This Privacy Policy applies to the website Adan Ortega, located at http://www.adan-ortega.net
Information we collect
Account information
This website has no user account facility so we are not collecting the kind of information associated with user accounts such as names, addresses, contact details.
Information we obtain through cookies and similar tools
We use cookies (and similar technologies) and analytics tools to collect information about you. This information can be used to improve the performance of the site and enhance your user experience. The data we use includes:
- Your usage – we use cookies to understand how our customers use our site and interact with our communications and journalism. For example, we use technology on our site, which records user movements, including page scrolling, clicks and text entered. (It does not record payment details.) This helps us to identify usability issues and improve the assistance we can provide to users and is also used for aggregated and statistical reporting purposes.
- Your device – we use cookies to understand what type of device you are using to show you the best version of the site.
Lawful basis for processing
We only process personal information where we have a lawful basis for doing so, such as the following:
- User consent – This is where you have given us explicit permission to process personal information for a given purpose. For example, if you complete one of our general enquiry forms, we would ask for your consent if we wanted to use your personal information for any other purpose. You have the right to withdraw this consent at any time. You can manage your preferences within your account or by contacting customer services.
- Legitimate business purposes – This is where we have a legitimate interest, as a business, to process personal information. For example, where we are aware of copyright infringements on our Site, it is in our legitimate interests as a business to identify those responsible. We take due care to balance our interests against your right to privacy.
- Contractual necessity – This is where we have to process personal information to meet our contractual obligations. For example, if you are a print subscriber, we would need to process your delivery address to fulfil your subscription.
- Legal obligation – This is where we have to process personal information in order to comply with the law. For example, we process and retain customer invoice information to comply with financial regulations.
How we use your personal information
We collect personal information for the folllowing reasons:
To provide our service – We require some of your basic personal information so our services work as you would expect and to assist us giving an insight as to functionality and popular features on the site.
To improve and maintain performance – In order to provide you with the best possible user experience, we need to make sure that our products and services work as they should. Using personal information helps us understand how our readers use our site so we can make improvements. This includes testing proposed developments on our site, reaching out to our customers with market research surveys and hosting subscriber focus groups.
To monitor compliance with our policies and terms – We monitor for breaches of our terms and conditions and copyright policies. For example, we reserve the right to inform the subscription holder if, through use of a group subscription, you are using our content in breach of the terms and conditions or copyright policies of our website. We also monitor activity on our site to detect and prevent invalid or fraudulent traffic.
To personalise our products and services – We improve your experience of our products and services by personalising parts of our site and apps with the information you give us and what we learn about you. This includes showing you content you may be interested in and recommending emails you may wish to sign up to. Where our site has such functionality, you can manage elements of personalisation in your account.
Who we share your personal information with
We disclose personal information to facilitate the running of our business or to provide specific services you have requested. Commonly, we will disclose information to:
- Service providers – We engage service providers who help to support our business and improve our products. These service providers include, for example, fulfilment providers for delivery of our digital content and marketing; customer service agencies; hosts, organisers and sponsors of our events; organisations that host our site or databases; and providers of online surveys.We also work with a number of distribution partners to deliver subscriptions. We have contracts in place with these data processors and they can only use your personal information under our instruction. For example, if you have a print subscription with us, we will disclose your information (address, contact details) to our distribution partners to facilitate delivery of the newspaper or magazine.
- Legal processes and successors in title – We may also disclose your information to comply with applicable laws, court orders or other valid legal processes, and to enforce or apply our terms of use, any subscription agreement, or any of our other rights. We may transfer or disclose your personal information to any entity which takes over or acquires the business. We also share aggregated, non-identifiable information with third parties. Before sharing this information, we ensure that it cannot identify you as an individual. For example, we regularly release information about the size and growth of our audiences.
How long we retain your personal information
Where we don’t need to keep all of your information in full, we will obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary.
It is sometimes necessary for us to keep your personal information for longer periods of time, for example:
- If there is a statutory requirement to retain it;
- If we require the information for legal reasons or there is a legitimate business need for us to retain it;
- To ensure we do not contact you if you have asked us not to.
How we keep your personal information secure
We have appropriate technical and administrative security measures in place to help ensure that our users’ information is protected against unauthorised or accidental access, use, alteration, or loss. We use encryption technology, such as Transport Layer Security (TLS), to protect your personal information when you order products or services from us.
We operate a global business, so your personal information may be processed and stored outside the European Economic Area (EEA).
Your rights
Under data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include:
- The right to access the personal data that we process about you;
- The right to request the deletion of your personal data;
- The right to request the rectification of your personal data.
You also have the right to lodge a complaint with a supervisory authority.
Advertising
This website does not host advertising or share your data with third party advertisers.
Where this Privacy Policy applies
Our site is not intended for children under 16 years of age. We do not intentionally collect or use any information from children.
Our site contains links to third party website which are not subject to this privacy policy. We are not responsible for their content, use of personal information, or security practices.
If you have a query in regards to the processing of your personal information, please contact us.
Last Updated: 24th May, 2018.