Privacy

Herald Media Network Limited. Online Privacy Policy
EU-Specific Privacy Policy
Last Revised: June 25th, 2018

Your Privacy is Serious Business to Us!
Maintaining the privacy of our website visitors and mobile application users is very important to us. Because we gather information about you, you need to know:
The kinds of information we collect and why we collect it;
How we use that information; and
How you can update that information or limit or control how it is used.
This privacy policy (“Privacy Policy”) describes how Herald Media Network Limited. (“HMN”) with registered address at 156 Brompton Road, Knights Bridge, London, SW3 1HW, United Kingdom, collects, uses and shares information you provide when using our Service, including your personal information. The term “Service” includes the websites www.britishherald.com and www.britishherald.news, together with any subsites, sub-domains, mobile and software applications, services, features and/or content associated therewith (collectively, “our Websites”). For purposes of this Privacy Policy, the terms “we,” “us” and “our” refer to HMN and “you” refers to you, as a user of our Service.
We’ve tried to keep this Privacy Policy simple, but if you’re not familiar with any of the terms used or have any questions, contact us at mail@britishherald.com. Your privacy matters to us at HMN, so whether you are new to our Service or are a regular or longtime user, it is important that you take the time to carefully read our Privacy Policy, so you can understand our practices as relates to your information.
HMN is the data controller of your personal information for the purposes of the General Data Protection Regulation.

1. The Kinds of Information We Collect.
1.1 We collect information to provide better services to all of users of our Service, including determining what types of editorial content and what services offered on our Service are of the most interest and relevance to you.
1.2 We collect information about you (“your personal information”) from the following two sources:
The information you give us (“HMN Profile Information”). Many of our services require that you create an account. When you do, we’ll ask for personal information, like your name, email address and telephone number. You may also provide us with personal information when you participate in discussion boards or other social media functions on any of our Websites, enter a competition, promotion or survey, sign up to a newsletter and when you report a problem with any of our Websites. Where we indicate that the information is mandatory, it is required to enable us to fulfill a contract with you and, if you do not provide the mandatory information, we will not be able to provide you with the applicable service.
The information we collect from your use of our Service (“HMN Use Information”). This information relates generally to what editorial and advertising content you view, and the services you use that we and our third-party providers offer. We collect the following HMN Use Information:
Device Information. We collect information about the devices you use to access our Service, such as hardware settings, browser type and version, browser language, browser plug-in types and versions, operating system and platform, time zone setting and the date and time of Service requests.
Log Information. When you use our Service, we automatically collect and store certain information in server logs, which automatically record certain information when you use our Service, including the following:
(a) details about how you use our Service, such as your search queries, the full referral Uniform Resource Locators (URL) clickstream to, through and from any of our Websites (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from any of our Websites;
(b) your Internet Protocol (IP) address, which is the number assigned to an Internet connected device such as a tablet or smartphone and used to identify the geographic location of that device; and
(c) cookies that uniquely identify your browser and collect information about how our visitors interact with our Service, as well as help us identify problems such as error messages from certain pages. A cookie is a small file containing a string of characters that is sent to your computer or other device when you visit our Service. When you visit our Service any time thereafter, the cookie allows our Service to recognize your browser and to store information about your user preferences and other personal information.
Location information. When you visit our Service, we collect and process information about your actual location. We use various technologies to determine location, including IP address.
Local storage. We collect and store information (including personal information) locally on your device, using mechanisms such as browser web storage (including HTML 5), which allows for data to be stored on a browser even after the browser has been closed and the reopened, and application data caches, which allow for data to be stored on your device, enabling an application to run without an Internet connection and to load content faster.
Collection and Storage technologies. We and our partners use various technologies to collect and store information when you access our Service, including by using cookies and tracking pixels, to identify your browser or device. We also use these technologies to collect and store information when you access our Service and interact with the content and services we offer, such as advertising services.

2. How We Use Information We Collect.
2.1 We use the information we collect from your use of our Service in order to provide you with meaningful editorial and advertising content and to offer you relevant services, as well as to maintain, protect and improve your overall experience. In particular, you may choose (i) to subscribe to any of our electronic newsletters, (ii) to receive “special offers” by HMN and its various service providers, and (iii) to receive franchise and business opportunity information from selected advertisers, and we will use your information for these purposes provided you have given us your consent. You may also choose to submit questions or comments in response to editorial content on our Service, in which case we will process your information to comply with your request. In each of those instances we will ask you to provide, and we will collect and store, certain personal information such as email address, zip code, telephone number and, where necessary to comply with your request, information about your business. If we ask you for, and you give us, your consent, HMN and its various advertisers and other service providers will use that information to send you promotions and other communications concerning business opportunities, products or services. You can remove yourself from any such electronic newsletters and otherwise stop receiving any further promotions and other commercial communications by following the “unsubscribe” directions included with each newsletter or, in all of the above instances, by sending an email with the word “unsubscribe” in the subject line to mail@britishherald.com

2.2 We may use the name you provide for your HMN Profile across all of the services we offer that require an HMN Account, which is where we maintain the information you provide. In addition, we may replace past names associated with your HMN Account, so that you are represented consistently across all our services.

2.3 When you contact HMN, we retain a record of your communications to help solve any issues you are facing, or to maintain a record to assist with legal claims. We will keep these records for a period of no more than 6 years. Provided you have consented thereto, we may use your email address to inform you about the services offered on our Service, such as letting you know about upcoming changes or improvements.

2.4 We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services. You can reset your browser to reject all cookies or to indicate when a cookie is being sent. But you need to know that you may not be able to access or use some features and services on our Service without cookies. A pixel tag is a type of technology, which is placed on a website or within an email and used for the purpose of tracking activity on a website; and we use pixel tags in combination with cookies. For further information about how we use and collect cookies, see our separate cookie policy located at Entrepreneur.com Cookies Policy.

2.5 We share your information with third parties in the circumstances set out in Sections 3 and 10 below.

2.6 We do not track our users across third-party websites and thus do not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain website browsers allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

2.7 We comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union (“EU”) to the United States (“U.S.”). We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certification, please visit . We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission in respect of our self-certification of compliance with the Privacy Shield framework. We may be liable under the Privacy Shield Principles if a third party processes personal information in a way inconsistent with those Principles, unless we can prove that we are not responsible for the event giving rise to damage.

3. Why We Share Your Information with Third-Party Advertisers.
We share your information with third-party advertisers for the reasons explained below. (For each reason your information is shared, we have identified the Controller and/or Processor of that information. The “Controller” is the entity, which stores the information and has control over your ability to unsubscribe from having that information tracked. The “Processor” is the entity that processes your information, in order to fulfill the purpose(s) for which that information is shared.)

a. To inform a prospective advertiser or its agency that you are visiting one of our Websites, so that the Website can solicit bids for the opportunity to show an ad to you.

b. To combine your browsing habits with data the advertiser may have already collected about you (and infer further insights about you), so that the advertiser can select relevant ads for you. These ads may be ads for products/services you have shown in interest in previously. This profile may include your income bracket, age and gender, habits, social media influence, ethnicity, sexual orientation, religion, political leaning, etc.

c. To use your browsing habits to build or improve a profile about you, in order to sell information to partners for online marketing, credit scoring, insurance companies, background checking services, and law enforcement. This profile information may include your income bracket, age and gender, habits, social media influence, ethnicity, sexual orientation, religion, political leaning, etc.

d. To identify whether you are the kind of person that the advertiser may want to show ads to.

e. To combine your browsing habits with data the advertiser may have already collected about you (and infer further insights about you) so that they can select relevant ads for you. These ads may be for products you have shown interest in previously. This profile may include your income bracket, age and gender, habits, social media influence, ethnicity, sexual orientation, religion, political leaning, etc.

f. To monitor your behaviour on websites, in order to determine if you have viewed or interacted with an ad.

g. To determine whether you have purchased any of the advertiser’s products or services following your viewing of or interaction with an ad that it has paid for.

h. To combine your browsing habits with data the advertiser may have already collected about you (and infer further insights about you), to verify that you are human rather than a “bot” attempting to defraud advertisers. This profile may include your income bracket, age and gender, habits, social media influence, ethnicity, sexual orientation, religion, political leaning, etc.

i. To record the number of times you have viewed each ad, to prevent a single ad being shown to you too frequently.

j. To combine your browsing habits with data the advertiser may have already collected about you (and infer further insights about you) to understand how you and people similar to you browse the web. This profile may include your income bracket, age and gender, and habits.

4. Advertising on Our Service.
The advertising you see on our Service is determined by a number of factors relating to relevance, including (i) your approximate geographical location based on your IP address and (ii) the subject matter you view on our Service. For example, if you are viewing an article about physical health, you may see ads concerning exercise equipment. We detect the use of ad blockers and store that information, in order to help us understand your use of our Services; but we do not restrict you use of our Service if you use ad blockers.

5. Privacy and Choice.
People have different concerns about privacy. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how that information is used. You may set your browser in its “options” or “preferences” feature, in order to warn you before accepting cookies or to disable all cookies entirely. However, it is important to understand that many of the services we provide on our Service and to our Service users may not function properly if your cookies are disabled.

6. Minors and Children under Age 16.
HMN does not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register to use our Service. No one under age 16 is allowed to provide any personal information to HMN or on our Service. In the event that we learn that we have collected personal information from a child under age 16, we will promptly delete that information. If you believe that we might have any information from or about a child under age 16, please contact us at mail@britishherald.com

7. Where We Store the Information.
The personal information that we collect from you will be transferred to, and processed in, the United States by HMN. We comply with the U.S. Department of Commerce’s EU-US Privacy Shield, and we have certified that we adhere to the EU-US Privacy Principles of Notice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation. For more information about the EU-US Privacy Shield Framework, please visit the U.S. Department of Commerce’s Privacy Shield website.

8. The Information You Share.
Our Service allows visitors to share information with others, such as comments on editorial content and information shared via social media. When you share information, it may as a result become accessible to others through such mechanisms as search engines. We cannot be responsible for how others, with whom you may share information, may use that information.

9. Updating Your Personal Information.
It is our policy that, whenever you visit our Service, you are able to access your personal information, which is information identifying you such as name, email address or any other information which can reasonably be expected to identify you. If that information is incorrect, you can contact us and we will update it or delete it – unless we have to keep that information for legitimate business or legal purposes, in which case it will be retained for the periods specified in this Privacy Policy. When updating your personal information, we may ask you to verify your identity before we act on your request.
Where we can provide information access and correction, we will do so at no cost to you, except where it would require a disproportionate effort. We aim to maintain our Service in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our Service, there may be a delay before we delete residual copies from our active servers and remove information from our backup systems.

10. The Information We Share.
We do not transfer personal information to companies, organizations and individuals outside of HMN except as described in this Privacy Policy.
10.2 We share your information with selected recipients. These categories of recipients include:
provided you have consented, advertisers and advertising networks, including Google and Rubicon, located in the United States, that require the data to select and serve relevant ads to you and others;
analytics and search engine providers including Google® services located in the United States that assist us in the improvement and optimization of our Websites;
Nielson, as explained in Section 1.2c above;
provided you have consented, third parties to whom we make available for rental a list of those registrants who have expressly provided us with their permission to receive third party information and offers as part of their user profile; and

10.3 We will also share personal information with companies, organizations or individuals outside of HMN when we have your consent to do so.
10.4 Other than the circumstances set out above, we will share personal information with companies, organizations or individuals outside of HMN if we have a good-faith belief that access, use, preservation or disclosure of that information is reasonably necessary to:
comply with applicable law, regulations, legal process or enforceable governmental request;
enforce any of our applicable Terms of Service, including any potential violations;
detect, prevent, or otherwise address fraud, security or technical issues; or
protect against harm to the rights, property or safety of users of our Service or service providers, as well as the general public and HMN as required or permitted by law.

10.5 We also may share personal information with a buyer or other successor, in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of HMN’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by HMN about our Service users is among the assets transferred.
10.6 We additionally share your information publicly and with our partners such as third-party content providers, advertisers or connected sites, but in a manner which does not reveal your personal information and which is aggregated with other user information to show usage of HMN and third-party products and services offered on our Service and trends based on such categories as age, gender, geographical origination and other demographic characteristics.

10.7 We may transfer and disclose information, including personal information, in response to lawful requests by public and governmental authorities and law enforcement agencies, including to meet national security or law enforcement requirements. In addition, we may disclose personal information to customers, vendors, service providers, public and governmental authorities and law enforcement agencies where required in order to comply with a legal obligation; when the law requires it, at the request of governmental authorities conducting an investigation; when we believe in good faith that disclosure is necessary to protect our rights; to investigate fraud; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our users or others, in all cases only if and to the extent such transfer and disclosure is permitted by applicable law.

11. The Protection of Your Information.
Unfortunately, the transmission of information via the Iinternet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to protect the information provided by, or collected about, the users of our Service, from unauthorized access, or alteration, disclosure or destruction. In particular:
We encrypt much of that information using SSL.
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to our systems and the information collected and stored therein.
We restrict access to personal information to those of our employees, contractors and agents, who need to know that information in order to process it for us, who are subject to the obligation of strict confidentiality as relates to that information, and who will be subject to discipline, including termination, if they violate that obligation.

12. Retention Periods.
12.1 We will retain your information for a period of one year after your last use of our Service, after which time your information will be automatically deleted.
12.2 You can also request that your information be deleted by sending an email request to mail@britishherald.com, which must include your name and email address with which your Website account is associated.

13. The Scope of Our Privacy Policy.
Our Privacy Policy applies to all of the services offered by HMN through its Service. However, our Privacy Policy does not apply to the any of the following:
services offered by other companies or individuals on non-HMN websites or applications, including any such websites or applications which are referenced on or linked from our Service; and
he information collected by, and information practices of, other companies, organizations or individuals, who advertise our Service, editorial or advertising content, or any of the services offered on our Service, and who use cookies, pixel tags and other technologies to serve and offer relevant ads.

14. Your Rights.
In certain circumstances, you have the right to access and receive a copy of information we hold about you, to rectify any personal information held about you that is inaccurate and to request the deletion of personal information held about you. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. You also have the right to data portability for information you provide to us – this means that you can obtain a copy of your data in a commonly used electronic format, so that you can manage and move it. You may have the right to restrict or object to the processing of your personal information by us. You can exercise your rights by contacting us at mail@britishherald.com

15. Handling Complaints from Our Service Users and Regulatory Authorities.
We regularly review our compliance with this Privacy Policy and with industry-recommended best practices, as well as applicable laws and regulations. We are subject to the investigatory and enforcement powers of the U.S. Department of Commerce and the U.S. Federal Trade Commission. In compliance with the Privacy Shield Principles, we are committed to resolve any complaints you might have about our collection or use of your personal information. In the event that you wish to make a complaint about how we process your personal information, you should first contact us at mail@britishherald.com, and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your local data protection supervisory authority. If we cannot resolve your complaint internally, we are further committed to refer such complaint to Privacy Trust, as an alternative dispute resolution provider located in the EU and U.S. If you do not receive timely acknowledgement of your complaint from us within forty-five (45) days after our receipt of that complaint or we have not addressed your complaint to your satisfaction. The services of Privacy Trust are at no cost to you. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints from the users of our Service regarding the transfer of personal information that we cannot resolve or which cannot be resolved through the services of Privacy Trust. Please note that, if your complaint is not resolved, you may have the right, under certain limited conditions, to invoke binding arbitration before the Privacy Shield Panel of the U.S. Department of Commerce and the European Commission.

16. Privacy Policy Revisions and Updates.
Our Privacy Policy may be revised from time to time, in which case the Privacy Policy you view on our Websites will be the most current version and the date of the latest such revision will be identified at the beginning of this Privacy Policy. Please check this page frequently to see any updates or changes to this Privacy Policy. We will provide you with 30 days’ notice of any substantial changes to the terms of this Privacy Policy.

17. Contacting Us.
If you have any questions, concerns or suggestions about this Privacy Policy, you may contact us at mail@britishherald.com or at the following address:
Herald Media Network Limited.
Attn.: Privacy Policy Issues
156 Brompton Road, Knights Bridge,
London, SW3 1HW, United Kingdom

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