them and how well our site is working. We also provide tools from the major social networks (Twitter, Facebook etc.) to allow you to share content from our site.

Delete My Account:

If you wish to delete your iNotices.ie account, please directly make your request by clicking the following link to our secure Data Subject Request Form. Alternatively, if you are having issues with our secure privacy portal, you can email data.protection@inmplc.com and request that your account is deleted. Please note that we may request id, in order to ensure the safety of your data.

Analytics

Analytics tools allow us to understand how our audience interacts with our site and our content and enables us to provide a better service to our site visitors. We do not collect or process any personal information in our analytics platform.

What we process:

  • Your IP address: in order to track your activity on our site we process your IP address
  • Anonymous data about your device: your operating system (e.g. iOS11), device type (e.g. tablet)
  • Anonymous aggregated demographics: for example your current city and other anonymous data.
  • Anonymous data about your browsing: stories you read, types of content consumed and browsing patterns.

Why we process this data:

The legal basis for processing this data is the legitimate interests of INM to manage and optimise the running of our site and its content.

This data helps us optimise the way the site is structured and how content is arranged on the site. It also allows us to show interested parties how many people access the different parts of our site and on average how often they visit. This allows understanding of how many people look at our content at different times of the day etc. These statistics are always calculated on an aggregated basis – never individually. We use the data for future marketing and personalised advertisement(https://support.google.com/analytics/answer/2700409?hl=en-GB&utm_id=ad).

Who has access:

Anonymised versions of the data are hosted on Google Analytics. At no point do we have access to personally identifiable information through Google Analytics. Anonymous aggregated reports about the general behaviour of our audience may be made available to the public or others.

Stop being tracked:

These analytics tools run on most sites across the web. If you wish to opt out of analytics tracking you must do so on these 3rd party sites or by changing your browser settings. Click on a link below to see the privacy policy and manage your consent across the web for each cookie type:

Further information can be found in our cookie policy.

Your Rights

Your Rights Under Data Protection Law

You have several rights under data-protection law in relation to the personal information that INM holds about you. If you choose to exercise any of these rights, we will ask you to verify your identity. We will consider your request and provide a response within one month. These rights are described in detail on the Data Commissioner’s Website and summarised below:

  • Right of Access: You are entitled to have access to your personal data which we hold (this is more commonly known as submitting a “data subject access request”). Typically, there is no fee for this, however, we have the right to apply a reasonable fee in exceptional circumstances.
  • Right of Portability: You can request a copy of the personal information we hold about you in a structured, commonly used and machine-readable format and if technically feasible, have your personal information transmitted to another data controller in a machine-readable format.
  • Right to rectify: If it is found that personal data is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate.
  • Right to withdraw consent: You have the right to withdraw your consent to any future processing for which you have previously given that consent.
  • Right to Erasure: Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”).
  • Right to Restriction: Restrict processing of your personal information in certain circumstances
  • Right to object to processing: You are entitled to object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes.
  • Rights relating to automated decision making including profiling: You are entitled to 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
  • Right to complain: You are entitled to lodge a complaint with the Data Protection Commissioner if you have concerns about how we process your personal data.

You can complain directly to the Office of the Data Protection Commissioner at Canal House, Station Road, Portarlington, Co. Laois by telephone at 1890 25 2231 and/or by email to info@dataprotection.ie.

You can also make a complaint directly to the relevant data protection authorities in the country where you are ordinarily resident. For example, in the UK you can also complain directly to the ICO at https://ico.org.uk/make-a-complaint/ or or call their helpline on 0303 123 1113.

How To Exercise Your Rights

Requests for information or to exercise these rights should be made directly via our secure privacy portal by clicking the following link: Data Subject Request Form

Alternatively, if you are having issues with accessing our secure privacy portal you make your request to the INM Data Protection Office as follows:

  • by email to data.protection@inmplc.com;
  • by post to the
    INM Data Protection Office, INM,
    27-32 Talbot St,
    Dublin 1,
    Ireland.

If possible, you should specify the type of information you would like to see to ensure that we meet your expectations. We must be able to verify your identity in order to ensure the safety of your data. Your request may not affect the rights and freedoms of others, e.g. privacy and confidentiality rights of other individuals and/or businesses.

Limitations To These Rights

These rights are in some circumstances limited by data-protection legislation. You may have various rights under Data Protection Legislation. However, in certain circumstances, these rights may be restricted (Article 23 of the General Data Protection Regulation, which is transposed into Irish law by section 54 of the Data Protection Bill 2018, sets out the circumstances in which your rights may be restricted). Also the personal information that is processed as part of INM’s journalistic work may be exempt under Art 85 of the GDPR.

In particular, your rights may be restricted where this is necessary:

  • for the prevention, detection, investigation and prosecution of criminal offences, and/or
  • in compliance with a legal obligation such as a court order and/or
  • in contemplation of or for the establishment, exercise or defence of a legal claim or legal proceedings (whether before a court, tribunal, statutory body or an administrative or out-of-court procedure).

Your Data

The following sections describe how we manage, secure and control access to your data and under what circumstances we disclose data to others.

Retention Of Your Data

To make sure we meet our legal data protection and privacy obligations, we will retain your information for at least as long as your account is active, as needed to provide you services or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you ask for your account to be closed, we will do this as soon as is reasonably possible subject to any applicable terms and conditions relating to the account. Personal information from closed accounts is retained in order to comply with legal obligations, prevent fraud, collect any fees owed or to resolve disputes.

As a matter of course, we will delete personal data associated with accounts that have been inactive for at least 6 years.

Sharing Data With 3rd Parties

We use third party service providers who work for us in the provision of our services. Your data may be processed by a third party if required to deliver a service you have requested.

We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your Data.

We will have written contracts with them which provide assurances regarding the protections that they will give to your Data and their compliance with our data security standards and international transfer restrictions.

We also share data with other INM entities within the group where they are providing you with services that you have requested or where they provide services to us that you have requested.

How Is Your Data Secured

INM operate and use appropriate technical and physical security measures to protect your personal data.

We have in particular taken appropriate security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. In addition, our service providers are also selected carefully and required to use appropriate protective measures.

Where Do We Store Your Data?

In most cases, INM stores your data securely within the European Economic Area (EEA) using GDPR compliant service providers.

In some cases, INM may have to transfer or store your data to countries outside the EEA, for example, when one of our service providers use employees or equipment based outside the EEA.

For transfers of your personal data to third parties outside of the EEA, we take additional steps in line with Data Protection Legislation. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, e.g. we establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU commission’s model clauses.

Disclosure Of Your Data

Your Data is private and confidential. Your Personal data may only be shared within INM, for any of the purposes set out in this Privacy Statement.

From time to time, we may access and/or disclose your Data if required to do so by law or in good faith and belief that such action is necessary to:

  • conform with the law or comply with legal process served on us;
  • protect and defend our rights or property including, without limitation the security and integrity of our network and systems; or
  • act under exigent circumstances to protect the personal safety of users of our services or members of the public

Changes to this Information

This statement is effective from: 22nd May 2020

We may decide to make changes to this Privacy Notice. If it’s a fundamental change in how we deal with you, then the updated Privacy Notice will be provided to you well in advance of the change actually taking effect.

We will post the changes on our website or send them to you via e-mail along with an explanation of what the likely impact of those changes will be to you, if any.

In order to ensure fairness of the processing, we encourage you to review the content of this Privacy Notice regularly.

Acceptance of this Privacy Statement

By using this Site and by disclosing your Data to us, you consent to the collection, storage, processing, use and disclosure of your Data by us as described in this Privacy Statement. If you do not agree with or are not comfortable with any aspect of this Privacy Statement, your only remedy is to discontinue using our Site. We reserve the right to modify this Privacy Statement at any time. Your continued use of any part of our Site following notification or posting of such changes will constitute your acceptance of those changes.

A more in-depth explanation about how a user’s data is handled by the INM Group can find under our Independent.ie Privacy Policy https://www.independent.ie/service/privacy-statement-26859902.html

Contact the Data Protection Office

INM has a data protection function including a data protection officer. If you wish to invoke your rights or have any questions please contact the INM Data Protection Office via our secure privacy portal by clicking the following link: Data Subject Request Form.

Alternatively you can contact us by post or by email:-

INM Data Protection Office
Independent News and Media PLC
Independent House
27-32 Talbot Street
Dublin 1

Email: data.protection@inmplc.com