This Privacy Notice applies to our News website (www.stv.tv/news) and our News application (“App”) (the “Services”), regardless of the platform you use to access them.
We are STV Central Limited, a company registered in Scotland (company number SC172149), with registered office at Pacific Quay, Glasgow, G51 1PQ (“STV”), the data controller responsible for looking after your personal data in line with data protection and privacy laws.
We are committed to ensuring your privacy and protecting the data we hold about you. This Privacy Notice explains how we do this and describes how and when STV collects and processes your personal data.
Please note that on specific occasions when we are collecting or processing personal data about you we may provide additional privacy notices so that you are fully aware of how and why we are using your data.
By using the Services, you are presumed to have read and understood this Privacy Notice.
Please note that we update our Privacy Notice from time to time, so please take a fresh read through every so often. If we make significant changes, we will make that clear on our Services.
This Privacy Notice is effective from 27 November 2019.
- What data is collected?
- Cookies and other tracking technologies
- Why we collect data
- How do we keep your data secure?
- Sharing of personal data
- Transfers of Data Out of the EEA
- Links to other sites
- Your rights
- Data retention
- Contact us
What data is collected?
The type of information that may be collected will vary depending on which of our Services you are accessing and includes:
Analytical Data: Information collected from cookies and other tracking methods about how you browse and use our Services including, for example, the frequency of your visits; the time you spend viewing our content; and what types of content you like most.
Technical Data: Includes internet protocol (IP) address, browser type and version, device identifiers, device advertising identifiers, location, operating system and platform; referring website addresses, date/time of visits, page view data, Internet service provider, click data, and information about your device including make, model and data connection type;
Cookies and other tracking technologies
When using our Services, Technical Data and Analytical Data will be collected by us and our authorised partners about your equipment, browsing actions and patterns by using cookies and similar technologies, only if necessary or expressly consented to by you. We do this in order to operate, personalise and serve you with targeted ads (that are more relevant to your interests) and enhance the performance of our Services and to distinguish you from other users.
We use third party advertising networks to provide some of the ads you see on our Services. Such third parties place cookies or tracking technologies which remember that you have visited a website in order to provide you with targeted ads which are more relevant to you and your interests. This is often referred to as Online Behavioural Advertising ("OBA"). Please see our Cookie Notice for more information.
Note that when you download or use our App on your mobile device or TV, information will be accessed from or stored to your device. This is done by using technologies similar to web browser cookies. These technologies carry out similar functions to web browser cookies, e.g. to enable the App to ‘remember’ you or to provide you with the content you have requested.
Please see our Cookie Notice for further details and how to manage your cookies.
Why we collect data
Data protection and privacy laws permit us to collect and use your personal data on a limited number of grounds. The key grounds upon which we rely are:
- Where we have your consent; and
- In order to comply with a legal or regulatory obligation.
Below we have set out a summary of why we seek to collect and process your personal data. We shall seek your express consent where appropriate:
- To administer and protect our Services (including troubleshooting, system maintenance, monitoring quality and security of service; support and reporting);
- To improve our Services, consumer relationships and experiences;
- To deliver targeted ads to you based on the information third party advertising parties hold about you;
- To share data with data processing companies who act on our behalf, to enable us to deliver our Services, host our data, provide ads or, other technical services to us;
- To share data with third party advertising partners.
How do we keep your data secure?
The security of your data is important to us. We have technical and operational security measures in place internally within STV, and externally with our authorised suppliers to protect the data we collect, use and store, against unauthorised access or disclosure; improper use, alteration, unlawful or accidental destruction or loss.
We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
However, please be aware that the sending of information through the internet is not completely secure. We do not guarantee the security of your data transmitted to and from our Services over the internet, and you accept the inherent security implications of using the internet.
Sharing of personal data
We share your data in the following circumstances:
When we engage data processing companies to act on our behalf from time to time to help manage your data, to provide analysis and to deliver specific functionality. We require those we share it with to respect the security of your personal data and to treat it in accordance with the law and our strict instructions. Please note that some of these companies may be either located and/or have servers which are located outside the European Economic Area (please see below for further detail).
In the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer, or new business partner.
When delivering ads to you that are more relevant to your interests.
Transfers of Data Out of the EEA
Whenever we transfer your personal data out of the EEA to certain authorised suppliers providing functionality or other services to us, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.
Links to other sites
To inform and enhance your experience when using our Services, we provide a number of links to third party websites that apply their own privacy policies. Please note that this Privacy Notice will not apply to any such third party website. We do not control such third party websites or have any responsibility for them.
You have the right to:
- Request access to a copy of the personal data we hold about you (commonly known as a “data subject access request or “SAR””).
- Request correction of any inaccurate personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with a legal obligation. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please Contact Us in the first instance.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you wish to exercise any of the rights set out above, please Contact Us in writing.
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Generally this means that we will hold your personal data on our systems for as long as you use the Services, and for a reasonable amount of time after you close your account.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We have appointed a Data Governance Manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice or you would like to exercise any of your legal rights, please contact the Data Governance Manager using the details set out below.
Data Governance Manager
STV Central Limited
Effective from: 27 November 2019