Last updated: April 2020
In this policy you will find information on the types of personal data we obtain, how we use the personal data, and with whom we share it. We also describe the rights you have and how you can contact us about our privacy practices. SoGlos’s data controller is SoPublishing, which is the organisation responsible for processing your personal information. You can contact the data controller via the information provided at the bottom of this page.
Users of SoGlos are subject to limitations which govern your visit to the Site; please see our legal notices and cookies policy for more information.
We may collect personal data you choose to provide to us through the Site, including, but not limited to, your first name, last name, physical address, email address, age, gender, and telephone number, such as when you:
• Register on the Site, to create a User Account;
• Fill out a form on the Site;
• Sign-up to receive direct marketing communications on the Site;
• Sign-up to a feature that we offer on the Site and you provide your personal data in connection with that feature;
• Attend an event that we or one of our business partners has organised;
• Communicate with us (for example, on a social media platform or by sending us an email);
• Vote in the SoGlos Gloucestershire Lifestyle Awards, enter a competition, respond to a survey.
When you visit our Site, we also may collect certain information by automated means using technologies such as cookies, non-cookie-based tokens, web server logs, tracking pixels, and web beacons. Cookies are files that websites send to your computer or other Internet-connected device to identify your browser uniquely or to store information or settings in your browser. Your browser may tell you when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Site. Non-cookie-based tokens are encoded URL-based identifiers that track email click-thru activity or time-sensitive password reset keys and will work in scenarios where cookies are disabled or a session has not been initiated.
Where permitted by law, we may acquire personal data about you from third parties. This may include publicly-available profile information (such as your preferences and interests) on third party social media sites (such as Facebook, Twitter and Instagram), and marketing lists acquired from third party marketing agencies.
We may also collect personal data in other contexts that we will notify you of at the time.
Personal data you provide directly to us will be apparent from the context in which you provide it.
In order to enter competitions, choose to receive the email newsletter or vote in the SoGlos Gloucestershire Lifestyle Awards, you will be required to register on the Site and create a user account. As part of this process you will generally provide your first name, last name, physical address, email address, age, gender, and (for competitions specifically) telephone number.
Our legal basis for processing your personal data in this way is that this is necessary for the performance of a contract to which you are a party.
Each form on SoGlos varies in the information required and collected. In some cases you may choose to provide additional information within fields which are not mandatory.
Our web servers may log information such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to our Site and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the Site, such as which pages you visit.
To control which web servers collect information by automated means, we may use tags called ‘web beacons’ – small files that link web pages to particular web servers and their cookies. We may also collect information from your browser, such as your browsing history, and use it in conjunction with data gathered from forms and emails to help us understand and respond to your needs.
Where the information gathered is completely anonymised, the information will not constitute personal data. Where your personal data is not in an anonymous form, our legal basis for processing your personal data in this way, is that it is in our legitimate interest to continually evaluate that personal data in operating and improving our business (and to ensure that the products and services we provide are relevant to the market) that is not overridden by your interests, rights and freedoms to protect personal data about you.
SoGlos includes social media functionality such as Google, Twitter, Facebook, Instagram and Riddle widgets. These widgets may collect information about which pages you visit on the Site and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly.
Social media functions and widgets are hosted either by a third party or directly on the Site. Your interactions with the social media functions and widgets located on the Site are governed by the privacy policies of the companies which provide them. If you use any of the social media functions or widgets on our Site, we strongly suggest you review the privacy policies of the companies which provide those functions and features.
Information we collect from third parties will generally consist of publicly-available profile information (such as your preferences and interests), for example from public social media posts.
We may use personal information you provide to us to respond to your enquiry, for example, to contact you about your request, ask a question, provide announcements, conduct surveys, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our clients and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal data about you.
In addition to the uses discussed above, we may also use the personal data you provide on our Site to:
• Operate, evaluate, and improve our business;
• Perform marketing research, develop new products and services;
• Advertise our products and services;
• Determine the effectiveness of our advertising;
• Analyse our products, services, and websites;
• Administer the Site;
• Segment and personalise the marketing communication that you have viewed on the Site.
We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights and freedoms to protect personal data about you.
We may also use the information to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.
We use personal data collected automatically through cookies, non-cookie-based tokens, web beacons, and other automated means for purposes such as customizing and enhancing our users’ visits to the Site, facilitating use of the Sites, collecting statistics about your visits to the Site, and understanding the manner in which our visitors browse the Site. We also use the information to help diagnose technical and service problems, administer the Site, and identify visitors to the Site. We use analytics data to determine how much time visitors spend on web pages of the Site, how visitors navigate through the Site, and how we may tailor the Site to meet the needs of our visitors. We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our Site that is not overridden by your interests, rights and freedoms to protect personal data about you.
In addition to the uses described above, we may use personal data you provide to us or that we collect for other purposes. Where that is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal data and our legal basis for doing so.
We do not sell or otherwise disclose personal data that you provide to us or that we collect on our Site, except as described here. We may share personal data you provide to us or that we collect on the Site with:
• Other titles in the SoPublishing group;
• Our business partners;
• A named third party, for example in relation to a competition you have entered, and only where you have given consent;
• Service providers which perform services on our behalf.
We may share personal data with service providers which perform services on our behalf such as payment service providers, analytics providers, hosting providers and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements.
In addition, we may disclose personal data about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (c) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
The time period for which we keep personal data depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfil the purposes for which we collected it. We will then delete the personal data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal data as follows:
• When you register for the email newsletter: For the duration of our relationship with you until you opt-out or until we do not have any contact with you for two years.
• Personal data collected for analytics purposes: For a short period of time necessary for us to carry out the analytics. Personal data used for analytics is anonymised immediately.
• Website logs: For up to a year
You have the following rights in relation to personal data that we hold about you:
• To request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
• To request that we rectify or update your personal data that is inaccurate, incomplete or outdated.
• To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
• To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
• Where you have given us consent to process your personal data, to withdraw your consent; and
• To request that we provide a copy of your personal data to you in a structured, commonly used and machine-readable format in certain circumstances.
You also have the right to lodge a complaint with the data protection supervisory authority in your country.
9 Imperial Square