- About Communicorp Media
- The information we collect
- How we use the personal data we collect
- Your rights
- Information collected for journalistic purposes
- Sharing and Disclosing Your Personal Information
- Our commitment to security
- Transfer Outside the EEA
- How Long We Keep Your Data
- Children’s Privacy
Communicorp Media is based in Ireland. Its subsidiaries include:
- Today FM
- Spin 1038
- Spin Southwest
Communicorp Media will never collect any unnecessary personal data from you and will not process your information in any way, other than as specified in this notice. The personal data that Communicorp Media collects varies depending on the online activity you access, below lists the information Communicorp Media may collect when you register for a newsletter, take a survey, enter a competition, register with our apps or sites, or if you make direct contact with one of our companies:
- - Name
- - Contact Phone Number (where required for a competition entry or where you contact the station via SMS or Whatsapp)
- - Home Address (where required for a competition entry or to reply to direct contact)
- - Confirmation that you’re over 18 (where required for a competition entry)
- - IP Address (To allow us geo-fence audio streams, this data is not used beyond this purpose)
- - Information contained in a curriculum vitae (where sent directly to the station)
- - subscribe (opt-in) to a newsletter,
- - enter a competition
- - participate in an online survey
- - contact the Communicorp Media directly
- - register on our sites or apps
- - Station Newsletter Subscriptions are based on Consent.
- - Direct Marketing emails are based on either Consent or Legitimate interest, where we use legitimate interest we will have completed an legitimate interest assessment where we conduct a balance test between our legitimate interests and your privacy rights.
Communicorp Media takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. We do not employ automated decision making methods to any of your personal data under our control.
- The purposes and reasons for processing your personal data are detailed below:
- - We collect your data to administer a service which you have subscribed to and given consent for your personal data to be processed, this includes Station Newsletter and/or promotional material.
- - We collect your data as part of a competition entry to allow us contact you regarding the competition, this data is processed based on consent.
- - We collect personal data to administer your personalised preferences such as news content or preferred music and services.
- - We collect your personal data that you provide us with when you contact us directly to respond to your specific inquiry or to administer the relevant site activity where we have a legitimate interest.
- - We automatically capture your IP addresses to geo-fence our content.
- - Comply with legal regulatory requirements and legitimate business purposes.
- - To help us to monitor, analyse and improve Communicorp Media . This information helps us to understand which Communicorp Media content, products and services are most interesting, enjoyable and useful to our users, and if they are shared via social networks. The information also helps us to identify when errors occur within the digital products and services within Communicorp Media and test different versions of a page or feature to see which one works best. All of which helps us improve our digital products and services for our users.
- - We can create a more tailored experience by looking at the information we have about you. For example, we will do this by making programme recommendations or telling you about relevant Communicorp Media events in your area.
- - To inform the way we commission future content at Communicorp Media. We will use aggregated and anonymous user data to help our commissioning teams understand what type of content our users like.
- - To sell advertising on Communicorp Media.
- - We will send you information about the digital products and services within Communicorp Media or other marketing activities, but only where you have signed up to receive these from us. Similarly, sometimes, third party partners will want to send you information about products and services, but will only do so if you have agreed to receive them by ticking an opt-in box associated separately with a competition partner.
- - We will email you occasionally about the digital products and services within Communicorp Media that you have signed up for (for example, to provide you with password reminders or to contact you about content you have submitted to us via our digital products and services) so that we are able to deliver these services to you. We may also invite you to participate in surveys from time to time to help us understand what you think about our programmes, products and services, and in turn make them better.
You have the right to access any personal information that Communicorp Media processes about you and to request information about:
- - What personal data we hold about you
- - The purposes of the processing
- - The categories of personal data concerned
- - The recipients to whom the personal data has/will be disclosed
- - How long we intend to store your personal data for
- - If we did not collect the data directly from you, information about the source
- You have the right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- You have the right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- You have the right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- You have the right of portability – you have the right to have the data we hold about you transferred to another organisation.
- You have the right to object – you have the right to object to certain types of processing such as direct marketing. (eg Newsletter Opt-out)
- You have the right to object to automated processing, including profiling
Under Article 85 of the GDPR (EU 2016/679) material acquired and used for journalistic purposes is exempt from certain Articles of GDPR, these include Chapter II (principles) other than Article 5(1)(f), Chapter III (rights of the data subject) Chapter IV (controller and processor obligations), Chapter V (transfer of data), Chapter V1, Chapter VII and Chapter IX. Please note that the requirement to process personal data in a manner that ensures appropriate security remains when processing for journalistic purposes.
Communicorp Media takes your privacy seriously, we employ appropriate technical and organisational security measures to prevent unauthorised access, alteration, disclosure or destruction of your information. We use the following industry standard methods to protect your data:
- - SSL (HTTPS) Across all websites
- - Encryption
- - Enterprise firewalls
Communicorp Media utilise services (or parts of them) that may be hosted/stored outside the EEA which means that we may transfer any information which is submitted by you through one of our digital services to outside the European Economic Area ("EEA") for the below purposes:
- - Newsletter Subscription
- Data Processor is MailChimp, more info here https://mailchimp.com/legal/privacy/ MailChimp have a proven track record in providing email marketing services across the globe. They have are Trusted Certified and are Certified with the EU-US Privacy Shield Framework.
- - Competition Forms and Surveys
- Data Processor is Wufoo.com, more information here https://secure.wufoo.com/privacy/
- Wufoo are Certified with the EU-US Privacy Shield Framework.
- - Events Registration Forms
- Data Processor is Eventbrite, more information https://www.eventbrite.ie/support/articles/en_US/Troubleshooting/eventbrite-privacy-policy?lg=en_IE
- Eventbrite are Certified with the EU-US Privacy Shield Framework.
- - Streaming Services
- Data Processor is Triton Digital, for more information https://www.tritondigital.com/eu-privacy-policy
Communicorp Media only ever retains personal information for as long as is necessary to provide a service you have consented to or to adhere to certain warranties or proof of delivery for competition winners. Where you have subscribed to a Newsletter we will retain your data until you unsubscribe or the Newsletter is canceled. We include unsubscribe links on all newsletter emails. Where you have registered for an event we’ll retain your personal data for 13 months after the event as a record of attendance. Where you enter a station competition we’ll retain your data for 12 months after the successful competition of the prize or event in the case of tickets. We have retention policies in place to meet these obligations.
These Services do not address anyone under the age of 16. We do not knowingly collect personally identifiable information from children under 16. In the case we discover that a child under 16 has provided us with personal information, we will delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
In the event that you wish to make a complaint about how your personal data is being processed by Communicorp Media, or how your complaint has been handled, you have the right to lodge a complaint directly with the Data Protection Commissioner and Communicorp Media. The details for each of these contacts are:
- Data Protection Commissioner
- Canal House
- Station Road
- R32 AP23
- Co. Laois
- Phone: 1890 252 231
- Fax: +353 57 868 4757
- Communicorp Media
- Privacy Officer
- Marconi House
- Digges Lane
- Dublin 2
- Co Dublin
- Phone: +353 1 8049000