[Mulberry Publications Ltd (“Mulberry”], “Us”, “We”, “Our”) registered in England and Wales under company number 03534647 is the Data Controller of your Information for the purposes of the Data Protection Act 1998 (the “Act”). Our VAT registration number is GB732164064.
We respect your privacy and we are committed to protecting your personal Information as that term is defined in the Act (“Information”). We comply with the principles of the Act and aim to maintain consistently high levels of best practice in our processing of your Information.
We know how important it is for you to have control over any communications that you receive from us. We therefore give you the right to unsubscribe from any communication that we send to you and have your data completely removed from all of our databases.
By using our website and services you consent to our collection and use of your Information as described in this Policy. If we change our Policy and/or procedures, we will update this Policy to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.
In addition to this Policy, each service offered by us may have additional privacy provisions that are specific to the particular service. These supplemental disclosures are made adjacent to the particular service at the time your Information is collected.
2 WHAT INFORMATION DO WE COLLECT?
All your Information will be held and used in accordance with the Act where applicable. If you want to know what Information we collect and hold about you, please email us at: email@example.com, or write to us at the address given at the end of this Policy. When you visit and use our website or request our services you may provide us with or we may collect your Information such as your postal address, email address and other personal information. You may provide or we may collect this Information in a number of ways:
2.1 Information you voluntarily provide to us
We collect and maintain Information that you voluntarily submit to us during your use of our website or services. For example:
- When you register on our website or for a product or service, you may provide us with certain Information including your name, email address, user name, password and demographic Information
- If you sign up to our service via a social network we may use the profile Information you enable us to access regarding your interests.
- If you sign up to receive a newsletter, a magazine, enter a competition or participate in social networking activities, you may provide us with contact Information (e.g., email, telephone and/or or physical address)
- You may provide us with Information in the course of email, customer support interactions and surveys.
Different websites operated by us may ask for different pieces of Information. You can choose not to provide us with certain Information, but this may stop you from gaining access to a service or limit the features that you can use on our websites. For more Information, please see the “How We Use Your Information” section of the Policy below.
2.2 Information we collect through your use of our Website
2.3 Information we receive from third parties
We may also combine online and/or offline Information received from third parties with your Information. The third party Information is used for a variety of purposes including to verify other Information about you (e.g., verify your mailing address to send you requested products or services) and to enhance the content and relevance of the advertising we provide to you.
3 PROTECTION OF CHILDREN’S PERSONAL INFORMATION
3.1 Most of our sites are not designed for children
3.2 We recommend that parents or guardians supervise young people while they are online.
3.3 We are dedicated to the protection of children’s and young people’s personal Information and we do not knowingly market to children.
3.4 If you are under 16 years of age you should always ask your parent or guardian before:
- Responding to anything on any of our sites
- Asking us to send anything to you or another young person
- Enter a competition or a game online – you must generally be over 16 years of age to enter, but please do check the specific Terms & Conditions for each instance.
- Post anything on a bulletin board or any chat room
- Offer to agree to buy anything online
3.5 A parent or guardian may submit a request to firstname.lastname@example.org to stop any further use of a child or young person’s personal Information or to request that we suppress any Information as far as we are able. Before disclosing Information about a child, we may request that the parent or guardian provide reasonable Information for identification purposes.
4 HOW WE USE YOUR INFORMATION
We will use your Information in the ways described below and as described at the time that the Information is collected.
4.1 To Provide the Services
In general, we use your Information as necessary or appropriate for our business purposes including to:
- Administer your account where you have opened an account with us
- Register you and provide you access to the website or services requested by you
- Respond to inquiries or requests that you direct to us
- Fulfil your requests for products or services
- Send communications and administrative emails about the website or our services
- Personalise and better tailor the features, performance and support of the website and our services for your use; analyse, benchmark and conduct research on user data and user interactions with the website and our services
- Run competitions
- Deliver customer services
- Other purposes related to any of the above
Where you have provided us with the appropriate consents, or where the Act entitles us to do so, we may send you marketing materials about other products or services offered by Mulberry Publications Ltd.
We do not ever release, rent or sell your data to any third party for their promotional activity. We understand the irritations of unsolicited communications and we are fully committed to ensuring the rights and obligations set out in the Act and the Privacy and Electronic Communications Regulations 2003, updated 2004 and 2011 are respected.
4.3 Behavioural Advertising – customer-relevant advertising
We believe that advertising is more interesting to you when it is relevant. Accordingly, we may customise the advertisements that you see based upon:
- The Information you voluntarily provide to us
- Geographic location Information, which we may determine through your IP address, from your mobile device, or other ways
- Data we receive from third parties
5 CAN I FIND OUT WHAT PERSONAL INFORMATION MULBERRY HOLDS ON ME?
Under the Act you have the right to request a copy of the Information that we hold about you. There will be an administration fee of £10 associated with this request, as permitted by the Act, and it will require two pieces of identification to prove your identity. Please make a written application to the Data Protection Officer, Mulberry Publications Ltd, 154-160 Fleet Street, London EC4A 2DQ. The statutory time for our response is 40 days but with your help in providing us with relevant Information we endeavour to respond sooner.
If any of the Information that we hold about you is incorrect and you’d like it amended, please email@example.com and we’ll review your request.
If the incorrect Information relates to your magazine subscription, then you can contact the Customer Services team at firstname.lastname@example.org who will update your details as soon as practically possible.
6 HOW WE DISCLOSE YOUR INFORMATION TO THIRD PARTIES
We may share your Information with third parties as specifically approved by you or under the circumstances described below and in this Policy.
6.1 Disclosure for legal reasons
We may disclose your Information if we are under a duty to disclose or share your Information to comply with any legal obligation or in order to enforce or apply or fulfil our terms and conditions and other agreements or protect the rights, property, or safety of our customers, our company or others. This includes exchanging Information with other companies and organisations for fraud protection and credit risk reduction.
We use a number of third party organisations to help provide a professional service to our customers (i.e. fulfilment bureaus, call centres, and website designers). These organisations act as data processors and are strictly contractually controlled in how they may/may not use your Information and we remain responsible for the protection of your Information.
6.2 Promotions and Sponsors
When you participate in a Promotion, you are subject to any official rules for that Promotion, which may contain additional Information about the specific privacy practices associated with the Promotion.
6.3 Changes to our Company
In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
6.4 Message Boards and Chats
We may make message boards, chat rooms, and other interactive forums available as part of our services. You should be aware that any Information which you post to these interactive forums or otherwise choose to make publicly available, may be disclosed and available to all users who have access to that portion of our website or services. By using these interactive forums, you agree that we are not responsible for any Information that you disclose or communicate in such forums, and any disclosures you make are at your own risk.
7 UPDATING AND CONTROL OF YOUR INFORMATION
There are a number of ways in which you can control the collection, use, and sharing of your Information and update your Information and preferences.
7.1 Opting-Out on Receipt of Marketing Communications
When you receive electronic marketing communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in e-mails covering any marketing communication from us.
7.2 Preference Services
The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS) and the Mailing Preference Service (MPS) allow you to choose to opt out of unsolicited marketing contact. However, if you are registered on any of the preference services, which are general opt-out registers, you may still receive marketing communications from us if you have given us your consent previously or if you subsequently give us that consent.
7.3 Contacting Us
If your Information has changed or if you no longer wish to receive marketing communications from us then you can amend your Information at any time Please note that:
- Even if you delete Information, we may retain your Information in conformance with our data retention policy most specifically for legal and tax reasons and to honour your opt-out requests; and
- We do not keep Information longer than we deem necessary.
- We are not responsible for updating or removing your Information contained in the lists or databases of third parties who have previously been provided with Information as permitted by this Policy.
8 THIRD PARTY LINKS AND SERVICES
Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies. Your browsing and interaction on any other website or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the Information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to Information collected by us through our website or services and does not apply to these third party websites and third party service providers.
9 WHERE WE STORE YOUR INFORMATION
The Information that we collect from you may be transferred to, stored and processed at a destination outside the European Economic Area, (all EU countries plus Norway, Iceland and Liechtenstein). Your Information may also be processed by staffs operating outside the EEA who work for us or for one of our suppliers, for instance, for customer service purposes. By submitting Information to us, you agree to this transfer, storing or processing. We will take all reasonable steps necessary, including the use of the Model Contractual Arrangements as approved by the EU, or other contractual means to ensure that your Information is treated securely and in accordance with this Policy and the Act.
10 SECURITY OF YOUR INFORMATION
We follow appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal Information to comply with the same. However, unfortunately, the transmission of Information via the Internet is not completely secure. So, we cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the Act. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.
11 REPORTING OF SECURITY VULNERABILITIES
Mulberry Publications Ltd is committed to the privacy, safety and security of our customers. If you discover a potential security vulnerability, we would appreciate it if you could report it just to us in a responsible manner. Please email us at Mulberry Publications Ltd email@example.com and we will respond to you as soon as possible. This provides us with an opportunity to work with you and quickly address and resolve any issue. Publicly disclosing a potential vulnerability could put the wider community at risk, and therefore we encourage you to come to us first. We’ll keep you informed as we move forward with our investigations.
12 SOCIAL MEDIA
12.1 Mulberry Publications Ltd provides users with the ability to use their social media credentials to sign in to our website(s)
When you create your Mulberry account, and authenticate via a third-party service like Twitter or Facebook, you grant permission to the social network to share your user details with us.
Depending on the network this will include
- Basic account Information included in your public profile such as name and email address required to verify and facilitate your sign in
- Other Information that is publically available based upon the privacy settings you have with your social media account.
- Any other details you choose to share according to your specific account settings.
We will be clear when we do request more than just basic account Information from you and request that you should also check what permissions we are asking for before you connect with these apps and services. We want to use this Information to better tailor any content we provide to you.
Social sign-in may be provided by Mulberry or a third party
12.2 Social networking sites, such as Facebook, Linked-In, among others, work with us as trusted third party partners. We also work with application developers who specialise in social media, so that we can connect with your social networks. We provide access to our Websites for third parties and business partners so that we can generate interest in our products and services among members of your social networks and to allow you to share product and service interests with friends in your network.
12.3 We do not control how your personal Information is collected, stored or used by such third party sites or to whom it is disclosed. You should review the privacy policies and settings on any social networking site that you subscribe to so that you understand the Information they may be sharing. If you do not want your networking sites to share Information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such Information. Mulberry is not responsible for how these third party sites may use Information collected from or about you.
13 ANTI-SPAM POLICY
Mulberry Publications Ltd provides interesting and thought-provoking content in our emails and aims to tailor them to the specific needs & interests of our brand audiences. We hope you enjoy receiving and reading them.
13.1 Automated Spam Filtering: We automatically scan all incoming electronic messages and filter out those that appear to be spam. As no system can be 100% accurate in detecting genuine emails from spam, authentic messages may occasionally be filtered. If you believe this may have happened, please contact the recipient by another means.
13.2 Unwanted messages from Mulberry: Any recipient of email communication from us may request, at any time, to unsubscribe. In the unlikely event you are in receipt of email communication from Mulberry which could be considered as spam, we encourage you to report it to us by forwarding a copy to us at: firstname.lastname@example.org
We will fully investigate any reports of abuse.
14 GDPR – EU General Data Protection Regulation May 2018
Mulberry Publications Ltd stores, protects and processes all data in accordance with the GDPR regulation. Mulberry does this under the provision of legitimate interest.
14.1 Mulberry Publications Ltd is a company registered in England in 1998 and operates as a publisher of magazines, websites and email based news wires. Our aim is always to provide interesting and informative editorial for all of our readers whether in print or in a digital format.
14.2 Our business model, the information that we publish and the people we employ is based upon our ability to process data. The data is used entirely for circulating printed magazines and email newswires. The abiding aim is to build engaged audiences who appreciate and enjoy our products.
14.3 Mulberry is always mindful of the interests of our readers or visitors to our websites. We operate exact systems where any data subject/reader may unsubscribe from any of our products at any time. All of our products whether in print, email or online offer the reader the opportunity to unsubscribe. We understand that unsolicited email communications can be irritating and so any unsubscribe request is processed with immediate effect. We carefully edit all communications that we send applying high journalistic standards, and so do not believe our communications could actually cause harm to any data subject besides the irritation element referred to above.
15 HOW TO CONTACT US
If you have any questions regarding privacy or this Policy, you may contact us as follows:
Data Controller, Mulberry Publications Ltd, 154-160 Fleet Street, London EC4A 2DQ email@example.com
Changes to this Policy
We may amend/update this policy by publishing a new version on this website at any time, so we encourage you to check back regularly to make sure that you are still happy with the terms under which we process your personal data.
Updated 6th February 2016.