LAST UPDATED 01/03/22
Life Lessons Festival (trading name of News Live Ltd, part of News Corp. ) (‘News Live’ or ‘we’) is committed to protecting the personal information you provide or we collect when you purchase tickets to our events, subscribe to our online content, buy any of our news titles or products, or use any of our websites and applications (our ‘services’).
The Life Lessons Festival is organised by News Live Ltd, part of News Corp. Head Office Postal Address. News UK & Ireland Ltd. 1 London Bridge Street. London SE1 9GF.
News Corp UK & Ireland Limited and its subsidiary companies listed below (together “News UK”, “we”, “our” or “us” “Group”) will collect, use, share and disclose or otherwise process your personal information in line with this Policy. The relevant controller for your information will depend on which event, product or service you have interacted with or to which event or title you have subscribed to, as set out below.
Our Notice also describes the measures we take to protect the security of the personal data. We also tell you how you can reach us to:
(i) access, correct, or delete the personal data that you have provided;
(ii) withdraw any consent you may have previously given to the processing of your personal data;
(iii) tell us not to contact you with marketing materials about our products and services; and
(iv) ask any questions you may have about our online privacy practices.
|News UK & Ireland Limited||Provides support and services to other Group entities and may act as a joint controller in relation to these services. It acts as a controller for the influencer talent agency trading as The Fifth and the associated websites, talkRADIO TV, and photography and illustration agency trading as Studio Pi and associated websites.|
|News Group Newspapers Limited||The Sun, The Sun on Sunday, The Irish Sun, The Scottish Sun, The Irish Sun on Sunday, The Scottish Sun on Sunday, The Sun’s Dream Team Fantasy Football game and the associated websites.|
|Times Newspapers Limited||The Times, The Sunday Times and The Sunday Times Travel Magazine and the associated websites.|
|Newsprinters Limited||Direct to Consumer, Direct to Retail and other production and retail services.|
|The Times Literary Supplement Limited||The Times Literary Supplement and the associated websites.|
|Sunday Times Driving Limited||Sunday Times Driving Limited.|
|talkSPORT Limited||talkSPORT, talkSPORT 2, talkRADIO, talkSPORT EDGE, Virgin Radio UK, Times Radio, and the local radio stations Scottish Sun 80s, Scottish Sun Hits, and Scottish Sun Greatest Hits.|
|U105 Limited||U105, broadcasting on 105.8FM and DAB in Northern Ireland and associated websites.|
|The Internet Business Limited||(Trading as Tibus) providers of digital infrastructure services.|
|Simply Zesty UK Limited||(Trading as Zesty) a PR and digital social media agency operating in the UK.|
|Independent Broadcasting Corporation Limited||LMFM in Drogheda.|
|Capital Radio Productions Limited||FM 104 in Dublin.|
|Treaty Radio Limited||Live 95FM in Limerick.|
|City Broadcasting Limited||Q102 in Dublin.|
|Cork Media Enterprises Limited||96FM and C103 in Cork.|
|News Live Limited||LifeLessons, RunFestRun, and associated websites. News Live branded events and joint controller for other News UK branded events.|
When you purchase tickets to our events, subscribe to our online content, sign up to our services (such as our website forums or regular newsletters), enter competitions, buy a subscription, order products, take up a reader offer or use our websites and mobile apps we may collect personal information about you. Different services may require different types of information.
If you are aged 16 or under, you must get your parent/guardian’s permission before you provide us with your personal information. Unless you have this consent, you are not allowed to give us your information.
Here is some more specific detail about the information we collect:
- Information you give to us: information that you provide by filling in forms on our services. This includes information provided at the time of buying any of our products or services, subscribing to any services or marketing, creating a user account, posting material, filling in a survey or requesting further services. We will also ask you for information when you enter a competition or promotion and when you report a problem with our services. This information will normally include information about yourself (such as your name or date of birth) and contact details (such as address, email address, telephone number etc);
- Information about your location: if you have enabled located services on your device, we may collect information about your actual location. You can disable location services at any time by updating your preferences on your device;
- Information about transactions: if you purchase something from us such as tickets to our events, subscribe to our online content, a magazine subscription or an app, we will make a record of the details of that transaction, including what products/services you have bought and details of the payment made; and
- Contact information: if you contact us, we may keep a record of that correspondence.
As well as collecting information directly, we may receive personal information about you from third parties (such as our business partners) where you have provided your permission to them to share your information, or they are otherwise legally permitted or required to disclose your personal information to us. We may also collect information gathered from publicly available sources and social media platforms.
We may also compile and share aggregated data, such as statistical or demographic data. This gathers together your personal information and that of others in an aggregated, anonymised way. It does not directly or indirectly reveal your identity.
If you fail to provide the personal information we have requested where we are required to collect this by law, or to perform our contract with you, we may be unable to perform the contract we have or are trying to enter into with you. However, we will notify you if this is the case.
REGISTRATION, FORUMS, APPS AND YOUR DEALINGS WITH US
We collect contact information, biographical details, preferences, and other declared personal information about you when you provide it to us. For example, when you fill out our online forms, purchase tickets, subscribe to one of our events, titles, products or services, enter a competition run by us, respond to our promotions, enquire about our products and services or participate in a reader forum or poll (which could be on any medium or platform, including social media).
INFORMATION FROM DEVICES
We also collect information automatically from your devices when you interact with our websites or use our apps. This can include:
• Information about your device type, operating system, hardware, software, display settings and browser type to tailor your experience to your device (tablet vs phone)
• Unique identifiers, such as you Advertising ID (e.g. Google’s Advertiser Identification or Apple’s Identifier for Advertisers) to save your preferences against an identifier to display advertising
• Other unique identifiers like IP address, so that we can recognise if you have been to our websites before, allow your device to interact with our websites and apps
• Device settings such as general geographic location (this can be to provide services that have copyright restrictions, to show you content that is relevant to where you are, and tailor advertising to your interests)
• Device operations, such as information about how you’ve used the device on our sites or apps, so that we can tailor the experience based on the way you or similar users interact with our content
• Details of the products and services you are using and your navigation around, and interaction with, our products and services
With your consent, we may also collect the specific location of your device or request access to data from other applications to provide certain services you have requested.
When you download our apps, we will collect the following information from your device: unique identifier (UDID), MAC address or other applicable device identifier and location.
We may also collect information from device identifiers and tags placed on your device when you use our mobile TV app, including viewing history, download history and settings and marketing consents. See the section on Cookies & Similar Technologies for more information about our use of such technologies.
POSTS, COMMENTS AND INTERACTION
If you correspond with any of our events, titles or radio stations or TV channels, or interact with other customers or audience members or our staff, for example by using polls, comments, text messages, video, email, phone, radio or by post, we may display this content indefinitely in any relevant context, subject to our editorial judgement and your rights as set out in this Policy. This may be anonymised in the case of testimonials or customer service conversations.
If you take part in any reader, listener or viewer forums, send us letters for publication, or take part in any radio ‘phone-ins’ or TV shows, then you may be identifiable to others publicly and your comments attributed to you.
PUBLIC INFORMATION AND POSTS
Any information about yourself or others that you post on our social media pages, on platforms like Twitter, Facebook and other chat rooms, blogs and forums, will be viewed by others (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in public areas, and you acknowledge that this may be collected and used by third parties.
We may ask data management and consumer insight providers if they have lifestyle, demographic, household information or other insights about you. This information helps us better understand our audiences. For more information on how to control this use of your information, see the section below on Controlling Your Information.
When you use third party payment providers, such as PayPal, to pay for or receive payment from us, we will receive information including your name, email address, billing or other address, phone number (if applicable), date of sign-up, the number of payments you have received from verified PayPal users, whether you have been verified to have control of a bank account and any other information you agree they can share. If you apply for credit, we may also receive information from credit reference agencies.
Other organisations that provide products and services to you may also share information with us. For example, they may notify us when you move home or when the payment card you used with us is renewed or replaced, so that we can keep your information accurate and up to date. This also helps ensure that you do not lose access to our products and services. We also may receive information from our partners about their customer database. This allows our partners to see if they can reach their audiences on our platforms. Generally, we will receive aggregated information rather than individual information, although your information may be used to generate these insights.
There may be some uses of your information where we need to ask for your consent. You will have the right to withdraw that consent at any time, however, if you withdraw consent, we may not be able to provide the product or service you have requested. We will rely on your consent to:
Deliver Direct Marketing Communications: where required, we will ask your permission if we want to deliver direct marketing to you. If you have an account connected to one of our products, you may be able to change your marketing preferences in a preference centre linked to that account. You will also be able to opt out in the communication itself.
We may send you direct marketing communications via post, telephone, email, SMS, social media, online, in-app and devices connected to the internet, like smart TVs, if we hold a valid direct marketing permission for you where required.
Place cookies and similar technologies: in accordance with the information provided in the “Cookies & Similar Technologies” section and the information provided to you when those technologies are used.
FULFILLING A CONTRACT
We process your personal information to fulfil a contract we have with you. We rely on this legal basis to:
Provide products and services you have asked for and manage our relationship with you: This may include managing requests, payments, access to products and services, allowing you to interact, comment, and participate in online games, contests, live and recorded events and reward programmes. This may also include sending you information and updates relating to the products and services we provide to you.
Take payments, check your identity and conduct credit checks: Information that we hold about you and that you provide to us may be used to take payment for products and services. It may also be used to verify credit details related to payments. Payment details may be retained in order to speed up the renewal process for products and services.
If you apply for credit, then in order to help us make credit decisions about you we may check with credit reference agencies who will record any credit searches on your credit file. We may also disclose details of how you conduct your account with us to these credit reference agencies for related purposes.
FOR A LEGITIMATE INTEREST
We may use your information where there is a legitimate reason to do so, such as where it would help achieve our business objectives or to facilitate a benefit to you or someone else.
Our legitimate interests in processing personal data include:
- to support a free press, including journalistic activities of societal importance;
- to support individual and societal rights to receive information;
- to develop, deliver and maintain relevant and engaging products services and advertising;
- understanding when our audiences engage with us or other organisations;
- to build a clearer understanding of who our audiences are in order to better serve them;
- to carry on the business of a commercial organisation; and
- to demonstrate that we provide services and products to agreed industry standards.
We rely on these legitimate interests to:
- Monitor, improve and protect our products, content, services and websites, online and offline: This includes using information about your app download to validate free trials.
- Manage complaints: including requests and concerns that you may have about products or services we provide.
- Personalise your experience: We sometimes make assumptions about your interests and preferences based on the way you interact with our products and services and the information we hold about you.
- Knowing these interests and preferences allows us to understand the products, content and services our customers like, letting us focus our efforts on developing those areas. We may use this information to tailor and personalise your user experience, as well as to make decisions about what direct marketing and advertising to show you.
Content recommendations: We may also use your information to optimise article and content recommendations. Based on the kind of articles and content which prove to be of interest to you.
- To build and manage direct marketing campaigns: We use your information to create engaging and relevant marketing campaigns promoting products and services we think you will like from our brands and partners.nThe use of your information to do this is usually based on a legitimate interest, however, we will ask your permission if we want to deliver direct marketing to you. You will be able to change your marketing preferences in your Preference Centre or in the communications you are sent.
- To send product related and similar product and services communications: for certain types of marketing communications, we do not require your consent and we instead rely on our legitimate interest. This is the case for example where we send you postal advertising or where we send you ‘in-life’ communications about products or services that we provide to you. You can opt out of these communications either by visiting your preference centre if you have an account or in the communication itself.
We may send you service-related messages, which are about the service we provide. We do not require your consent for these, and you are not able to opt out.
- Prevent fraud, check your identity, and prevent money laundering: We may use your information to check your identity in relation to requests you make. We may also have a legal obligation requiring us to carry out this activity.
- Facilitate posting, commenting and interaction: If you correspond with any of our titles, radio stations or TV channels, or interact with other customers or audience members or our staff, for example by using polls, comments, text messages, video, email, phone, radio or by post, we may display this content indefinitely in any relevant context, subject to our editorial judgement and your rights as set out in this Policy. This may be anonymised in the case of testimonials or customer service conversations. If you take part in any reader or listener forums, send us letters for publication, or take part in any radio ‘phone-ins’, then you may be identifiable to others publicly and your comments attributed to you.
- Deliver relevant advertising: We may use the information we hold about you to help us and our partners make better decisions about what adverts to present to you. We also use the information we collect from you and other sources to create engaging and relevant marketing campaigns promoting products and services we think you will like from our brands and partners.
- When you visit our websites, use our apps, or watch content on devices connected to the internet such as smart TVs, advertising networks and other intermediaries that we work with may select and then display adverts on your device. In the case of some of our digital radio stations, when listening online, we and our partners may insert a relevant audio advert for you to listen to.
- Audience segmentation and creation: we may use the information we hold about you, including how you engage with our products and services, as well as from other sources, to segment our audiences into groups with particular attributes (likes/dislikes/reading behaviours etc). This helps us personalise your experience and show you more relevant content and adverts.
- Cookie matching/syncing: When you visit our sites, we may check your device to see if a cookie ID has been assigned to it. This is a form of identifier that tells us who is visiting our sites. We are then able to compare the cookie ID we have for you with IDs that our advertisers hold to see if we both know who you are. By knowing it is you (or your device), the advertiser can decide if they want to advertise to you and if so, what advertising would be relevant. See the section on Cookies & Similar Technologies for more information.
- Data matching: From time to time we may allow our clients to compare their customer database to ours. This is called data matching and allows our partners to see if they can reach their audiences on our platforms. Generally this will be conducted at an aggregate audience level to provide insights, rather than individual level information, although your information may be used to generate these insights. These insights might include the overlap between our audiences and the client and other information that would be useful to understand if an advertising campaign would be effective.
- As part of the data matching process we may allow partners to build target audiences based on pre-defined attributes. These ‘lookalike’ audiences may be similar to our partners’ existing audiences. For example, a sports brand may want to reach ‘sports enthusiasts’ or those who enjoy ‘outdoor pursuits’. They could select audiences who have been identified as having an interest in these areas. To do this, we segment our audiences into groups depending on what we think they like or other behaviours. This helps them find the right audiences and we are able to show you more relevant advertising.
- Detect ad blockers: We may collect information from your devices that tells us whether you are using an ad blocker. This is so that we can manage our compliance with the law and also determine if we are able to show you advertising. We may also ask you to suspend or whitelist our sites or platforms so that we can show you adverts. As a predominantly advertising funded business, we do rely on our ability to show you advertising to help ensure we are able to provide you with the products and services you request.
- Ensure our services are used appropriately: If you post or send offensive or objectionable content anywhere on or to our websites or apps, or otherwise engage in any disruptive behaviour on any of our platforms, we may use the information that is available to us about you to stop such behaviour. This may involve informing relevant third parties, including your employer, law enforcement or other competent authorities about the content and your behaviour.
- Ensure that our products and services conform to agreed industry standards: Some of our products and services are independently monitored and assessed to ensure they meet approved industry standards and for industry reporting purposes.
- Provide you with support: We may also provide you with help and support where we believe it is required. For example, if you have provided your contact information, we may contact you when a checkout journey is not completed. We may record phone calls or customer enquiries via online chat for quality, training and management purposes.
- Conduct market research and analytics: We may use the information we hold on you about your engagement with our products and services, as well as other information collected from partners and other sources, to understand how our products are used and make improvements or develop other products and services our audiences may like. We may need to contact you about your experience of a product or service we provide you.
- Ipsos Iris – market research project: When you visit our website, we may collect certain personal data about you for an online audience measurement project that analyses internet users’ behaviour and profile across different websites, applications and devices in the UK. Ipsos MORI, a specialist research agency will be carrying out this research, in conjunction with UKOM, the UK Online Measurement company and DotMetrics. To contact Ipsos MORI about this specific research, please email: email@example.com
- Change of control or sale of our business: We may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business
TO COMPLY WITH LEGAL OBLIGATIONS & PROTECT OUR RIGHTS
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This may include publishing information about prize winners, for example.
We may also disclose your information where we are allowed to by law to protect or enforce our rights or the rights of others and for the prevention and detection of crime, such as fraud.
The specific legal basis we use will depend on the activity the information is used for. Please keep in mind that while we will rely on one legal basis, if that is no longer available to us, we may be able to rely on another.
SHARING BETWEEN NEWS UK GROUP COMPANIES
Your information will be shared between the News UK companies listed in the About Us section above for use in accordance with this Policy. Legal basis: Performance of a contract, legitimate interest.
SHARING WITH NEWS CORP AFFILIATES
News UK is part of the News Corporation (“News Corp”) group of companies. We may share your information with News Corp and its affiliates, including The Sun US to: perform analytics and analysis of how you interact with the group’s products and services, to facilitate business efficiencies and develop products and services that would be relevant to you; and deliver more relevant advertising from across our News Corp network.
For more information about how to exercise your rights, please see the section on Controlling Your Information: The Sun US, Inc is the data controller for The Sun U.S. (the-sun.com and associated websites) will use your information in accordance with this Policy. Your information may be shared between the News UK Group and The Sun US, Inc for use in accordance with this Policy.
We also participate in an advertising platform offered by our affiliate, NC Audience Exchange LLC, called News IQ. To learn more about News IQ please visit http://ncaudienceexchange.com/about/.
Legal basis: Performance of a contract, legitimate interest, consent
SHARING WITH RETAILERS
When you sign up to our Home News Delivery (HND) service, we may share your information with your selected retailer in order to help set-up and manage your subscription. The retailers we work with may also share information about you with us in order to manage your subscription, including handling complaints, preventing fraud. This information will also be used for analysis, insights and product development.
Your information may also be used to tailor the marketing we send you in relation to HND. For example, we may use your information and preferences to send you information and offers about other products and services we offer.
Legal basis: Performance of a contract, legitimate interest, consent
SHARING WITH COMMERCIAL PARTNERS
We may disclose your personal information to third parties, such as competition partners, for their direct marketing purposes where we have told you about this and you have given permission or there is a legitimate interest to do so. We may also share cookie data for cookie syncing purposes with commercial partners. Legal basis: Performance of a contract, legitimate interest, consent.
WHITE LABEL PRODUCTS & SERVICES
These partners will also pass us the information they collect about you, including your usage and interaction with those products and services, which we will use in accordance with this Policy. They may also collect direct marketing permissions for us, which we will use to send you direct marketing. Legal basis: Performance of a contract, legitimate interest, consent.
We may share personal data collected on our websites and apps with our advertising partners, which includes the Ozone Project and separately Octave Audio, who act as our processors to help deliver relevant advertising across our platforms. Information that may be shared with these partners includes: contact details, biographical details, engagement information (how a user engages with a product or service), declared data from surveys and polls, online identifiers and inferences such as audience segments based on engagement data. If you would prefer that your information was not shared with Octave Audio and Ozone Project for these purposes, you can change your cookie settings when you visit our websites, and by following the instructions in the Cookies & Similar Technologies section of this Policy. You may still receive advertising when you use our products and services, but this may not be tailored to you.
Legal basis: Legitimate interest, consent
When you sign up for an event put on by one of our bands, we may pass your information to our partners who help to administer them to facilitate your participation or attendance. For example, if you registered to attend an event on our programme via a third party venue, we would need to pass your name and address to our partner to add you to the event guest list.
Legal basis: Legitimate interest, consent, contract
SHARING WITH OUR SERVICE PROVIDERS
We may pass your information to our processors – companies that we use to provide services on our behalf, for example for event management, prize fulfilment agencies, market research or other purposes mentioned in this Policy such as analytics, direct marketing or online advertising. These processors can only use your information in accordance with our instructions and for no other purpose.
Legal basis: Performance of a contract, legitimate interest, consent
SHARING WITH OUR GOVERNING BODY
We may submit audience figures to The Publishers Audience Measurement Company (PAMCo) who are the governing body which oversees audience measurement for the published media industry. While this will generally be achieved through aggregate information, we may use information that could identify individuals.
Legal basis: Legitimate interest, consent
When you provide information to us, we may transfer your information to our group companies and processors outside the UK to countries that may not have data protection rules that provide the same level of protection, including the United States of America. We have appropriate agreements in place to ensure they protect your information in accordance with our legal obligations.
If you would like to receive a copy of the applicable data transfer safeguards used when your information is transferred outside the UK to non-adequate countries, please contact us using our contact details below.
Legal basis: Performance of a contract, legitimate interest, consent
TRANSFER AS PART OF THE SALE OF OUR BUSINESS
If we sell part or all of our business, customer personal information may be one of the transferred business assets. If this happens, your information may be disclosed to any successors of our business for them to use for the purpose set out in this Policy.
Legal basis: Legitimate interest
UPDATING YOUR INFORMATION
Please ensure you provide us with accurate information, update your personal information or tell us if it changes or is inaccurate. You can update your details, for example your email address, in your account settings or an equivalent section if you are a subscriber. You may also email our Customer Services team at firstname.lastname@example.org.
PREFERENCE CENTRE: CONTROLLING DIRECT MARKETING AND OTHER COMMUNICATIONS
You can change your mind about receiving direct marketing or other communications you receive from us, such as bulletins and other information about your chosen products and services (for example, your Times+ subscription or one of our campaigns) by changing the settings in your preference centre or by following the unsubscribe instructions in the relevant communication.
There may be some types of communication that you receive that cannot be controlled through your preference centre, but you will still be able to opt-out by following the instructions in the communication itself.
WITHDRAWING CONSENT FOR PROCESSING
Where we rely on your consent to process your information, you have the right to withdraw that consent at any time. In some instances, we may have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent, we may not be able to provide the product or service you have requested.
STOPPING BROWSER POP-UP NOTIFICATIONS
If you have pop-up notifications enabled on your desktop, you can use the following instructions to opt out.
Google Chrome – Click the 3 dots at the top right > Select settings > advanced > privacy and security > content settings > notifications > click the three dots next to the websites that are in the “allowed” category > click Remove.
Safari – Choose Safari > Preferences, click Websites, then click Notifications > Find the website in the list, then select Deny.
Firefox – Click the menu button and select Options > Select the Privacy & Security panel and go down to the Permissions section > Click the Settings using the button next to Notifications > Select the website > Click Remove Website
Microsoft Edge – Click the three dots button in the top-right of the browser window > Click settings > Click View advanced settings > Under Notifications, click Manage
CONTROLLING DATA SUPPLIED BY PARTNERS
Experian – We use Experian to make the content and advertising shown on devices that you might use or that may relate to the same household more relevant and useful. Experian may also provide insight reporting as part of their service.
You have a choice about whether or not you want your information to be used in this way. Please see the section below on Controlling your Information. This will not stop you from seeing content about our products and services when you visit our websites, but it will mean that the content you do see may not be as relevant to you.
CONTROL OVER DATA MATCHING
If you would like to opt out of data matching with our commercial partners, please contact us. You will need to provide us with relevant information in order to identify you.
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (port) this data to another controller. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
To exercise any of these rights, please contact us using the contact details below. These rights may be restricted by law, for example we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.
If you have unresolved concerns and you live in the EU/EEA, you have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred. In the UK, you also have this right and you may contact the Information Commissioner’s Office.
OUR INTENDED AUDIENCES
Our websites and apps, products and services are not aimed at anyone under the age of 18. We do not intentionally target, create interest segments, or otherwise process personal data relating to anyone under the age of 18.
“DO NOT TRACK” BROWSER SETTINGS
If you choose to turn on the “Do Not Track” setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to request that they stop tracking your activity. Currently our websites and apps are not designed to respond to “Do Not Track” signals.
If you wish to get in touch with us, please write to us at email@example.com.
OR Data Protection Enquiries, Customer Services Department, News UK, 1 London Bridge Street, London, SE1 9GF.
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