Introduction
Welcome to Newspaper Licensing Ireland Limited (“NLI”)’s privacy policy.
NLI respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when we handle it and tell you about your privacy rights and how the law protects you.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how NLI collects and processes your personal data, including any data you may provide through our website.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
NLI is a rights management organisation that facilitates the commercial use (copying) of newspaper and magazine content. We offer a range of licences that permit organisations to access, copy and share press content while ensuring that the rights of the copyright holders – the publishers – are respected.
Having regard to the nature of our activities and the fact that we deal with businesses, we process a very limited amount of personal data.
Controller
NLI is the controller and responsible for your personal data (referred to as “NLI”, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Contact details
Full name of legal entity: Newspaper Licensing Ireland Limited
Email address: info@newspaperlicensing.ie
Postal address: Clyde Lodge, 15A Clyde Road, Dublin 4, D04 YO76
You have the right to make a complaint at any time to the Data Protection Commission (“DPC”), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
Third-party links on our website
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below. We handle
- Identity Data includes first name, last name and title.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for or make arrangements in respect of a licence; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [INSERT LINK] for further details.
Third parties. We may receive personal data about you from third parties as set out below:
Identity and Contact Data from public relations companies or media monitoring organisations in connection with putting necessary licences in place; and
Technical and Usage Data from analytics providers who provide us with information regarding how users interact with our website.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances.
To enter into and perform a contract
When we enter into or are about to enter into a licensing contract it is necessary to collect personal data from you in order to put the necessary arrangements in place, including for the purpose of making arrangements for payment in connection with the licensing contract.
To comply with our legal obligations
We may process your personal data to comply with certain legal obligations to which we are subject, including to verify information provided to us for purposes including detecting and preventing money laundering and tax offences.
For our legitimate interests
We may use your personal data for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). When we use your personal data in this way, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms. Our legitimate interests include managing and operating the administrative and technical aspects of our business efficiently and effectively. This will include verifying the accuracy of the personal data that we hold and taking steps to protect your personal data against loss, damage, theft or unauthorised access.
We may use your personal data in our legitimate interest to manage our everyday business needs including accounting, internal reporting needs, market research, to progress and respond to legal claims, to ensure appropriate IT security and to prevent fraud.
We may use your personal data to update you on developments in relation to copyright licensing and/or the way in which we carry out our business, for the purpose of connecting with our clients and updating our clients and prospective clients in respect of the products and services we provide.
Marketing
We may send you marketing messages in respect of our products and services that may be of interest to you.
You can ask us to stop sending you marketing messages at any time by following the instructions on any marketing message sent to you or by contacting us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see [LINK TO COOKIE POLICY].]
Your personal data and third parties
Third Party Service Providers
We may share your personal data with third party service providers who perform services and functions at our direction and on our behalf. Such third party services providers include accountants, legal advisers, IT service providers, payment service providers, security services providers, administrative services providers and marketing agencies engaged by us.
An Garda Síochána, government or quasi-government bodies, courts and tribunals
We may share your personal data with these organisations and bodies where required to do so by law.
Potential sale or merger
If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your personal data in the same or similar way as set out in this privacy policy.
Transfers of personal data outside the EEA
We may transfer, store or process your personal data in countries outside the European Economic Area (“EEA”). Where the laws of such countries do not afford an equivalent level of protection of personal data as the laws of Ireland, we take specific steps in accordance with data protection law to protect your personal data.
We’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract with the recipient of the personal data that means they must protect it to the same standards as the EEA.
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain the information in the event of a legal claim.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your rights
You have a number of rights under data protection law in relation to how we use your personal data. These include the right, free of charge, to:
These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights, you can contact us using the details below.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Updates
We may update this privacy policy from time to time. Any updates will be made available and, where appropriate, notified to you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.