Last updated December 2018.
Introduction & General Terms
This document (“Privacy Policy”), in combination with the Cookies Policy and Competition rules, make up our commitment to protecting the personal information we hold about our customers, prospective customers, newsletter subscribers, competition entrants, website users or any other data subject whose personal information we hold. Personal information as outlined in this policy is being processed by FX Guys (“we”, “our”, “us”, “FX Guys”). In the event of any part of FX Guys either being sold or going into receivership, we reserve the right to continue to share your data to third parties in accordance with the latest preferences you have provided. You will be informed should any change of ownership occur, and the new owner will manage your personal information preferences.
Our Commitment to you
We are committed to managing & safeguarding your personal information in accordance with current legislation and best practice. Our aim is to be responsible, relevant and secure when using your data. Whenever you provide personal information we will treat that information in accordance with this Privacy Policy. We will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our ‘Legitimate Interests’. We endeavour at all times to keep your data accurate and secure, and to honour your data preferences with regard to receipt of direct marketing e.g. postal communications, email, mobile messaging and telephone calls.
We operate websites that may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies and are also likely to use cookies, and we, therefore, urge you to review them. They will govern the use of personal information you submit when visiting these websites, which may also be collected by cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We may use third-party suppliers to provide part of our service to you. In some circumstances, these providers may be based in countries outside the European Economic Area whose laws provide for a different standard of protection for your personal information than that provided under UK Law. In such circumstances:
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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• 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. For further details, see European Commission: EU-US Privacy Shield.
Your personal data will not be disclosed to state institutions and authorities except if required by law or other regulation. Before we release data on this basis, we will ensure that the information is being provided to a genuine and properly authorised investigation.
We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to email all of our registered users to make sure that they are informed of such changes. However, it is your responsibility to check this Privacy Policy before each use of the Website.
Who we are
FX Guys, operate in excellence: Current Affairs, Investment, Technology, Automotive and Lifestyle, all of which are governed by this Privacy Policy.
What Data we collect
When you send us information, talk to us over the phone, submit an online form or when you visit one of our websites, we may collect both personal and pseudonymous data about you.
When we talk about personal data we mean any information that can identify you as an individual, such as your name and postal address. Pseudonymous data doesn’t identify you as a person but it might be used in aggregate, for instance when you participate in a survey or when we analyse audience interaction with our products and services.
Data you provide to us
When you participate in, access, purchase or sign up to any of our services, activities or online content, such as magazine subscriptions, newsletters, competitions or events, we receive personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, as well as information collected about your use of our services (such as when you enter our sites and how long you stay on them).
Data we buy from a third party
We occasionally purchase data from third party suppliers. The data we purchase is primarily business data. Business data may include but not be limited to a business email address, business job title and business postal address. Such a purchase may result in you receiving communications from I-D regarding your business sector or business interests without you having directly supplied your information to us. We keep clear records of the data suppliers and provide an unsubscribe option at every contact.
Data we collect through your use of our websites
We may collect information about how you use our websites or other content online, and the device(s) you use to access the services. This includes collecting unique online identifiers such as IP addresses, which are numbers that can uniquely identify a specific computer or other network devices on the internet. Anonymous data will be recorded for the purpose of reporting web traffic statistics, advertisement ‘click-throughs’, and/or other activities on our sites. We may receive information about you from any third parties we may partner with through the use of cookie technologies to personalise advertisements for goods and services.
How we use your data
We may use the information you share with us and the information we collect through your use of our sites in the ways described below and as described at the time of capture.
Competitions & Prize Draws
We will use the details you have shared to manage your entry to any competition or prize draw. This may include your name, e-mail address and telephone number. We shall use such information to notify you if you are the winner. Your data will be retained for the period of the competition only, and will not be added to any marketing lists unless you have consented to this, and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of your prize.
Newsletters
We will use the details you have shared to send you the newsletter to which you have subscribed. We will not add them to any marketing lists unless you have consented to this. We will provide a way for you to unsubscribe on every newsletter we send to you. Details you share with us for the purpose of newsletter subscription will never be shared with a thirbd party.
Events
We will use the details you have shared to manage your registration and entry into our event. This may include contact via telephone, email, SMS and post with information relating to the event you have registered to attend. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of the event.
Magazine Subscription
We will use the details you have shared to manage your subscription to our magazine, which includes sending the magazine, managing access to any digital version, taking secure payments, to fulfil any gift that was offered at the time of purchase, to handle any customer query you may have and to contact you via telephone, email, SMS and post with information relating to your magazine subscription. e.g. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with third parties where we have appointed them to manage specific aspects of your magazine subscription.
Customer Services
We will use the information you provide to deliver customer services related to your purchase and to respond to inquiries or requests that you direct to us. Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with third parties where we have appointed them to manage specific aspects of your customer care.
Research
We may use the information you provide to invite you to participate in surveys and focus groups about our products, advertisers and services. Participation is always voluntary and the answers you provide are anonymous and aggregated to support our learnings and inform changes we can make to improve our products and services. Your data will not be added to any marketing lists unless you have consented to this and were informed at the point of capture and will only be shared with third parties where we have appointed them to manage research activity on our behalf.
Occasionally we get paid by commercial partners to carry out research on their behalf. In this situation, the data we share with them will be anonymous however we may share your personal data with specific commercial partners where they were named at the point of capture and where you agreed to the sharing of your personal data with them.
Direct Marketing
We may use the details you share with us to send you offers and promotions by email, post, telephone or SMS wherever we have legitimate interest grounds to do so and where you have not objected. We will provide a way for you to opt-out of receiving marketing promotions both at the time of data capture and everytime we contact you thereafter. We won’t use your personal data for marketing purposes at all if you’ve told us not to.
Legitimate Interest
We may process your personal data on the basis of a legitimate interest after carefully considering the balance between your rights and the benefit of the purpose for which we intend to use your personal data. These legitimate interests may include: –
• Promoting similar products or services, via direct marketing activity, that we have identified may be of interest to you based on your history of interaction with us and where you have not opted out of receiving such information.
• To manage suppression and unsubscribe requests received from you.
• To invite you to participate in research surveys about our products or services to help us improve these.
• For statistical and data analytics so we can improve the products and services offered to you. To personalise and improve our services to you by using insight regarding your purchase or communication history with us.
• To identify and prevent fraudulent behaviour.
• Using your data to help find similar audiences through the use of Facebook’s audience function and Google customer match
• Identifying usage trends and determining the effectiveness of our campaigns to improve targeted advertising.
Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights.
Cookies and how we use them
“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We use cookies for a number of reasons:
Strictly Necessary Cookies – These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information
Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Functional Cookies – These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting Cookies – These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media Cookies – These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.
Analytics
The FX Guys portfolio of websites uses Google Analytics as its primary solution for tracking website visits, interactions and events. I-D uses website analytics data to help improve the way we deliver content and online experiences to visitors.
Online Advertising
Many of the FX Guys portfolios of websites show advertising to users. A certain amount of this advertising is tailored to the individual user, a practice known as “Online Behavioural Advertising” which uses cookies to discover general information about the pages you visit. This keeps many of our websites and services you use free of charge. Our advertising delivery systems and partners use the limited information available to it to serve adverts to you, which it believes are relevant. It does not collect personal information such as your name, email address postal address or telephone number.
From time to time, FX Guys may share this aggregated data with our advertising partners. This could mean that when you are on other websites you are served to advertise based on your behaviour across FX Guys titles or you may be served to advertise based on your behaviour on other sites.
Behavioural retargeting is another form of Online Behavioural Advertising that enables us and some of our advertising partners to show you adverts based on browsing patterns and interactions with the site away from our sites. For example, if you have visited the website of a car dealership you may start seeing adverts from that same dealership site displaying special offers or showing you the products that you were browsing. This allows companies to advertise to website visitors who leave their website without making a purchase.
If you want to opt out of receiving Online Behavioural Advertising this does not mean that you will no longer receive advertising when you are using our sites. It just means that the advertising you see will not be customised for you.
Our website uses JavaScript to detect the use of ad-blocking extensions for web browsers, we do not store any information on users’ devices and do not process any personal data.
Links to third party websites
When you click on advertisements or links on any of our sites, you will leave that site and go to a third-party site, which is outside of our control. When we place an advertisement on one of our sites, it does not signify that we are endorsing that advertiser’s product or service. We do not accept responsibility for the content, have no control over and our Privacy Policy does not apply to these companies, sites or content and if such third-party sites collect personal data, we cannot control how this data is processed, stored or used. We advise that you read their data collection statements, which accompany any registration and their Privacy Policies before you submit your personal information
Using our websites from outside the UK
We use servers located in the EEA to store data. When you submit your details and in whichever country you are situated you agree to the data being transferred to the EEA and processed under the terms of Regulation (EU) 2016/679 (GDPR) including any implementing data protection legislation in the UK. If you are not in agreement please do not add your personal details on the website. FX Guys makes no representation or warranty that the content and materials on the Website are appropriate or available for use in locations outside of the United Kingdom. Those who choose to access the Website or use the services from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent applicable.
How we keep your personal data secure
FX Guys’s security policies, rules and technical measures have been implemented to protect your personal information from unauthorised or improper use and from accidental loss.
All our employees and data processors that have access to, and are associated with, the processing of your personal information are legally obliged to respect the confidentiality of your data and are bound by contract to do so.
Note that some of our websites provide forums and commenting facilities where you can post information. When you do so, be aware that other visitors may collect any information you make public.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Who we share your personal data with no one
Personal Data – Your rights
Under the GDPR including any implementing data protection legislation in the UK you have the rights shown below:-
• Your right to be informed
• Your right of access
• Your right to rectification
• Your right to erasure
• Your right to restrict processing
• Your right to data portability
• Your right to object
• Your rights in relation to automated decision making and profiling.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the How we use your data section of this Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
If you wish to exercise any of these rights or simply wish to find out what information, if any, we hold that relates to you, you must make your request in writing.
You can help us to process your request quickly by providing us with information that will help us identify records we hold that relate to you. For example your name, address, email address, telephone number, subscriber id or in the case of information captured via cookies, the IP address of the device you have used.