Telegraph Media Group is also responsible for our website www.telegraph.co.uk, and whether you browse as a guest or register with us we will collect different types of information about you: for example, for website functionality; to provide improved or personalised services to you; to help decide what kind of advertising you will see on the site; and, in accordance with your chosen preferences, to market goods or services to you. Please also see our website terms and conditions.
1. What information do we gather?
The information that we gather falls broadly into two types (please see further below for how we collect it and what we use it for):
1.1 Information that relates directly to you (e.g. your name, your email address and contact details, communication preferences and customer history).
1.2 Information that does not directly identify you (e.g. how you might browse our website), specifically:
(1) Your IP address through the placement of cookies; and
(2) Location data, which might be gained through your IP address or GPS data (see Section 3 (4), below).
Please note that not all cookies are either personally identifiable information or even unique identifiers; but some can be, while others can influence what you see on our website and others (see Sections 6 and 7 on cookies and their management, below).
2. How we use your information
2.1 When we seek your permission. Often we will be using your information in accordance with your specific consent or instructions: for example, because you have requested or consented to receiving certain information, or entered into a contract with us (or one of Our Brands) for goods and services: see Section 2.2 below.
At other times we will use your information on one of the other lawful bases described below in this section.
(1) When you enter into a contract for goods or services with us (including competitions, offers, subscriptions or your online Telegraph account), or where you wish to register an interest in doing so, we will use your personal data to enter into and fulfil our contractual relationship with you.
(2) Fulfilling our contract with you means being able to manage and administer our services, and maintain our standards of tailored service levels, customer care and consumer compliance. This might include fulfilling orders or returns, processing payments or refunds, and providing aftercare, as well as improving your customer experience online and otherwise, including by monitoring service levels and responding to feedback.
2.3 Legitimate interests.
Other uses of your information are made for ordinary and transparent purposes which we think are necessary for our legitimate interests as a provider of news, content, and other services (including when working with Our Brands). We use your information on this basis to do the following:
(1) Recognise and remember you when you visit our website and better understand how you use our website and others by using cookies to follow your use. We explain what cookies are in Section 6 and how you can manage them in Section 7, below;
(2) Recognise and remember you when you use a Telegraph application (“Telegraph App”), to analyse how you use it and to serve you with advertisements based on your interests. Section 3.1 (4) explains how we gather this information;
(3) Serve you advertisements on selected, third-party websites that make their advertising space available to us. We call this “Audience Extension” and we do this either by means of using retargeting cookies and similar technologies (we explain what cookies are in Section
6 and how you can manage them in Section 7, below) or by matching other unique identifiers, subject to appropriate safeguards and preferences for the purposes of serving you targeted advertisements and for running website analytics.
One such example is when we use Facebook’s Custom Audience feature (although other sites may offer similar services). Custom Audiences enable us to display personalised advertising to our customers whilst they are on Facebook, or your information may be used to create lookalikes of similar audiences for targeting. This information is matched on a pseudonymised basis without leaving our servers. Facebook does not receive any new information from us about you except as necessary to fulfil our instructions to serve relevant advertising as our data processor, and if you are not an existing Facebook customer then Facebook will not see any of your personally identifiable data (please see this link for further information). You can opt out of your data being used in this way by contacting firstname.lastname@example.org. You can manage your Facebook advertising preferences by visiting facebook.com/adpreferences/data;
Serve you advertisements on our own website that are tailored to you or a group similar to you, where we make advertising space available to carefully selected third parties. This is subject to appropriate safeguards and your preferences around us serving you targeted advertising.
(4) Identify your interests. We might then put your information in aggregated form into groupings (known as “segments”) by a particular audience, which means we can serve you advertisements and offers that will interest you within the website, including by reference to data we receive from third parties. These advertisements and offers can be for our own products and for those of third parties. Please see Sections 6 and 7 for more information about cookies and how we serve you more targeted messaging;
(5) Keep you updated on any services you have subscribed to, or any products you have purchased, and/or about similar services unless you have told us otherwise (including where we are working alongside other Service Providers to provide these services, such as travel or insurance, as detailed in the Our Brands section);
(6) Contact you to let you know about any of our products, services or promotions (which may in some cases be provided by third parties), including by email, mail, telephone, app push notification or SMS text message, always having regard to your preferences. Please see Section 4 to understand more about how you provide and can manage your preferences.
(7) Contact you directly or via social media in relation to any competitions and/or prize draws you have entered.
(9) Make sure materials on the website or in apps are presented in the most effective way for you and your computer or mobile device;
(10) Collect and log numeric internet addresses to improve the website and to monitor website usage; and
(11) Assess and understand our readers’, customers, site users'; and account holders'; feedback and identify usage hotspots;
2.4 Some limited uses of your data are required to comply with legal obligations, for example fraud detection and taxation;
2.6 We occasionally work with partners to compare their customer database to ours. This is called “data matching” and it allows our partners (such as other brands) to see if they can reach their audiences on our platforms. This will usually be carried out at an aggregated group audience level rather than on an individual level basis, although your information may be used to generate these insights. These insights may show, for example, if there is an overlap between our audiences and our partner’s audience and other information to help understand whether an advertising campaign would be effective.
We may also work with partners to build ‘lookalike’ audiences that are similar to our partners’ existing audiences, for targeting. An example of this may be a restaurant brand that wants to advertise to “food and drink enthusiasts” or “restaurant goers”, and so wishing to select an audience who we have identified as having interests in these ares. We would do this by segmenting our audiences into groups based on what they seem to like and similar behaviours. The restaurant is then able to identify a relevant audience, which means we can show you advertising that is relevant to you.
3. How do we gather information?
3.1 Information (as set out in Section 1) is gathered in the following ways:
(1) indirectly (e.g. from third party data providers or by using website technology that tracks and administers your visits through your browser, or similar technology when you use a Telegraph application (“App”) on a mobile device, or when you log on and/or share stories through social media;
(2) directly (e.g. when you buy a subscription, sign up to create a telegraph.co.uk profile, download a mobile device application or you otherwise provide your information when you interact with us, for example by telephone, email, or live chat);
(3) through your device (e.g. mobile, PC or tablet) where you have enabled location services for the applicable App or browser. This may be used for location targeted services or advertising in accordance with your preferences, which may be adjusted either on your device or via server, App or website preferences;
(4) through location technology for mobile web services. The service we use is based on machine learning algorithms which analyse data from different connection types. These include fixed http and https connections, location consent requests on https sites and from mobiles Apps using https connections. More information is available here. You can opt-out of this service here;
(5) through social media sign-on. We offer a quick registration option using your existing social media accounts via an App or the website. If you log in to our sites using a social media account, you are granting permission to that social media company to share your user details with us, and to collect information about you and how you use our site (which process we do not control and will be subject to the terms and conditions of your social media account). This will include that social media company tracking or identifying when you share one of our stories through their site. When you use social sign-on, we will gather the information you have already used in the process of registering for that social media site (in accordance with your preferences provided to that site and/or to us at the point that you use our social sign-on) and your social media account will be linked to your Telegraph account, including in our providing social media messaging to you (See Section 5.2, below on de-linking accounts);
(6) when you subscribe to The Telegraph, we may also use a card updater service to automatically update your credit or debit card details. This service is facilitated by your credit or debit card issuer, whom you should contact for further information;
(7) in the past we may have obtained certain additional details through a telephone number appending service where we have had contact details for you but did not have your phone number or needed to update your phone number (but would not use phone numbers that are gathered this way where those numbers are registered with the Telephone Preference Service). We no longer append data in this way; and
(8) we may also overlay additional demographic and lifestyle data from CACI (www.caci.co.uk) to help us understand what else you might be interested in for direct marketing and insight purposes. These segmentations are built using a variety of sources, including publicly available data (such as the electoral register and the UK Census) or derived from surveys and questionnaires. You can opt out of having your personal information profiled in this way by contacting us. See Section 5, below.
(9) through cross-device graphing algorithms to associate devices that might be related to each other, such as devices used by the same person or in the same household. We may collect and use this analytics data together with your personal information, to stitch session data from unauthenticated (anonymous) user visits with authenticated (logged in) user visits in order to build a broader profile of our individual users so that we can serve you better.
(10) we may obtain personal data based on the content you view via our Apps. Your recently viewed articles are also cached in the local storage on your device. This can be deleted by you via the settings of the App. You can choose to receive notifications from us on your device via the App, and manage these notifications in the settings of the App;
(11) when you use the App, we may ask for your permission to be able to access certain functions of your mobile handset, depending on your device. This may include us asking for your permission: (i) if you choose to store content to use offline, permission to save that content on your mobile; (ii) to access your details on your mobile, so we can locate your account on your mobile; (ii) to access your photographs/camera if you choose to submit photographs to the Telegraph.
(12) if you register or sign into our websites or Apps by using your Google login details, you give Google your permission to share personal data that is publicly available in your Google profile (e.g. your name, email address). Your email address will be linked to your Telegraph subscription or registration to allow you to access your profile and subscribed content.
(12) If you register or purchase a subscription via Apple, you give Apple permission to share personal data with us (e.g. your name and email address) You can choose for Apple not to share this data and create a random email address. This email address will be linked to your Telegraph subscription or registration to allow you to access your profile and subscribed content.
4. How do you decide how you want to hear from us?
4.1 We will contact you in accordance with your preferences, including by email, phone, post, Telegraph App notifications and SMS text. We always seek to explain why and how we might contact you at the point you give your information to us.
4.2 We also provide the means for you to grant and withhold your permission for us to contact you. We do this by using opt-in and opt-out boxes or unsubscribe options, which determine your permission for us to contact you about our wider range of goods and services, including those provided by Our Brands (the range of Telegraph-branded offers, products and services listed below this policy).
4.3 Sometimes, we need your information to be able to contact you to provide the service you wish to use (e.g. a subscription or Telegraph Fantasy Football). In those cases, by signing up to the service you are agreeing that we will have to send you service communications to run the service itself, and we will not offer you the chance to opt-out from receiving those messages until you decide you no longer wish to use the services.
4.4 As well as the communications we send you, we also offer you the opportunity to choose whether to hear from specific companies and organisations that we work in association with, including (but not limited to) the Service Providers for Our Brands. We will always name those companies and organisations, and you will have to opt in to hearing from them via a tick box (or because you choose to engage with them directly).
4.5 If you have signed up to receive marketing from us by SMS, to stop this, please reply STOP to the last message you received.
5. Accessing and updating your personal information
5.1 You can update your details and marketing preferences by accessing your account pages on the website, by emailing email@example.com or by writing to us at The Telegraph - Data Protection, Firstsource, Riverside Road, Pride Park, Derby, DE24 8HY
5.2 You can de-link your social media account from your Telegraph account by emailing firstname.lastname@example.org. De-linking your account will not change your marketing preferences unless you specifically request it and we are not responsible for how third party social media sites use information they collect about you, including via your own social media account or through your having linked it to your Telegraph account.
5.3 You have the right to access the personal information held about you from us, or from any other organisation that controls your personal information. To understand how to obtain a copy of the personal information that we hold, please see Section 13 below.
6. Cookies and similar technologies
6.3 We use the following types of cookie, as will your browser:
(1) Analytics cookies that remember your computer or mobile device when you visit our website and recognise visits to our website across different devices. They keep track of browsing patterns and help us to build up a profile of how our readers use the website. We use that information for customer analytics and to serve advertisements that we think might be of particular interest to you on our and other websites (see Section 7.5), and to serve editorial content tailored to your interests when you are on our website or in our newsletters to you. Your browser may use similar cookies for similar purposes and to serve advertisements for others. The information we gather from your visit is limited to page URLs on our website.
(2) Service cookies that help us to make our website work as efficiently as possible; remember your registration and login details; remember your settings preferences; to detect what device you are using and adapt how we present our services according to the screen size of that device; and meter the number of pages you view for the purpose of administering subscriptions to The Telegraph.
(3) Third party advertising and analytics cookies, which are placed by or on behalf of independent advertisers who are advertising on our site. These cookies may be placed within the advertisement and elsewhere on our site by us or by your browser. They can allow the advertiser or your browser to tailor advertising to you when you visit other websites. They are used for statistical analysis by allowing the advertiser to count how many people have seen their advertisement or have seen it more than once, to make sure you are not repeatedly served with the same advertising messages.
(4) We also place third party cookies to enable the serving of our own advertisements, (for example, for our subscriptions offers), on our own website or other websites. These advertisements will be based on your browsing behaviour on our website and will be tailored to your interests. The information we gather from your visit is limited to page URLs. For instance, if you are particularly interested in Food and Drink articles, the subscription offer advertisements served to you when you visit your Facebook account will feature our Food and Drink content.
Alternatively, visit youronlinechoices.com or click on the AdChoices logo that you will see in the corner of advertisements that carry behavioural targeting cookies.
7.3 We use various third parties to provide us with information to help us learn about how users use our website. To find out more about how we use these third party services click on their names, below, to view their websites and privacy policies:
7.4 If you would like to disable 'third party'; cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to the third party's website and getting them to generate a one-time 'no thanks' cookie that will stop any further cookies being written to your device. Here is a link to the third party advertising platform we use, which has instructions on how to do this:
Please note that even after disabling this, you may still see “non-personalised” advertisements that may appear materially the same as the “personalised” ones. This is simply a function of what advertisers and partners we are working with, and does not mean your preferences have not been applied.
7.5 We also use a data management platform. We use the data this platform records, including data gathered through cross-device tracking, to better understand our users’ interests, so that we can provide better and relevant TMG and Advertiser services based on this information.
7.6 When you share stories using social media, for example Facebook, the social media company will drop cookies and identifiers to track this.
7.7 You can also visit the trade body representing these advertising companies for more information on how to opt out of these cookies: youronlinechoices.com
8. Ad Blockers
8.2 By detecting ad blockers, we do not store any information on your device and we do not process any of your personal data.
8.3 We may display a message to advise you that we have detected that you are using and ad blocker
8.4 We reserve the right to restrict your access to some or all of our website while you have an ad blocker turned on.
9. Protecting your information
9.1 The password you provide when registering with the website is encrypted to ensure protection against unauthorised access to your personal information.
9.2 We invest in high-quality security and do our utmost to protect user privacy. No data transmission over the Internet can be entirely secure, and therefore we cannot guarantee the security of your personal information and/or use of the website. Any information that you send is at your own risk and may be read by others. However once we have received your personal information we use strict procedures to protect the security of your personal information.
10. Disclosing your information
10.2 Your internet browser or other accounts. Depending on which browser you use to visit our site, and in accordance with your browser cookie preferences (see above), your browser (such as Google) may collect information about you and your visit for its own services, including those services such as segmented or personalised advertising that it provides to us and other sites. If you use social media sign-on (such as with Facebook), you will be enabling sharing of information between us and that site in the manner set out in Section 3.1(5) above and any notices provided to you. You can de-link your social sign-in as set out in Section 5.2.
10.3 Our partners. Except as set out in Section 10.1 or 10.2 above, we never sell personal information, or pass it to third parties outside of the Telegraph Media Group for their own marketing purposes, without your permission. We sometimes provide your personal information to third parties who are our subcontractors or providers of various products and services on our behalf e.g. the providers of the branded services listed below (Our Brands and their Service Providers) and intermediaries, in order to fulfil those orders and providers of key services such as our customer care partners, First Source. Your personal information will always be subject to appropriate protections under contract.
Where you are engaging with Our Brands for products and services, you will sometimes contract with our Service Providers and may choose to provide them with personal information or permissions directly.
10.4 Legal requirements. We may disclose your personal information if we are required to do so by law, or if in good faith we believe such action is necessary to comply with the law a legal obligation.
10.6 Data processors. In common with most organisations, some of our functions using your personal information are outsourced to contractors (for example, Sourcepoint who manage our cookies consents or our other software providers). Any processing of personal information by these contractors will only be for these carefully defined purposes, and will be adequately and lawfully protected under contract, including requirements of confidentiality and data security.
11. Where we store your personal information
11.1 The personal information that we collect from you will sometimes be sent and stored outside of the UK or the European Economic Area ("EEA") in order to carry out the activities listed in “Use of Your Information”. Except where this is on your specific instructions, this will always be subject to adequate safeguards as to the protection and security of your personal data. This means that we will only transfer your personal data outside of the UK or EEA:
to countries that have been found to provide an adequate level of protection for personal data; or
where we have used specific approved contracts that use approved clauses for the protection of personal data. These contracts give your personal data the same level of protection as the UK and EEA.
Further details on these safeguards are available on enquiry from email@example.com.
11.2 We will only keep your personal information for as long as we need it for a lawful purpose: whether because of the products and services we have provided to you, for example as a subscriber or registered user (and to allow for reasonable retention of records afterwards to reflect legal requirements or limitation periods),or because we believe you still wish to hear from us. This is again separate from our role as a media organisation and the information we are lawfully able keep in the public interest because it is relevant to our journalism and publishing activities.
12. Changes to this Policy
12.1 If we change our Policy, we will post the changes on this page. Please check the website regularly for any changes to this Policy. However, from 25 May 2018 any significant changes will be provided to you directly where possible.
13. If you don't feel we're adhering to this Policy, what should you do?
13.1 You have the following rights:
(1) To obtain access to, and copies of, the personal data that we hold about you, or require that it is transmitted to another data controller;
(2) To request that we restrict our data processing activities or cease processing your personal data in certain ways, for example because you do not consider it lawful;
(3) To require us not to send you marketing communications;
(4) To withdraw your consent, where we are relying on it to process your personal data;
(5) To object to how we process your personal data, in particular where we are relying on our legitimate interests; and
(6) To ask us to erase the personal data we hold about you, for example because it is causing you distress or you believe it to be no longer relevant, or to correct the information if it is incorrect. If you would like to exercise any of your rights as stated above, you can do so by emailing firstname.lastname@example.org.
Please note that the above rights are not absolute, and we will be entitled to refuse requests where exceptions apply (including where we are processing it in our capacity as a media organisation). You can find out more about your rights at www.ico.org.uk.
Automated decision making
You also have the right to object to automated decision-making, including by means of profiling. Although we use various algorithms and automated criteria to help us serve advertising in the manner set out in this Policy, this results in segmented advertising (by category of user) rather than specific decisions being made about you. This can in any event be controlled through your cookie and ad preferences.
If we change how we use this technology in the future, we will let you know if it affects you via this Policy (and significant changes or effects we will notify directly).
14. If you don't feel we're adhering to this Policy, what should you do?
14.1 If you believe that we have not adhered to this Policy, please notify us by email at email@example.com and we will try to solve the problem promptly. If you are not satisfied with our response, or have any other queries, you can also contact the Information Commissioner at www.ico.org.uk or 0303 123 1113. This policy was last updated on 3 August 2023.
Telegraph brands and their suppliers change from time to time. The following list was updated on 18th October 2022.
N.B. Telegraph Travel also uses the services of smaller organisations and individual hotels. These are clearly specified in our marketing communications.
Effective Date: January 10, 2023
Your U.S. State Privacy Rights
About Ads and Tracking
Learn about certain choices you have regarding Tracking Technologies, including certain sharing of activities for interest-based advertising, including Location-Based Advertising and Cross-Device Matching.
Telegraph Media Group, and/or its Service Providers (defined below), may collect information you provide directly to Telegraph Media Group and/or its Service Providers via the Service. For example, Telegraph Media Group collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here.
Telegraph Media Group, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include information regarding how you might browse our website, specifically, IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Telegraph Media Group with Telegraph Media Group-Collected PII, Telegraph Media Group does not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or Telegraph Media Group-Collected PII. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
The methods that may be used on the Service to collect Usage Information include:
- Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
- Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device recognition technologies, in-app tracking methods, device and activity monitoring and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Service may associate some or all these types of cookies with your devices.
Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Telegraph Media Group’s web server, or from a third party with which Telegraph Media Group works and is active only while you are connected to the Service and deleted or deactivated thereafter.
GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content, including third party ads, based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked by us and third parties.
Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs,” or may use “SDKs,” to associate app user activity to a particular app and to track user activity across apps and/or devices. SDKs are blocks of code that may be installed in our mobile application by third party companies with which we work. SDKs help us understand how you interact with our mobile application and collect certain information about the device and network you use to access our application, such as the advertising identifier associated with your device and information about how you interact with our application.
Some information about your use of the Service and certain other online services may be collected using Tracking Technologies across time and services and used by Telegraph Media Group and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services. See Section 11 regarding certain choices regarding these activities.
Telegraph Media Group is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
- Allow you to participate in the features we offer on the Service;
- Facilitate, manage, personalize, and improve your online experience;
- Process your registration, manage your account, and provide customer care and consumer compliance (e.g., fulfilling orders or returns, processing payments or refunds, and providing aftercare, as well as improving your customer experience);
- Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
- Telegraph Media Group Affiliates’ marketing and other purposes;
- Improve the Service and for any other business purposes;
- Tailor our content, advertisements, and offers;
- Fulfill other purposes disclosed at the time you provide Personally Identifiable Information or otherwise where we are legally permitted or are required to do so;
- Determine your location and manage digital content rights (e.g., territory restrictions); and
- Prevent and address fraud, breach of policies or terms, and threats or harm.
- Marketing: Subject to your communications choices explained in Section 11.D, and the rights of California residents explained in Section 12, we may use your Personally Identifiable Information to send you marketing communications. Telegraph Media Group will not share your Telegraph Media Group-Collected PII with third parties or Telegraph Media Group Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below) without your consent (which may be by means of third-party interaction described in the next bullet point). We sometimes provide your PI to third parties who are our Vendors of various products and services on our behalf to fulfill those orders.
- Your Disclosure or Consent: As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your Telegraph Media Group-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not Telegraph Media Group.
- Telegraph Media Group’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to, your information, including, without limitation, Personally Identifiable Information, Demographic Information, and Usage Information, in connection with their work on Telegraph Media Group’s behalf, provided however, Telegraph Media Group does not authorize its Service Providers to use Telegraph Media Group-Collected PII provided by Telegraph Media Group to the Service Providers to send you direct marketing messages other than related to Telegraph Media Group and Telegraph Media Group Affiliates absent your consent. For more information on choices Service Providers may offer you visit Section 11.
- Third parties and their advisers if we are approached by a potential buyer in connection with the potential sale of our business or of any part of it.
- Your internet browser or other accounts. Depending on which browser you use to visit our site, and in accordance with your browser cookie preferences (see above), your browser (such as Google) may collect information about you and your visit for its own services, including those services such as segmented or personalized advertising that it provides to us and other sites.
- Data processors. In common with most organizations, some of our functions using your personal information are outsourced to contractors. Any processing of personal information by these contractors will only be for these carefully defined purposes, and will be adequately and lawfully protected under contract, including requirements of confidentiality and data security.
- To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
- If Telegraph Media Group believes your actions are inconsistent with Telegraph Media Group’s terms and conditions, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Telegraph Media Group, the Service or its users, or any third party.
In addition, Telegraph Media Group may share your Telegraph Media Group-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Telegraph Media Group assets, or transfer of all or a portion of Telegraph Media Group’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Telegraph Media Group relies on you to only send to people that have given you permission to do so. The recipient’s Personally Identifiable Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Telegraph Media Group for any other marketing purpose unless Telegraph Media Group obtains consent from that person. Your contact information and message may be included in the communication.
The Service may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)) or other services (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personally Identifiable Information from you.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Telegraph Media Group’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5 or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with Telegraph Media Group or other Telegraph Media Group Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Telegraph Media Group and Telegraph Media Group Affiliates. Also, both Telegraph Media Group and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
Telegraph Media group may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”). We may use Microsoft and Google for advertising Services. See Section 11 for more information on your choices regarding certain personalized advertising.
Telegraph Media Group takes reasonable measures to protect Telegraph Media Group-Collected PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Telegraph Media Group does not guarantee the security of your information collected through the Service.
Telegraph Media Group does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Telegraph Media Group here, detailing where the content or information is posted and attesting that you posted it. Telegraph Media Group will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that Telegraph Media Group does not control.
Telegraph Media Group may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Telegraph Media Group-Collected PII, and potentially certain other information about you (e.g., profile and account information). Telegraph Media Group will make good faith efforts to make requested changes in Telegraph Media Group’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all your information or public postings from Telegraph Media Group’s databases (California minors see Section 9 and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to HTML5 cookies or other Tracking Technologies. Visitors in the U.S. may also manage cookies on our Service through our consent management platform
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Telegraph Media Group currently does not alter Telegraph Media Group’s practices when Telegraph Media Group receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Telegraph Media Group is not responsible for the completeness or accuracy of this third-party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Telegraph Media Group is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Services, but such tools rely on third parties and third-party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective. For instance, here is where you can find cookie controls for popular browsers:
We do not represent that these third-party tools, programs or statements are complete or accurate. You will need to do this on each browser that you use to access our Services and clearing cookies on your browser(s) may disable your preference settings. Also, our Services may not function properly or as intended if you block all or even certain cookies. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us, and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you can opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Telegraph Media Group supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Telegraph Media Group directly engages to serve you Interest-based Advertising will do so as well, though Telegraph Media Group cannot guaranty their compliance.
We may also use Microsoft Advertising Services. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit here. We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit here.
In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the other online services. For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads. If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
Telegraph Media Group is not responsible for effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
With respect to Telegraph Media Group’s mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., tracking across apps and websites owned by other online services, location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. For example, to limit receiving Interest-based Advertising on your mobile device, for iOS 14, go to “Settings,” select “Privacy,” select “Tracking,” and then toggle off “Allow Apps to Request to Track.” For earlier versions of iOS dating back to iOS 6, go to “Settings,” select “Privacy,” select “Advertising,” and toggle on “Limit Ad Tracking.” For Android, go to “Settings,” select “Privacy,” select “Ads,” and then toggle on “Opt out of Ads Personalization.” Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist. To learn more about how you can control certain location permissions, such as GPS, wi-fi, and network data, using your mobile device’s operating system settings, please visit the following links depending on which device you use:
You can opt out of receiving certain promotional communications (emails or text messaging) from Telegraph Media Group at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from Telegraph Media Group to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Telegraph Media Group may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Telegraph Media Group’s ongoing business relations. Except in connection with Corporate Transactions, to prospectively opt-out of our sharing of your Company-Collected PII with third parties, other than with Telegraph Media Group Affiliates, for their own direct marketing purposes, email us here
To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the prior section regarding the DAA’s Interest-based Advertising choices.
This U.S. State Privacy Notice (“Notice”) applies to “Consumers” as defined under the California Consumer Privacy Act, including as amended by the California Privacy Rights Act, Colorado Privacy Act (effective July 1, 2023), and all laws implementing, supplementing or amending the foregoing, including regulations promulgated thereunder (together, the “CCPA”), and Chapter 603A of the Nevada Revised Statutes (collectively, “U.S. Privacy Laws”). Capitalized terms used but not defined in this Notice shall have the meanings given to them under the CCPA.
- Section A of this Notice provides notice of our data practices, including our collection, use, disclosure, and sale of Consumers’ Personal Information or Personal Data (collectively, “PI”), as that respective term is defined under US Privacy Laws.
- Sections B-D of this Notice provide information regarding Consumer rights and how you may exercise them. Nevada “consumers” have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, the other Consumer rights only apply to California Consumers.
- Section E of this Notice provides additional information for California residents.
For California residents the term “Consumer” is not limited to data subjects acting as individuals regarding household goods and services and includes data subjects in a business-to-business context.
Non-Applicability: This Notice does not apply to our job applicants, current employees, former employees, or independent contractors (“Personnel”), however, California Personnel may obtain a separate privacy notice that applies to them by contacting our human resources department by email here. This Notice also does not apply to PI that we may process as a Service Provider/Processor on behalf of another Business/Controller.
The description of our data practices in this Notice covers the twelve (12) months prior to the Effective Date and will be updated at least annually. Our data practices may differ between updates. However, if the practices are materially different from this Notice, we will provide supplemental pre-collection notice of the current practices, which may include references to other privacy policies, notices, or statements. Otherwise, this Notice serves as our notice at collection.
We may Collect your PI directly from you (e.g., when you register for an account); your devices; our affiliates; service providers; public sources of data; credit reporting agencies; or other businesses or individuals. As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We will not reidentify or attempt to reidentify data that we maintain as deidentified or knowingly enable any third party to do so.
We may also use and disclose your PI under this Notice for Commercial Purposes, which may be considered a “Sale” or “Share” under applicable U.S. Privacy Laws, such as when Third-Party Digital Businesses (defined below) Collect your PI via third-party cookies, and when we Process PI for certain advertising purposes.
We provide more detail on our data practices in the two charts that follow.
We collect, disclose, and retain PI as follows:
There may be additional information we Collect that meets the definition of PI under applicable U.S. Privacy Laws but is not reflected by a category above, in which case we will treat it as required, but will not include it when we describe our practices by PI category.
As required by California law, we note our general PI retention rules by category of PI in the chart above. However, because there are numerous types of PI in each category, and various uses for each PI type, actual retention periods vary. We will retain specific PI pieces based on how long we have a lawful purpose for the retention. For instance, we may maintain business records for so long as relevant to our business, and may have a legal obligation to hold PI for so long as potentially relevant to prospective or actual litigation or government investigation. We apply the same criteria for determining if we have a legitimate purpose for retaining your PI that you ask us to delete. If you make a deletion request, we will conduct a review of your PI to confirm if legitimate ongoing retention purposes exist, will limit the retention to such purposes for so long as the purpose continues, and will respond to you with information on any retention purposes on which we rely for not deleting your PI. For more information on deletion requests see the Right to Delete section.
We use and disclose PI for the processing purposes described below:
As described more below, subject to meeting the requirements for a Verifiable Consumer Request (defined below), Telegraph Media Group provides Consumers the privacy rights described in this section. For residents of states without Consumer privacy rights, we will consider requests but will apply our absolute discretion with respect to, if, and how we process such requests. Visitors in the U.S. may also manage cookies on our Service through our consent management platform.
To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, use our Consumer Rights Request Portal, or e-mail us at firstname.lastname@example.org, and respond to any follow-up inquiries we make. Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.). More details on the request and verification process are in Section 3. The Consumer rights we accommodate are as follows:
We only Process Sensitive PI for purposes that are exempt from Consumer choice under U.S. Privacy Laws.
Residents of California are entitled to access PI, up to twice in a 12-month period, collected and maintained about the Consumer on or after January 1, 2022, including beyond the 12-month period preceding our receipt of the request, unless doing so proves impossible or would involve a disproportionate effort.
California residents have a right to submit a request for any of the following:
- The categories of PI we have Collected about you.
- The categories of sources from which we Collected your PI.
- The Business Purposes or Commercial Purposes for our Collecting, Selling, or Sharing your PI.
- The categories of Third Parties to whom we have disclosed your PI.
- A list of the categories of PI disclosed for a Business Purpose and, for each, the categories of recipients, or that no disclosure occurred.
- A list of the categories of PI Sold or Share about you and, for each, the categories of recipients, or that no Sale or Share occurred.
(2) Specific Pieces
You may request to confirm if we are Processing your PI and, if we are, to obtain a transportable copy, subject to applicable request limits, of your PI that we have collected and are maintaining. For your specific pieces of PI, as required by applicable U.S. Privacy Laws, we will apply the heightened verification standards as described below. We have no obligation to re-identify information or to keep PI longer than we need it or are required to by applicable law to comply with access requests.
Under U.S. Privacy Laws there are broad and differing concepts of “Selling” PI for which an opt-out is required. California has an opt-out from “Sharing” for Cross-Context Behavioral Advertising (use of PI from different businesses or services to target advertisements). Colorado has an opt-out from targeted advertising. Nevada “consumers” have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes. You may contact us here to be verified and learn more about your opt-out rights under that law. We may Sell or Share your PI and/or use your PI for Targeted Advertising, as these terms apply under U.S. Privacy Laws. However, we provide Consumers an opt-out of Sale/Sharing/Targeting regardless of state of residency.
Third-Party digital businesses (“Third-Party Digital Businesses”) may associate cookies and other tracking technologies that Collect PI about you on our services, or otherwise Collect and Process PI that we make available about you, including digital activity information. We understand that giving access to PI on our services, or otherwise, to Third-Party Digital Businesses could be deemed a Sale and/or Share and thus we will treat such PI (e.g., cookie ID, IP address, and other online IDs and internet or other electronic activity information) collected by Third-Party Digital Businesses, where not limited to acting as our Service Provider (or Contractor or Processor), as a Sale and/or Share and subject to a Do Not Sell/Share/Target opt-out request. We will not Sell your PI, Share your PI for Cross-Context Behavioral Advertising, or Process your PI for Targeted Advertising if you make a Do Not Sell/Share/Target opt-out request.
Opt-out preference signals (also known as global privacy control or GPC): Some of the U.S. Privacy Laws require businesses to process GPC signals, which is referred to in California as opt-out preference signals (“OOPS”), which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the Sale or Sharing of personal information. To use an OOPS/GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the OOPS/GPC. We have configured the settings of our consent management platform to receive and process GPC signals on our website. We process OOPS/GPC with respect to Sales and Sharing that may occur in the context of Collection of cookie PI by tracking technologies online by Third-Party Digital Businesses, discussed above, and apply it to the specific browser on which you enable OOPS/GPC. We currently do not, due to technical limitations, process OOPS/GPC for opt-outs of Sales and Sharing in other contexts (e.g., non-cookie PI). We do not: (1) charge a fee for use of our service if you have enabled OOPS/GPC; or (2) change your experience with any product or service offered by Telegraph Media Group if you use OOPS/GPC; (3) apart from notifying you that you opted out, display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the OOPS/GPC.
Opt-out for non-cookie PI: If you want to limit our Processing of your non-cookie PI (e.g., your email address) for Targeted Advertising, or opt-out of the Sale/Sharing of such data, make an opt-out request here.
Opt-out for cookie PI: If you want to limit our Processing of your cookie-related PI for Targeted Advertising, or opt-out of the Sale/Sharing of such PI, you need to exercise a separate opt-out request on our cookie management tool or by clicking on the “Do Not Sell or Share My Personal Information” link on the banner of the website and app. This is because we have to use different technologies to apply your opt-out of cookie PI and to non-cookie PI. Our cookie management tool enables you to exercise such an opt-out request and enable certain cookie preferences on your device. A similar tool is available for our app, which you can access via the Do Not Sell/Share/Target option in the settings menu. You must exercise your preferences on each of our websites and apps you visit, from each browser you use, and on each device that you use. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to enable them again via our cookie management tool. Please also refer to Section 11 for other ways to exercise preferences regarding Third-Party Digital Businesses. Beware that if you use ad blocking software, our cookie banner may not appear when you visit our services and you may have to use the link above to access the tool.
We do not knowingly Sell or Share the PI of Consumers under 16, unless we receive affirmative authorization (“opt-in”) from either the Consumer who is between 13 and 16 years old, or the parent or guardian of a Consumer who is less than 13 years old. If you think we may have unknowingly collected PI of a Consumer under 16 years old, please Contact Us.
We may disclose your PI for the following purposes, which are not a Sale or Share: (i) if you direct us to disclose PI; (ii) to comply with a Consumer rights request you submit to us; (iii) disclosures amongst the entities that constitute Telegraph Media Group as defined above, or as part of a Corporate Transaction; and (iv) as otherwise required or permitted by applicable law.
Except to the extent we have a basis for retention under applicable law, you may request that we delete your PI. Our retention rights include, without limitation:
- to complete transactions and services you have requested;
- for security purposes;
- for legitimate internal Business Purposes (e.g., maintaining business records);
- to comply with law and to cooperate with law enforcement; and
- to exercise or defend legal claims.
Please also be aware that making a deletion request does not ensure complete or comprehensive removal or deletion of PI or content you may have posted.
Note also that, depending on where you reside (e.g., California), we may not be required to delete your PI that we did not Collect directly from you.
Consumers may bring inaccuracies they find in their PI that we maintain to our attention, and we will act upon such a complaint as required by applicable law. You can also make changes to your online account in the account settings section of the account. That will not, however, change your information that exists in other places.
We do not engage in Automated Decision Making or Profiling.
To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, use our Consumer Rights Request Portal, or e-mail us here, and respond to any follow-up inquiries we make. Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.).
As permitted or required by applicable U.S. Privacy Laws, any request you submit to us must be an authenticated or Verifiable Consumer Request, meaning when you make a request, we may ask you to provide verifying information, such as your name, e-mail, phone number and/or account information. We will review the information provided and may request additional information (e.g., transaction history) via e-mail or other means to ensure we are interacting with the correct individual. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), Right to Delete, or Right to Correction request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. We do not verify opt-outs of Sell/Share/Target or Limitation of Sensitive PI requests unless we suspect fraud.
We verify each request as follows:
- Right to Know (Categories) (available for California residents only): We verify your Request to Know Categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. If we cannot do so, we will refer you to this Notice for a general description of our data practices.
- Right to Know (Specific Pieces): We verify your Request To Know Specific Pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you and may require a signed declaration under penalty of perjury that you are the Consumer whose PI is the subject of the request. If you fail to provide requested information, we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know Categories Request if you are a California resident.
- Do Not Sell/Share/Target & Limit SPI: No specific verification required unless we suspect fraud.
- Right to Delete: We verify your Request to Delete to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized deletion. If we cannot verify you sufficiently to honor a deletion request, you can still make a Do Not Sell/Share/Target and/or Limit SPI request.
- Correction: We verify your Request to Correct PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized correction.
To protect Consumers, if we are unable to verify you sufficiently we will be unable to honor your request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority to submit requests on your behalf, and of you. You can learn how to do this, emailing us here. In order to, submit an agent request, the agent must provide us with written permission signed by the Consumer or a lawful power of attorney, when you submit the request or in response to our confirmation email if you did not submit it with the request. In certain instances, we may require the Consumer to verify their own identity directly with us or directly confirm with the Consumer that they provided the agent with permission. In certain circumstances, we may require additional information or documentation. Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable U.S. Privacy Laws.
Residents of Colorado, may appeal Telegraph Media Group’s decision regarding a request by replying to our Response.
Some PI that we maintain is insufficiently specific for us to be able to associate it with a verified Consumer (e.g., clickstream data tied only to a pseudonymous browser ID). We do not include that PI in response to those requests if we cannot associate it with a verified Consumer. If we deny a request, in whole or in part, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we Process to respond to your Consumer request(s). In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
Consistent with applicable U.S. Privacy Laws and our interest in the security of your PI, we will not deliver to you more sensitive PI such as your account password or payment information in response to a Consumer privacy rights request; however, you may be able to access some of this information yourself through your account if you have an active account with us.
We will not discriminate or retaliate against you in a manner prohibited by applicable U.S. Privacy Laws for your exercise of your Consumer privacy rights. If you wish to delete some or all of your PI, and wish to remain in a Notice of Financial Incentive Program (as explained below), you are able to do so. We may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable PI.
We may offer discounts or other rewards (“Incentives”) from time-to-time to Consumers that register to view articles (“Registrants”) on our Service. We collect certain pieces of PI from Registrants, such as name, phone number, e-mail address, IP address, or location which are used to administer the Incentives to Registrants and reasonably necessary to provide the Incentives. You may opt-in to Incentives by registering to access a limited number of free articles a month (subject to our standard terms and conditions, or other loyalty and Incentive programs we may offer from time-to-time (“Program(s)”). Each Program is subject to our standard terms and conditions and may have additional terms (“Program Terms”), available on the specific Program page or at Program sign-up. The Incentives will be described in the Program page, or at Program sign-up. As the value of the Incentive may change from time to time, please review the current applicable Program Terms. We measure the value of your PI collected in the Program as value of the advertising revenue generated per article view by a U.S. Registrant. We value the Program as the additional revenue generated per article view. We deem the value of the PI to be reasonably related to the value of the Incentive, and by subscribing to these Programs you indicate you agree. If you do not agree to the Program Terms and do not agree that the value of your PI collected is reasonably related to the value of the Incentive, do not subscribe to the Programs. If you subsequently wish to withdraw from the Programs, the method for doing so will be explained in the Program terms or you may contact us by email at email@example.com, and you may withdraw at any time. We do not limit Program participation to consumers that do not exercise their CCPA rights. However, if you submit a deletion request, and inform us that you wish to remain in the program, we will retain the PI necessary to administer the Program. If you do not want us to retain your information to administer the Program, then we will also terminate your participation in the Program.
Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your rights under U.S. Privacy Laws. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.
In addition to the CCPA, certain Californians are entitled to certain other notices, as follows:
This Notice provides information on our online practices and your California rights specific to our online services. Without limitation, Californians that visit our online services and seek to acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:
(1) California Minors
Although our services are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our services, and posted content on the service, can request removal by contacting us, detailing where the content is posted and attesting you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines we do not control.
(2) Shine the Light
We may share “personal information,” as defined by California’s “Shine the Light” law, with third parties for such third parties own direct marketing purposes. California residents may opt-out of this sharing by contacting us at firstname.lastname@example.org. You must put the statement “Shine the Light Request” in the body of your correspondence. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. This right is different than, and in addition to, CCPA rights, and must be requested separately. However, a Do Not Sell/Share/Target opt-out is broader and will limit our sharing with third parties for their own direct marketing purposes without the need for making a separate Shine the Light request. We will not accept Shine the Light requests by telephone or by fax, and are not responsible for requests not labeled or sent properly, or that are incomplete.
If you have any questions, comments, or concerns about our U.S. privacy practices, please contact as outlined in Section 14. Please note that e-mail communications will not necessarily be secure; accordingly, you should not include sensitive information in your e-mail correspondence with us.
© Telegraph Media Group February 21, 2023. All Rights Reserved.
6.4 We are a shareholder in The Ozone Project (“Ozone”), which is an advertising and audience platform part-owned by Telegraph Media Group along with other publishers.
Ozone and its data management providers set cookies to collect information to build audience segments so that Ozone can serve targeted advertisements on our websites and those of other publishers.
6.5 We may use selected data management providers for our own purposes such as and/or similar to those described in 6.4, above.
6.6 We have no access to third party cookies and third party organisations have no access to ours. The third party organisations that place cookies, including your browser (such as Google), Ozone, data management providers and the third party companies who pay for advertising and analytics services using this information, will have their own privacy policies.
7. Managing your cookies preferences
7.1 Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates. We also provide our own cookie management tool for you to make more specific choices about how cookies are used for your visits to our site..
7.2 We also use third party cookies, as will your browser. These are cookies that may be read by third parties (for example if you have used social sign-on and have the option to like or comment using your social media account). If you would prefer to just restrict third party cookies, here is our cookie management tool: