This Privacy Policy applies to visitors who use our websites, apps, and other digital platforms. It explains how we collect, use, and protect personal data about you, and outlines how you can exercise your legal rights. In this Privacy Policy, “we”, “us”, and “our” refer to SurgeZirc Media, which operates this platform.
What is personal data?
Personal data may include, but is not limited to: Your name, address, year of birth, or title. Debit or credit card details. Information about your devices, such as IP address. How you browse and interact with our websites. Details of products or services you purchase.
What data do we process about our visitors?
If you register for an account on our website—for example, to comment on articles, enter competitions, or receive selected newsletters—you will be asked to provide your full name, email address, year of birth, and postcode.
If you wish to comment on our website, you will also need to choose and provide a commenting name.
If you subscribe to one of our paid products or services, we will collect your name, email address, year of birth, billing address, and payment card details.
If you contact our Customer Services team, we will collect your name, contact details, and information relating to your enquiry so that we can respond appropriately.
Automatically collected data
We collect data about visitors to our websites using technologies such as cookies, device identifiers, IP addresses, and location data. This information may include your approximate location, the type of device you use, and your browsing activity on our sites.
Data from third parties
In some cases, we receive additional information about you from third parties. This information may come from publicly available sources, such as the electoral roll, or from other sources where you have agreed for your data to be shared with third parties.
We may compare our database of registered users with data held by these third parties to identify potential matches. Where a match is found, we may collect and store additional information—such as inferred interests or lifestyle indicators—to help us better understand the products and services that may be relevant to you.
We may also link this third-party information with cookie data and group it into interest-based segments or profiles. These profiles help us improve our products and services and deliver more relevant advertising. In some cases, we may share these anonymised segments with other publishers so that relevant advertising can be shown to you on their websites. We may also combine our segments with those from other publishers to display advertising across multiple websites while limiting how often you see the same adverts.
The information we collect helps us to:
Better understand the likely characteristics and interests of our website visitors
Improve the relevance and suitability of advertisements shown to you
Social media data
We may access information related to your social media interactions with us, such as when you like our pages, share our content, or follow us on social platforms. If you choose to sign in to our website using a social media account, you grant that platform permission to share certain information with us. Depending on your settings and the platform used, this may include basic account details such as your name, email address, date of birth, and other information you choose to make available.
Third-party purchases
We may also collect information about third-party products or services you purchase after visiting our website. For example, this may occur when you use a voucher code or click through to an advertiser’s website from one of our pages.
How we use your data
We use your data for the following purposes:
Verifying your identity, for example when you return to the website and are already logged in.
Personalising advertising so that the ads you see are more relevant to you.
Improving the design, functionality, and performance of our website.
Informing you about products, services, or promotional offers you may find interesting, where you have chosen to receive such communications.
Sending service-related messages about your subscription or account (such as password reset notifications), via email, on-site messages, or push notifications.
Responding to comments or content you submit on our message boards, blogs, or other user-generated content features.
Enabling content sharing through social media or email.
Sending newsletters and personalised communications that you have explicitly consented to receive.
Administering competitions and promotions, including notifying you if you are successful.
Conducting market research to improve our services.
Providing access to subscriptions and managing your account.
Handling queries or complaints submitted to our customer services team. Please only provide sensitive information (such as health, race, or religion) if you are comfortable with us using it to manage your enquiry.
Sending push notifications from our apps, where enabled.
Ensuring accurate commission payments from advertising partners that help support our journalism.
We also collect information about service errors or interruptions you may experience. This helps us identify issues, implement fixes, and make technical improvements to our website.
How we may contact you
From time to time, we may contact you by email or push notification to provide important service information, such as:
Notifications about your subscription ending
Alerts if your payment method has expired
With your permission, we may also contact you to:
Send newsletters or updates
Share information about events, subscription benefits, or special offers
Notify you when new stories are published
Occasionally, we may invite you to participate in market research or contact you in response to a query or complaint you have submitted.
Our legal basis for processing personal data.
Consent
Where you have given us your consent, we will process your personal data for advertising and marketing purposes, content and service personalisation, analytics (such as understanding who our readers are and how they use our websites), and to track eCommerce purchases.
This may include using data provided by you and by our partners for profiling and revenue-generation purposes, which helps us improve our products and services.
If you have consented to receive newsletters, you can withdraw your consent at any time by clicking the unsubscribe link at the bottom of each email or by logging into your account and managing your email preferences.
Legitimate interests
We process personal data where it is necessary for our legitimate interests, such as analysing website traffic to maintain and improve our services. This includes monitoring page performance, successful page loads, and error messages.
Performance of a contract
When you purchase a subscription or any other product or service from us, we process your personal data as necessary to fulfil our contract with you. For example, we use your name and address to deliver physical products.
How can you access and update your personal information on our website?
If you are a registered user or subscriber, you can access and update your personal information by signing in to your account or through your linked social network provider.
You may also request a copy of the personal data we hold about you, or ask for your data to be deleted, by contacting customer services.
How long do we keep your personal information?
We retain personal data only for as long as it is relevant and necessary for the purposes for which it was collected.
If your account has been inactive for 12 months, we may contact you to confirm whether it is still in use. If not, your account may be deleted. Any comments associated with the account will also be removed.
If you do not open newsletters you are subscribed to, your details will be suppressed from the relevant mailing list after six months.
If you begin but do not complete a social registration, the data entered will be deleted within 24 hours. Data from any other incomplete registration or subscription attempt will not be stored.
If you purchase a subscription, we will retain your data for at least 12 months after the subscription ends to address any billing or customer service matters.
Records of customer service enquiries are kept for a minimum of three years from the date of submission.
Cookie data and associated third-party data are retained for 13 months from the date they are collected.
We may retain personal data for longer where required to comply with legal obligations or to establish, exercise, or defend legal claims.
Who will we share your personal information with?
We may share your personal information with our sister companies.
From time to time, advertisers and advertising networks require data to help them select and deliver relevant advertisements to you and other users. We may provide advertisers with aggregated and anonymised cookie information about users with certain characteristics (for example, reporting that 500 men under the age of 30 clicked on a particular advertisement in a single day). This aggregated data may also be used to help advertisers target audiences with specific interests or demographics (for example, individuals aged 30 to 45 in the UK who are interested in purchasing a new home).
We may share cookie data with other publishers through a secure data management platform when advertising campaigns are delivered across multiple news websites. These publisher partners cannot access or view the data directly; they are only able to serve advertisements on their own websites to users whose cookie data falls within selected advertising segments.
We reserve the right to disclose your personal information where required to comply with applicable laws, regulations, or lawful requests from government or regulatory authorities.
Your personal information may also be shared with third-party service providers engaged to perform services on our behalf that involve data processing, such as delivering emails you have subscribed to. We work only with service providers that offer appropriate safeguards to ensure your data is stored and processed securely.
We may be required to disclose personal information where we are legally obligated to do so, including in response to court orders.
In the event of a sale, merger, consolidation, reorganisation, transfer of assets, or change of control of our business, we may transfer, sell, or assign any of the information described in this Privacy Notice to relevant third parties.
Using children’s personal data
We do not aim for our services to be used by children under the age of 13. We do not allow children under 18 to register an account with us.
Will your data be sent overseas?
As you may be aware, the internet does not observe national borders. Online services are accessible worldwide, meaning that the collection and transfer of personal data is not always limited to a single country.
By using this website, as well as the websites of our partners or any third-party sites linked from it, you acknowledge and agree that your personal data may be processed in, or transferred to, countries outside your own jurisdiction, including the United States.
We ensure that any transfer or storage of personal data outside the UK, EU, or US is carried out using Standard Contractual Clauses or other appropriate safeguards approved by the relevant regulatory authorities.
Your rights
You have the following rights in relation to your personal data:
Right of access – to request a copy of the personal data we hold about you.
Right of rectification – to request correction of any inaccurate or incomplete data.
Right to erasure (right to be forgotten) – to request that your personal data be deleted.
Right to restriction of processing – to request limits on how we process your data.
Right to data portability – to request that your data be transferred to another organisation.
Right to object – to object to processing where we rely on legitimate interests.
Right to withdraw consent – to withdraw your consent at any time.
Please note that these rights are not absolute and may be subject to certain legal exemptions.
Exercising your rights, raising questions, or expressing concerns
To exercise your rights or if you have any questions or concerns regarding how your personal data is handled, please submit your request by emailing our Customer Service at info@surgezirc.co.uk.
