This privacy policy is effective as and from Sep 26th, 2019

Introduction

Your privacy is important to The College Tribune and maintaining your trust is paramount to us. By using our site, you are trusting us with your information. We are fully committed to keeping your personal data safe. This privacy policy is intended to provide you with information about the personal information we collect and how that information is used and shared. We collect personal information about you when you access this site or when you use any of our products, applications or services (collectively our “Services”).

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.

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions 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.

We value your opinions. Should you have any questions or comments related to this privacy policy, please contact us at dataprotection@45.76.141.254.

Changes to this privacy policy

We may update this privacy policy from time to time. If we make any material changes, we will notify you prior to the changes taking effect by posting a notice on our websites and, where appropriate, sending you a notification.

Who is The College Tribune and how are we contacted?

Throughout this privacy policy, “we”, “us” and “ours” refers to The College Tribune as an independent student publication. The College Tribune has an address at LG18, John Henry Newman Building, UCD, Belfield, Dublin 4, Ireland. We are the organisation that controls your data, known as the “ data controller” under data protection law.

Data protection officer

We have appointed an internal data protection officer (DPO) for you to contact if you have any questions regarding this privacy policy, our privacy practices or if you wish to exercise your data rights. They can be reached by email at dataprotection@45.76.141.254.

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 dataprotection@45.76.141.254.

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.
We use cookies and similar technologies to facilitate our Services in the retrieving of your user preferences; to personalise your visits; for the operation of our website; to collect statistical information about our visitors for analytical purposes (we use Google analytics and WordPress); and to provide social media features.

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.

Advertising networks may use cookies and similar technologies to track you in order to measure the effectiveness of the ads they serve, detect fraudulent traffic, or to create a browsing profile that is used to deliver more relevant ads.

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.

Other

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 process data in a form that does not, on its own, permit direct association with any specific individual and therefore cannot be reasonably used to identify or contact you. Aggregated and anonymous data is considered non-personal information for the purposes of this privacy policy.

Push notifications

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 dataprotection@45.76.141.254 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 dataprotection@45.76.141.254. 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

We may share your personal information with any member of our team, which means our different sections and writers and use it in a manner that is consistent with this privacy policy.

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.

Third-party 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.

Independent auditors

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

Our website and mobile applications use interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to like or share information from our sites through these services, you should review the privacy policy of that service. If you are a member of a social media site and logged in, the interfaces configured on our Services allow the social media site to connect your site visit and browsing behaviour to the personal data held on your social media site. The College Tribune can use this information on an aggregate basis to place ads that are based on your interests on these social media sites. These practices are governed by the privacy statements of these social networking sites and you are advised to review these separately.

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 dataprotection@45.76.141.254. 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.