Privacy Policy

PRIVACY POLICY

This privacy policy is effective as and from May 25th 2018

1. Introduction

Kennedy Echo Publishing Ltd T/a The Echo Newspaper (“The Echo Newspaper”) respects your right to privacy and is committed to protecting the privacy of its readers, customers, suppliers, contributors, contractors and also its users of The Echo Newspaper social media platforms and website – http://www.echo.ie (the “Website”) and complying with our obligations under the General Data Protection Regulation (the “GDPR”).

The purpose of this Privacy Policy (the “Policy”) is to outline how we deal with any personal data you provide to us in person or while visiting our Website.

We are aware that as a user of the Website you care about the security and privacy of your information. By visiting this Website, you are accepting the terms of this Policy.

You should not use this Website if you are not happy with this Policy.

Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of those other websites. When we link to another website it does not constitute an endorsement of that website by The Echo Newspaper.

2. The information we collect and how we use it

There are a number of reasons why we collect and use your personal information including the following:

2.1 Non-Personal Data:

This information is used in an aggregate form to get a better understanding of how people use the website, e.g. which pages are most popular, which links people find most useful, etc. This helps us to improve the website and provide better information and support for those who use it. We also use cookies. See our Cookie Policy for further information.

2.2 Personal Data:

Online Subscription

To become a subscriber of The Echo Newspaper you will need to create an account with us. You will be asked to provide personal data such as your name and email address to set up your account.

Customer Portal/Log In

If you are using the Customer portal on our website, you will be required to supply your email and a password.

Email Newsletter & Other Marketing Communications

If you register with The Echo Newspaper for the weekly newsletter and email marketing you will be asked to provide personal data such as your e-mail address.

This information will be used to provide you with weekly newsletters and promotional emails.

If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each mailing. You can also email mkeane@echo.ie to be removed. To remove yourself from push notifications, click the bell icon at the bottom right or click the lock icon in the top left of your browser while on The Echo website and you’ll see an option to turn off Notifications.

Online, Postal and In Person Correspondence

If you complete any of our Forms on our website, such as the memorial or planning forms, you will be asked to provide personal data such as your name, email address, and phone number along with other relevant information.

You may also write to us by post or call to our premises in person for the same services or to correspond with us in general.

In all of these instances we process the information provided, to correspond with you, in pursuit of our legitimate interests to develop and maintain relationships with our customers and readers.

To Pay for a Service.

There are a number of ways to pay for a service you have requested from us:

Online payment – Currently, the only online payment facility we provide is for our subscription service. This payment facility is through PayPal. Before you continue with this process you should refer to the privacy policy of PayPal and or Stripe.

Phone Payment – Our accounts and admin staff receive payment information from customers over the phone. When this occurs, the payment information is entered as instructed into the relevant payment system. Once payment is processed successfully all card details are destroyed immediately.

In Person Payment – You can make a payment in person by calling in to our premises where our reception/admin staff will be happy to help. There is chip and pin available for card payments. A receipt for all payments will be issued.

To Place an Advertisement

We may process your personal information if you opt to place an advertisement, both online and in print. We only process this information to deliver the advertising service you have requested as per the terms and conditions you accept.

Professional Service Providers

You may provide us with your personal information if you provide professional services to us. We process this information so we can administer, manage and pay for the relevant services you provide and as per the terms and conditions of our contract.

For Competitions and Promotional Purposes

We regularly run competitions or similar promotions. If you choose to enter a competition or promotion, we will use your personal information to administer these promotions and as per the terms and conditions you accept when you enter. In some cases, your competition entry may be shared with the promoter and this will be specified when you enter. If you win a competition, your contact information will be used to notify you as the winner and to award the relevant prize. We will publish your name on our website, social media platforms or in print, and indicate the prize you have won.

Accessing our Online Content

We collect information relating to your use of our services to track how you gain access to or read our content. We use log-in information, cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services.

You have the right to object to this processing, and if you wish to do so please visit the My Preferences section of your online account or contact us at dp@echo.ie

Email Communication Effectiveness

In order to monitor the effectiveness of our email communications we use such technologies to determine whether you’ve opened an email communication from us or clicked on a link contained in an email. Collecting information in this manner allows us to gather statistics about the usage and effectiveness of our services and products, including our email newsletters and direct marketing communications, in our legitimate interest.

Online Advertising Services

Third-party vendors, including Google, display advertising on our Services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site. This type of behavioral advertising is targeted towards groups of users in an anonymous and aggregated manner as opposed to you as an individual. Such online advertising helps support the content, products and services we provide. This process involves the use of cookies. Please see our Cookie Policy.

Recruitment

If you apply for a job with The Echo Newspaper, you may provide personal information about yourself. We will use this information for the purpose of processing and responding to your application, to assess your suitability as a potential candidate and for current and future career opportunities.

To Manage our Everyday Business Needs

We may use your personal information to manage our every business needs, including for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, technical support and fraud prevention in our legitimate interest. Our legitimate interest is the effective management of our business.

Identity Verification

To exercise your data rights, we may need to collect additional personal information from you to verify your identify and to process your request.

CCTV Camera Surveillance

The Edge, Avonmore Road, Tallaght, Dublin 24, D24 K07Y from which we operate our business, is monitored by CCTV security cameras, is monitored by CCTV security cameras. Personal information about you may be recorded if you visit the premises.

3. Lawful basis for which we hold and use your Information, including the retention periods

When we collect and process your personal information there are several legal bases which we rely on for the purpose of collecting and processing that data.

Performance of a Contract

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Consent

We will, in certain circumstances, rely on your explicit consent to process your personal information. Where we do, you have the right to withdraw your consent at any time. In most circumstances, your consent can be withdrawn by following the unsubscribe instructions included at the end of each email communication from us. You can also contact us at dp@echo.ie and we will be happy to facilitate your request.

Legal Obligation

The Echo Newspaper may be required to process your personal information when obliged to comply with its legal obligations including providing information to Government Bodies, the Revenue Commissioners or An Garda Siochana.

Legitimate Interests

Processing your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. Our legitimate business interests do not automatically override your interests. You have the right, free of charge, to object to our use of your personal information for our legitimate interests. If you wish to do so contact us at dp@echo.ie.

Please bear in mind that if you do object, this may affect our ability to carry out certain tasks for your benefit.

Storage & Retention Periods

The storage and retention periods depend on the nature of the information processed and its purpose. For example:

As a local newspaper, for journalistic and archive purposes, some information we process has an indefinite storage and retention period.

In the case of a contract, information may be stored and retained for up to seven years depending on the nature of the contract and its terms and conditions.

For further clarification on the legal basis, storage and retention periods directly related to your personal information please email dp@echo.ie

4. Processing for Journalistic Purposes

As a local newspaper, The Echo Newspaper processes personal data for the purpose of exercising the right to freedom of expression and information and for journalistic purposes.

This processing is exempt from compliance with certain obligations of the GDPR.

There are a number of ways in which your personal information may be used for journalistic purposes:

If you submit content to be published online and in our printed publications
Where you have voluntarily contributed your experience to us and we publish this information
If we publish a letter you have written to the Editor
If you participate in or attend an event that we are covering
It is important to understand that certain rights which you have in relation to your personal information may not apply where that data is processed for journalistic purposes.

5. Disclosure of Information to Third Parties

5.1 We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential as part of their contract with The Echo Newspaper and adhere to the GDPR.

5.2 We may also release your personal data where compliance with legal requirements is a necessity. We also reserve the right to enforce our site policies in order to protect our rights and the rights of other individuals in a manner that is safe and compliant with the law.

5.3 Our website and mobile applications use interfaces with social media sites such as Facebook, Twitter and others. If you choose to like or share information from our sites through these services, you should review the privacy policy of that service. If you are a member of a social media site and logged in, the interfaces configured on our Services allow the social media site to connect your site visit and browsing behavior to the personal data held on your social media site. The Irish Times can use this information on an aggregate basis to place ads that are based on your interests on these social media sites. These practices are governed by the privacy statements of these social networking sites and you are advised to review these separately.

5.4 We may transfer your personal data outside the European Economic Area (EEA). These countries do not always afford an equivalent level of privacy protection and in such circumstances we take specific steps, in accordance with data protection law to protect your personal information. In particular, for transfers of personal data outside the EEA we rely either on an adequacy decision by the European Commission or on contractual protection approved by the European Commission. For example the EU-US Privacy Shield, which is recognized by the EU as providing adequate safeguards for the transfer of personal data.

6. Your Rights

6.1 Unless subject to an exemption (under the GDPR), you have the following rights with respect to your personal data: –

The right to find out, if The Echo Newspaper holds personal information about you. You have the right to be given a description of the personal data and to be told the purpose(s) for holding your information
The right to request a copy of your personal data which the The Echo Newspaper holds about you;
The right to request that The Echo Newspaper corrects any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary for The Echo Newspaper to retain such data;
The right to withdraw your consent to the processing at any time
The right to request that the The Echo Newspaper provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable)
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable)
the right not to be subject to a decision based solely on automated processing, including profiling
The right to lodge a complaint with the Data Protection Commission.

You can request any of this information by writing to the Compliance Officer with responsibilities for Data Protection & GDPR.

Mr. Peter Kennedy. Compliance Officer. The Echo Newspaper.

The Edge, Avonmore Road, Tallaght, Dublin 24, D24 K07Y or email dp@echo.ie
Please enclose proof of identity and as much specific information in order to assist us and The Echo Newspaper will reply within one month.

7. Cookies

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

We use cookies to track your usage of the Website and compile anonymous data about site traffic and site interaction so that we can offer better site experiences and tools in the future. This website uses Google Analytics to gather anonymous statistics about visitors to the site and which pages are visited.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly.

For more information on cookies, see our Cookie Policy.

8. Security

The Echo Newspaper takes its security responsibilities very seriously, including by employing appropriate physical and technical security measures, conducting staff training and generating awareness, and regular reviews of these responsibilities. We will take all reasonable precautions to prevent the loss, misuse or alteration of Personal Data you volunteer. You should note however, that Internet transmissions are never completely private or secure.

You accept that any information or message you send to the Website may be intercepted or read by others. You hereby acknowledge and accept that we have no responsibility and shall accept no liability whatsoever for loss, injury or damage occasioned by the interception by third parties of your transmissions, or the disclosure of information, nor do we offer any guarantees, warranties or indemnities as to the security or otherwise of any information which you volunteer.

9. Sale of Business

We reserve the right to transfer information (including your Personal Data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of the Privacy Policy and provided that the third party only uses your Personal Data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.

10. Changes to our Privacy Policy

This Privacy Policy will be the subject of change and the use of information that we gather shall be subject to the privacy policy in effect.

Contacting Us

If you have any questions regarding this privacy policy or any other matters relating to our privacy policy generally, you may contact us using the information below:

Mr. Peter Kennedy. Compliance Officer.

Address: The Echo Newspaper. The Edge, Avonmore Road, Tallaght, Dublin 24, D24 K07Y

Email: dp@echo.ie.