This policy covers the processing of personal data by Halfwayhomeonline (“halfwayhomeonline.com”, “we” or “us”). Halfwayhomeonline is committed to protecting the privacy of your personal information whilst striving to provide the very best user experience. We want our websites to be safe and enjoyable for everyone.
Under the General Data Protection Regulation (GDPR) and related laws, we have a legal duty to protect the personal information we collect from you. GDPR says that ‘personal data’ is any information relating to a living individual who can be identified, either directly or indirectly, from that information. This could include your name, email address, postal address or telephone number, or information collected online and used to identify you.
What lawful bases do we rely on for processing?
In order to process your personal data, we must have a lawful reason for doing so. GDPR sets out six lawful bases under which organisations can collect, use and store personal data. We rely on four of the lawful bases:
Necessary for the performance of a contract
If you are our customer, for example a subscriber of a magazine or an attendee at one of our events, we will process your personal data on the basis that it is necessary for us to provide our products and services to you.
In some instances we rely on your specific consent to process your personal information. This is where you have actively agreed and ‘opted-in’, for example to receive marketing communications from us, and you have the right to withdraw your consent at any time.
Compliance with laws
We may have to process and share your personal data in order to comply with our legal obligations, or to protect our rights or the rights of others. For example, we are required to collect certain information from you when processing your subscription payment for tax or financial reporting reasons.
In some situations we rely on our legitimate business interests in order to collect and use your personal data. In these situations, we have conducted a balancing test to carefully consider the impact of the processing on your interests, rights and freedoms. We will only undertake the processing if we are satisfied there is no negative impact on you. We rely on Legitimate Interests for the following activities:
- providing, maintaining, improving and developing our products and services;
- sending direct marketing communications about our products and services to customers;
- sending marketing communications related to the products and services of carefully selected companies in a business-to-business context;
- managing suppression and unsubscribe requests;
- researching publicly available business contact details;
- managing certain aspects of our events;
- analysing the use of our products and services;
- using analytics to identify usage trends and determining the effectiveness of campaigns;
- allowing you to comment on on our sites;
- dealing with queries and complaints;
- personalising your experience on our sites;
- identifying fraudulent behaviour and ensuring our websites and systems are secure.
Who may we share your data with?
We use third parties to perform certain functions on our behalf including fulfilling orders, sending emails, organising and managing events, running competitions and promotions, conducting surveys or polls, removing repetitive information from customer lists, comment hosting, website analysis, data analysis and processing credit card payments. They will have access to your personal information if necessary to perform their function but they cannot use it or disclose it for any other purpose, unless you have specifically given them consent to do so.
We may share aggregated, non-personally identifiable information, such as demographics and website usage statistics, with advertisers, sponsors and other organisations.
Option to receive marketing information from associated third parties
Products or services offered in partnership with third parties
We only share your personal information with our group companies if you have elected to receive marketing information from them which may be of interest to you. They are only permitted by us to use it for the purpose of providing you with the marketing information you have requested. If you do not want to receive marketing information from our group companies you can notify us and you can stop receiving this information at any time by following the unsubscribe instructions on the correspondence you receive or by emailing our DPO at [email protected]eonline.com, giving your email address and details of the information you no longer wish to receive.
What data is collected on our websites?
Information storage and access
The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.
Content selection, delivery, reporting
The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether the you took any action related to the content, including for example clicking on content. This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, such as websites or apps, over time.
The collection of information about your use of the content, and combination with previously collected information, used to measure, understand, and report on your usage of the service. This does not include personalisation, the collection of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, i.e. on other service, such as websites or apps, over time.
The collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, which inform future selection of advertising and/or content.
Ad selection, delivery, reporting
The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase. This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as websites or apps, over time.
Please see our Cookies Policy for more information.
Links to other websites
Our websites 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, when you leave our website, we encourage you to read the privacy notice of every website you visit. We may monetise some of these links through the use of third party affiliate programmes. Notwithstanding such affiliate programmes, we are not responsible for the content or privacy policies of these websites or for third party advertisers, nor for the way in which they use information they collect about you.
Storage and retention of data
Your information is collected and stored on our secure systems, mainly based in the UK and European Economic Area (EEA). Where we use third party service providers to store data, we have appropriate agreements in place to ensure that your personal data is protected. Your personal data may be transferred to a country outside the EEA if, for example, a supplier or service is based outside the EEA. We will take all steps reasonably necessary to ensure your data is treated securely, including ensuring the location has been granted ‘adequacy status’ by the European Commission, or using our agreement with the supplier contains model contractual clauses approved by the European Commission, or ensuring the company we are transferring the data to is certified under the EU-US Privacy Shield.
We hold personal data for a variety of different purposes and the length of time we keep your data will vary depending on the services or products we are providing. We will only keep your data for a reasonable period of time, which is based on the purpose for which we are using your data. Once that purpose has been fulfilled, we will securely delete that data or anonymise your information (so that we, or anyone else, can no longer tell that data relates to you) unless we are required to retain the data longer for legal, tax or accounting reasons.
We are committed to protecting the personal data we hold. In accordance with GDPR, we adopt appropriate technical and organisational measures to help prevent unauthorised access to your information and ensure data is held securely. We also require any third parties to whom we may transfer personal data to have appropriate security measures in place. We ask third parties to complete Data Security Questionnaires so we can be sure they are a safe place for your data.