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Our Privacy Policy

Introduction

 

This Privacy and Cookie Policy explains what information we may collect about you, as well as how we collect, use, share, disclose or otherwise process that personal information. It also provides information about your data protection rights.

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We use your information to provide you with the products and services you request, as well as to understand how and why our audiences engage with us. This allows us to personalise content, show you relevant adverts that supports our journalism, articles, content, and to generally improve your experience of our products and services.

 

About Us

 

The Aurora Press Group Limited (together “The Aurora Press Group Limited”, “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 product or service you have interacted with or to which title you have subscribed as set out below.

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The Aurora Press Group Limited will use your information in accordance with this Policy when you engage with its products and services.

 

How We Collect Your Information

 

Registration, Forums, Comments, 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, subscribe to one of our 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:

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  • 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 your 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 have 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.

  • We may also collect information from cookies placed on your device and store other cookies and technologies. See the section on Cookies below for more information about our use of cookies

  • 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.

 

Social Login

 

If you log in to our websites or online services via a third-party site, such as Facebook, that site may pass information to us, such as user ID, name associated with the ID, email address and location, plus other information as described in that website’s privacy policy. Our websites may also return information about you to that social networking site regarding your log in, such as which of our websites and pages you visit and use, and your use of social media services on our website.

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If you log in with or connect to your account using social media (Facebook, Twitter, etc), the social media service’s use of the shared information will be governed by their privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your Aurora Press Group Limited account, and do not participate in social sharing on our website.

 

Posts, Comments, And Interaction

 

If you correspond with any of our titles, or interact with other customers or audience members or our staff, for example by using polls, comments, email, 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.

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If you take part in any reader forums, send us letters for publication, 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 (including comments on articles), will be viewed by others (including search engines, subscribers, readers), 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, shared, and used by third-parties.

 

Polls And Reader Forums

 

We collect personal information, including biographical details, preferences and other declared personal information about you, when you provide it to us via reader forums or polls (which could be on any medium or platform, including social media). 

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These uses may include:

  • Measuring engagement with polls. 

  • Creating editorial content based on the aggregate results of polls. 

  • Using aggregate engagement metrics to inform commercial client briefs. 

  • Enriching user profiles to serve relevant content, create personalised content recommendations.

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User interactions with polls that touch on topics that we consider more sensitive or emotive, like those involving topics relating to wars or conflicts, crime and wrongdoing, gender-based issues etc., may be associated with individual users, but will only be used at an aggregate level for editorial and commercial insights and analysis. User engagement with these types of polls will not be used to profile individual customers for marketing or advertising purposes.

 

Other Sources

 

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 titled Controlling Your Information.

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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.

 

How We Use Your Personal Information and Our Legal Bases for These Uses

 

With Your Consent

 

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:

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  • 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:

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  • 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.

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Our legitimate interests in processing personal data include:

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  • 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.

  • To enable 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.

  • 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.

  • 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 the services our customers like, letting us focus our efforts on developing in 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. The 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 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, or interact with other customers or audience members or our staff, for example by using polls, comments, email, 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 forums, send us letters for publication 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, or watch content on devices connected to the internet such as smart TVs, advertising networks and other intermediaries that we may work with, may select, and then display adverts on your device.

  • 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.

  • Provide co-branded services, events and features: We may offer co-branded services or features, such as competitions or other promotions, together with a third party and may share the information you provide to us with that third party. These co-branded services may be hosted by us or by the third party. It will usually be obvious where this is the case and will provide you with additional information where required. Please remember that where we share your information with these third parties, that they will use your information in accordance with their privacy policy.

  • 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 may be 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 customer enquiries and contact 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.

  • 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 and Protect Our Rights

 

There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims.

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.

 

Other Considerations

 

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.

 

How We Share Your Information

 

Sharing With Commercial Partners

 

We may disclose your personal information to third parties, 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. The legal basis being: performance of a contract, legitimate interest, consent.

 

Advertising Partners

 

We may share personal data collected on our websites and apps with our advertising partners, which includes Wix who act as domain host, Google AdSense, 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 these entities for these purposes, you can change your cookie settings when you visit our websites. You may still receive advertising when you use our products and services, but this may not be tailored to you.

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When you enter your email address on our website (either to log in, or to sign up to a newsletter, or similar), we may share personal data or other information that we collect from you, such as your email (in hashed, pseudonymous form), mobile advertising identifier, IP address, or information about your browser or operating system, with Google AdSense who may use this information to create an online identification code for the purpose of recognising you on your devices. This code does not contain any of your identifiable personal data. We place this code in our first party cookie and allow it to be used for online and cross-channel advertising. It may be shared with our advertising partners and other third-party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc).

 

Detailed information on Google AdSense’s data processing activities is: Privacy Policy – Privacy & Terms – Google

Detailed information on Wix’s data processing activities is: About Privacy | WIX


You have the right to withdraw your consent or opt-out to the processing of your personal data at any time. 

 

Sharing With Our Services Providers

 

We may pass your information to our processors – companies that we use to provide services on our behalf, for example for home delivery services, 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. Our legal basis: performance of a contract, legitimate interest, and consent.

 

Sharing With Governing Bodies

 

We may submit audience figures to governing bodies such as The Publishers Audience Measurement Company (PAMCo) who are the governing body which oversees audience measurement for the published media industry. While this may generally be achieved through aggregate information, we may use information that could identify individuals. Our legal basis: legitimate interest, and consent.

 

Data Transfers

 

When you provide information to us, we may transfer your information to companies and processors outside the UK 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. 

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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: info@theaurorapress.co.uk. Our legal basis being: performance of a contract, legitimate interest, and 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. Our legal basis: legitimate interest.

 

Controlling Your Information

 

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 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:

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For Google Chrome Browser:
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.

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For Safari Browser:
Choose Safari > Preferences, click Websites, then click Notifications > Find the website in the list, then select Deny.

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For Safari Browser:
Choose Safari > Preferences, click Websites, then click Notifications > Find the website in the list, then select Deny.

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For Firefox Browser:
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.

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For Microsoft Edge Browser:
Click the three dots button in the top-right of the browser window > Click settings > Click View advanced settings > Under Notifications, click Manage.

 

Other Rights

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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 do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

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To exercise any of these rights, please contact us at info@theaurorapress.co.uk. 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.

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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.

 

California Residents

 

California “Shine the Light” Law  

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Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us at info@theaurorapress.co.uk.

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For all requests, you must put the statement “CA shine the light request” in the subject field of your request and include the name of the data controller to which you are requesting the information. You must also include your name, contact details, address and other identifiers that will help us locate your information.

 

Notice To California Residents

 

The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide certain rights to residents of California. This section of our Policy applies if you are a natural person who is a resident of California (“California Consumer”) and you use our products or services. Certain terms used below have the meanings given to them in the CCPA and CPRA. The CCPA and CPRA shall be collectively referred to herein as the “CPRA”.

 

Categories Of Personal Information We Collect About You, Why, And How

 

Summarised below are the categories of personal information we may collect about you over the past twelve months, depending on how you interact with us. The following table also describes how we collect and use such categories of information.

You can find further information about the categories of personal information we may have collected about you, as well as the sources and method of collection, in the ‘Collection of Your Information’ section of this Policy. The precise categories collected and purposes used will depend on which of our products and services you interact with.

 

Categories of information collected - Identifiers

Purposes of collection - Performing Services, Auditing, Short-term Use, Data Security & Fraud Prevention, Repairs, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Affiliates & Partners, Service Use.

 

Categories of information collected - Commercial Data

Purposes of collection - Performing Services, Auditing, Short-term Use, Data Security & Fraud Prevention, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Affiliates & Partners, Service Use.

 

Categories of information collected - Financial Data

Purposes of collection - Performing Services, Auditing, Data Security & Fraud Prevention, Repairs, Quality and Safety.

Sources of personal information - Directly from you, Affiliates & Partners.

 

Categories of information collected - Internet Data

Purposes of collection - Performing Services, Auditing, Short-term Use, Data Security & Fraud Prevention, Repairs, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Affiliates & Partners, Service Use.

 

Categories of information collected - Geolocation Data

Purposes of collection - Performing Services, Auditing, Short-term Use, Data Security & Fraud Prevention, Repairs, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Affiliates & Partners, Service Use.

 

Categories of information collected - Sensory Data

Purposes of collection - Performing Services, Auditing, Short-term Use, Data Security & Fraud Prevention, Repairs, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Service Use.

 

Categories of information collected - Inference Data

Purposes of collection - Performing Services, Auditing, Short-term Use, Data Security & Fraud Prevention, Repairs, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Affiliates & Partners, Service Use.

 

Categories of information collected - Protected Data

Purposes of collection - Performing Services, Auditing, Data Security & Fraud Prevention, Repairs, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Affiliates & Partners, Service Use.

 

Categories of information collected - Profile Data

Purposes of collection - Performing Services, Auditing, Short-term Use, Data Security & Fraud Prevention, Repairs, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Service Use.

 

Categories of information collected - Associated Data

Purposes of collection - Performing Services, Auditing, Short-term Use, Data Security & Fraud Prevention, Repairs, Research and Development, Quality and Safety, Commercial Interests.

Sources of personal information - Directly from you and your devices, Affiliates & Partners, Service Use.

 

Categories of Personal Information Collected:

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  • Identifiers (such as your contact information (name, email address, postal address, phone number)), unique personal identifiers (such as device ID, cookies, IP address) (“Identifiers”).

  • Commercial information (such as transaction data, viewing history or purchase history) (“Commercial Data”).

  • Financial information (such as credit card information) (“Financial Data”).

  • Internet or other network or device activity (such as browsing history or app usage) (“Internet Data”).

  • Geo-location information (such as city, state and zip code associated with your IP address) (“Geolocation Data”).

  • Sensory information (such as audio or visual information) (“Sensory Data”).

  • Inference information about you (such as preferences) (“Inference Data”).

  • Legally protected classifications (such as gender, marital status) (“Protected Data”).

  • Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviours, attitudes) (“Profile Data”).

  • Information that identifies or can be reasonably associated with you (“Associated Data”).

 

We do not knowingly collect or use the personal information of consumers under the age of 18. We do not process sensitive personal data as defined in the CPRA.

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Retention Of Personal Data

 

We will retain the categories of information identified for as long as is reasonably necessary for the purposes for which they were originally collected, as laid out in this policy, or while there is a legitimate reason for doing so.

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Business or Commercial Purpose for Which We Collected or Disclosed Personal Information:

 

  • Performing services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, responding to complaints and data subject rights requests, defence of legal claims, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services (“Performing Services”).

  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance (“Auditing”).

  • Short-term, transient use, including, but not limited to, the contextual customisation of ads shown as part of the same interaction (“Short-term Use”).

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”).

  • Debugging to identify and repair errors that impair existing intended functionality (“Repairs”).

  • Undertaking internal research for technological development and demonstration (“Research and Development”).

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us (“Quality and Safety”).

  • To advance our commercial or economic interests, such as by inducing another to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction (“Commercial Interests”).

 

Categories Of Sources From Which We May Collect Personal Information

 

The sources from which we may have collected personal information about you or your use of the Services are set out in the ‘Collection of Your Information’ section of this Policy. These include information collected:

  • Directly from you and your devices.

  • From other sources (such as our affiliates and/or business partners such as commercial Partners, Analytics providers, and social media networks).

  • Through your use of the Services.

 

How We Sell/Share And Disclose Your Information

 

We will share the personal information collected from and about you over the past twelve months as discussed above for various business purposes. The information below explains the categories of information that we may share with third parties and the categories of those parties.

 

Third Parties we share information with - Third Party Partners for Marketing Purposes.

Purposes of sharing - We may share your information with partners if you participate in competitions and provide your permission for their marketing purposes. You will be asked to opt in to this.

Categories of information shared - Identifiers, Commercial Data, Inference Data, Profile Data, Associated Data.

 

Third Parties we share information with - Third Party Partners to Provide Co-Branded Products and Services.

Purposes of sharing - In some cases, we may share information with third-party partners to provide co-branded products or services.

Categories of information shared - Identifiers, Commercial Data, Financial Data, Internet Data, Geolocation Data, Sensory Data, Inference Data, Protected Data, Profile Data, Associated Data.

 

Third Parties we share information with - Third Parties for Legal Requirements and Proceedings.

Purposes of sharing - We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or government measures, and to comply with other legal obligations. We may disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.

Categories of information shared - Identifiers, Commercial Data, Financial Data, Internet Data, Geolocation Data, Sensory Data, Inference Data, Protected Data, Profile Data, Associated Data. 

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Third Parties we share information with - Third Parties for the Protection of our Services and Users.

Purposes of sharing - We may disclose information to protect and defend the rights, interests, and safety of the services, our affiliates, and their employees, contractors, and agents; to protect the security and safety of our users of the services, including when we believe disclosure is necessary to prevent physical harm or financial loss.

Categories of information shared - Identifiers, Commercial Data, Financial Data, Internet Data, Geolocation Data, Sensory Data, Inference Data, Protected Data, Profile Data, Associated Data.

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Third Parties we share information with - Third Parties in Business Transfers. 

Purposes of sharing - We may disclose information in connection with a proposed or completed corporate transaction, including for example a merger, investment, acquisition, reorganisation, consolidation, bankruptcy, liquidation, or sale of some or all of our assets.

Categories of information shared - Identifiers, Commercial Data, Financial Data, Internet Data, Geolocation Data, Sensory Data, Inference Data, Protected Data, Profile Data, Associated Data. 

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Third Parties we share information with - Third-Party Online Advertisers and Ad Networks.

Purposes of sharing - As discussed in the Cookies and Similar Technologies section of this Policy, our products and services may rely on third-party advertising technologies that allow for the delivery of relevant content and advertising on our sites and other websites you visit, and other applications you use. These technologies will collect certain information to assist in delivering such ads.

Categories of information shared - Identifiers, Internet Data, Geolocation Data, Sensory Data, Inference Data, Profile Data, Associated Data. 

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Third Parties we share information with - Internet Service Providers.

Purposes of sharing - In connection with the provision of the services, we may share information with companies that provide internet services.

Categories of information shared - Identifiers, Internet Data, Geolocation Data, Sensory Data, Inference Data, Profile Data, Associated Data. 

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Third Parties we share information with - Data Analytics Providers.

Purposes of sharing - We may share information with companies that provide data analytics services in order to operate, evaluate and improve our business.

Categories of information shared - Identifiers, Internet Data, Geolocation Data, Sensory Data, Inference Data, Profile Data, Associated Data.

 

Third Parties we share information with - Social Networks.

Purposes of sharing - We may share information about you with social networks where you have provided your permission.

Identifiers.

Categories of information shared - Commercial Data, Internet Data, Profile Data, Associated Data.

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Third Parties we share information with - Operating systems and platforms.

Purposes of sharing - We may share information with software companies that power your devices and companies that provide common tools/ information for software or apps about software or app consumers.

Categories of information shared - Identifiers, Internet Data, Geolocation Data, Sensory Data, Inference Data, Profile Data, Associated Data.

 

California Consumer Rights & Choices

 

California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:

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1.) The right to access and disclosure – You may have the right to request, twice during a twelve-month period, the following information about the personal information we have collected about you during the past 12 months.

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  • The categories and specific pieces of personal information we have collected about you.

  • The categories of sources from which we collected the personal information.

  • The business or commercial purpose for which we collected or sold the personal information.

  • The categories of third parties with whom we shared the personal information.

  • The categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

  • The specific pieces of personal information we obtained from you in a format that is easily understandable, and to the extent technically feasible, in a commonly used, machine-readable format.

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2.) The right to deletion – under certain circumstances, you may have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with applicable legal requirements. If the personal data is no longer needed for any purposes that justify its retention and we are not required by law to retain it, we will do what we can to delete, destroy, or permanently de-identify it. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

 

3.) The right to correction – you may have the right to have your personal information corrected if it is incorrect.

 

4.) The right to portability – you may have, subject to certain exceptions:

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  • The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format,

  • The right to transmit the data to another business or data controller.

  • The right to (depending on the circumstances), have us perform that transmission.

 

5.) The right to non-discrimination – we will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

 

6.) The right to opt out of the sale and sharing of your personal information – you have the right to opt out of the “sale” or sharing of your personal information. California law broadly defines sale such that it may include allowing third parties to receive certain information, such as cookies, IP address and/or browsing behaviour, to deliver targeted advertising.

 

How To Exercise Your Access, Correction, Portability, And Deletion Rights

 

California residents may exercise their California privacy rights by submitting a request by sending an email to info@theaurorapress.co.uk with ‘CCPA Action Request’ in the subject line. For security purposes, we will verify your identity – in part by asking you to verify your email address and requesting certain information from you, when you request to exercise your California privacy rights, such as address and photographic ID. 

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To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may also need to ask you for additional information to verify your identity.

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Once we have verified your identity (and your agent, as applicable), we will comply with your request, unless an exemption applies.

Where you have requested the categories of information that we have collected about you, or specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CPRA. For instance, we may not disclose financial account numbers as such disclosure may create an unreasonable risk to your personal information, your account with us, or our business systems.

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Where you have requested that we delete personal information that we have collected from you, we will inform you whether or not we were able to comply with your request. Certain information may be exempt from such requests under applicable law.

If we are unable to complete your requests fully for any of the reasons above, we will provide you with additional information about the reasons that we could not comply with your request.

 

Authorised Agents

 

You may designate an agent to make requests to exercise your rights under CPRA as described above. We will take steps to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorised to make a request on your behalf through providing us with a signed written authorisation or a copy of a power of attorney.

 

CPRA Required Disclosures for Large Scale Personal Information Processing:

 

Commencement of operation began after the calendar year, ending December 31st 2023, and as such are currently have no requests to report:

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Requests to know – 0

Requests to delete – 0

Requests to opt out – 0

Requests to correct – 0

 

The mean number of days it took us to substantively respond to these requests was as follows:

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Requests to know – 0

Requests to delete – 0

Requests to opt out – 0

Requests to correct – 0

 

How To Contact Us

 

If you are a California Consumer, to submit a request please contact us at info@theaurorapress.co.uk. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

 

Colorado, Utah, Connecticut, And Virginia Residents

 

The Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CDPA”), Virginia Consumer Data Protection Act (“VCDPA”) and Utah Consumer Privacy Act (“UCPA”) each provide certain rights to residents of Colorado, Connecticut, Virginia, and Utah, respectively. This Section of this Policy applies if you are a natural person who is a resident of the States of Colorado, Connecticut, Utah, or Commonwealth of Virginia and use our Services (each and all of whom shall be referred to collectively, as “Consumer”). This section supplements the information in the rest of this Policy but for the section aimed specifically at California residents. Certain terms used below have the meanings given to them in the respective laws.

 

Specific Processing Activities

 

De-identified or pseudonymous data – In addition to the collection of personal data as described in this policy, we process de-identified data. With regard to our processing of de-identified data, we take reasonable measures to ensure the de-identified data cannot be associated with a natural person and commit to maintain and use such de-identified data without attempting to re-identify the data, and we require all of our service providers and partners in receipt of such de-identified data from us treat the data in the same manner.

 

Consumer Privacy Rights And Choices

 

In addition to your rights of access, correction, deletion, and data portability, as described in the rest of this Policy. Consumers may have certain additional rights in connection with the personal data we collect about you, many of which are subject to exceptions under applicable law:

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  1. The right to non-discrimination- We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your rights.

  2. The right to opt out of the sale and/or processing of your personal data – You have the right to opt out of the sale of your personal data to a third party and/or the processing of your personal data for the following purposes: (1) targeted advertising and (2) profiling. 

 

How To Contact Us

 

To submit a request, please contact us at: info@theaurorapress.co.uk. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. 

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