The Lady Ltd. Privacy Policy

Version: 05.2018

The Lady Ltd., (The Lady) 39-40 Bedford Street, Strand, London WC2E 9ER respects the privacy rights of its users and customers and recognise the importance of protecting their personal data.

1 What Information We Collect and Process

1.1 Information about Your Person

The type of “Personal Information” and its amount varies depending on the service offered and in some cases this information can be collected and processed by third parties for the sole purpose of providing the service requested by the user.

1.2 Account information on the editorial website (lady.co.uk)

The Lady will collect your address and your e-mail address. The provision of this information is necessary to register an account and to use the website and its services.

1.2.1 Online competitions submission on the editorial website

The Lady may collect additional information such as name, surname and telephone number. If the competition is organised by a third party company, you will be asked to accept and allow The Lady to share this information with the third party company.

1.3 Account information on our online Jobs Board (jobs.lady.co.uk)

The Lady will collect your title, first name, surname, address, e-mail address and telephone number.

1.3.1 Vacancy application

The Lady will collect additional personal data for the purpose of assisting in the recruitment process. This data consists of information as follows (which list may not be exclusive) where appropriate: date of birth, sex, nationality (which item of information The Lady is required by law to collect), current remuneration level, education history, work history and all other details comprising your curriculum vitae ('CV') as submitted by the user, details of available jobs, plus the user's responses to assessments administered through the website and the results of such assessments. Additionally, The Lady collects personal information from users via enquiry and application forms and also on each occasion that users e-mail details to The Lady. Supplementary information relevant to the recruitment service which The Lady provides may also be collected by The Lady, including a record of any contact The Lady may have with candidates in the course of recruitment assignments and details of reference checks, education verification and other recruitment-related research which The Lady may effect. Where necessary, The Lady will pass your data to prospective or intended employers for the purpose of recruitment.

1.4 Competitions submission from the Magazine

The Lady will collect your title, first name, surname, address, e-mail address and telephone number. If the competition is organised by a third party company, The Lady will sort the winner/s and will only share his/their information with the third party company. The number of winners may vary depending on the number of prizes to be won.

1.5 Survey participation

The Lady will collect additional personal information that may change from time to time, depending on the nature of the survey.

1.6 Advertisement placing

The Lady will collect your title, first name, surname, address, e-mail address, telephone number, billing information (when different from the personal information provided) and payment details. Depending on the payment method chosen, The Lady may receive or share this information with external providers. The Lady may also collect additional details included in your advertisement.

1.7 Magazine subscription

The Lady will collect your title, first name, surname, address, e-mail address, telephone number, billing information (when different from the personal information provided) and payment details. The Lady may receive or share this information with external providers and suppliers.

1.8 Information about the User’s Device

To enable the connection of the user’s device to our servers, we may collect and process technical information related to your device, such as IP address, operative system and web browser version.

1.9 Cookies and Similar Technology

1.9.1 General Information

Websites, digital products and online content offered by The Lady may use cookies and other similar technologies. Cookies are small files downloaded to your device. Cookies help us to ensure the safety and smooth functionality of our services (security cookies and session cookies) and to collect information about the preferences of users in order to make our online offers more attractive for users (tracking cookies).

The security and session cookies that we serve are necessary to provide you with the online services you have requested. For example, we serve cookies that enable us to authenticate you when you use your account and to maintain your online session. We also serve cookies that enable us to remember any preferences you have chosen. The websites also serves cookies that are required in order to make the shopping basket function available.

Most browsers are automatically set to accept cookies. You can often set your browser to notify you when you are sent a cookie and you may also be able to elect not to accept cookies by changing the designated settings on your User Device. However, not utilising cookies may prevent you from using certain functions and features. Apart from cookies that are necessary for the provision of our services, the websites, digital products and online content offered by The Lady may use tracking cookies. If we use tracking cookies, we will inform you about the use of and details of such tracking cookies and describe the available options to enable or disable such tracking cookies in the respective privacy policies.

1.9.2 Google Analytics

Our websites, digital products and/or online features use Google Analytics, a web analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google"). Google Analytics uses cookies that are stored on your computer and facilitate the analysis of your use of our websites, the digital products and the online features. The information generated by the cookie about your use of our websites, the digital products and the online features is transmitted to Google and stored by Google on servers located in the United States. If IP anonymisation has been activated, the IP address of users located within a country of the European Union or in other states contracting to the Agreement on the European Economic Area will be shortened. Only in exceptional cases will a complete IP address be transferred to a Google server in the United States and shortened there. IP anonymisation is activated. On our behalf, Google will use this information for the purpose of evaluating the websites, the digital products and the online features for us, in order to compile reports on the activity on the websites, the digital products and the online features, and to provide other services relating to the activity and internet usage for us. Google will not associate the IP address transferred in the context of Google Analytics with any other data held by Google.

For further information please visit https://support.google.com/analytics/answer/6004245.

2 How Information Is Used – Purposes of Processing

2.1 Providing the Service

We collect and further process the information we collect in order to:

  • Register your accounts and to provide you with access to your accounts and the related online services;
  • Set up the connection of your device and applications on your device with our servers;
  • Delivery your copy/copies of the Magazine;
  • Process orders and requests;
  • Provide consumer support.

2.2 Fraud Prevention and Prevention of Other Illegal Activities

We may process the collected information as far as necessary to prevent fraud, potentially illegal or offensive activities, or to enforce our rights or the rights of our users. The legal basis for this processing is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the prevention of fraudulent and illegal activities; the protection of our systems and networks and of our users; and the enforcement of our legitimate rights and rights of our users.

You have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right you may at any time contact us as provided in Section 9 of this Privacy Policy.

2.3 Usage Information

"Usage Information" as referred to in this Section 2.3 includes all information submitted through our online systems as well as all information collected and processed when using any of our other services.

2.3.1 Provision of the Services

We process the usage Information for the provision of the services. The legal basis for the processing referred to in this Section 2.3.1 is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).

2.3.2 Products and Services Improvement

We process the usage Information (excluding, however, your payment data) to perform analytics and statistics of the usage of the services in order to improve and optimise our services and our products, and our performance.

The legal basis for this processing is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the improvement and optimisation of our services and of our products and performances which is to the benefit of the users.

You have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right you may at any time contact us as provided in Section 9 of this Privacy Policy.

2.4 Cookies and Similar Technologies

2.4.1 General Information

The legal basis for using security and session cookies as explained in Section 1.9.1 above is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).

When you access our websites that use tracking cookies (see above Section 1.9.1) while logged into your accounts and if you have not objected to the use of such tracking cookies, information received via such tracking cookies may be combined with your other information obtained through your accounts and used for the purposes as described in Section 2.3 above.

2.4.2 Google Analytics

The legal basis for using Google Analytics (see above Section 1.9.2) and for analysing usage of our service is Art. 6 para. 1 (f) GDPR. The legitimate interest we pursue is the improvement and optimisation of our services for the benefit of our users. You have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right you may at any time contact us as provided in Section 9 of this Privacy Policy.

With regard to websites using Google Analytics, you can prevent the collection of data about the use of the website (including your IP address) generated by the cookie and the processing of data by Google, by downloading and installing the browser plug-in through the following link: http://tools.google.com/dlpage/gaoptout

If you do not object to the use of Google Analytics, information received via Google Analytics may be combined with your other information obtained through your account and used for the purposes as described in Section 2.3 above.

3 Marketing and Advertising Messages

Subject to your separate consent, The Lady may send you marketing and advertising messages about products of The Lady Ltd. or third parties to your email address. You can withdraw your consent to receive marketing and advertising messages as described above at any time by changing your newsletter subscription settings in your editorial website or online Jobs Board accounts accordingly, or by clicking the “Unsubscribe” link displayed at the bottom of any newsletter.

4 User Communications

When you send an email or other communication to The Lady, we use those communications in order to process your inquiries and respond to your requests. The legal basis for this processing is the provision of the service you have requested (Art. 6 para. 1 (b) GDPR).

5 Who Has Access to Your Information

The lady will share your information with external suppliers or third party companies in accordance with this Privacy Policy as follows:

  • “DBF” Data Base Factory a wholly owned subsidiary of CCA International: subscription fulfilment (names, addresses, billing information and payment details);
  • William Gibbons, Magazine printer and subscription handling (names and addresses);
  • Air Business, postal suppliers responsible for mailing the copies both UK and overseas (names and addresses);
  • i-subscribe, third party sellers of Magazine subscriptions (names and addresses);
  • Jelly Fish, third party sellers of Magazine subscriptions (names and addresses);
  • Unique, third party sellers of Magazine subscriptions (names and addresses);
  • Exact Editions: processing and fulfilment of electronic editions of The Lady (names and addresses and payment details);
  • Magazine Company: fulfilment of electronic subscriptions (names and addresses and payment details);
  • ABC Magazine: auditing verification (names and addresses of selected subscribers);
  • Sage Pay https://www.sagepay.co.uk, online payment (see above Section1.6);
  • Paypal https://www.paypal.com, online payment (see above Section1.6);
  • Third-party companies that organise a competition (see above Sections 1.2.1 and 1.4);
  • Recruiters and customers of our online Jobs Board or our TLR department (see above Section1.3.1).

6 Storage Time

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or – where the applicable law provides for longer storage and retention period – for the storage and retention period required by law. After that your personal data will be deleted.

In particular:

  • If you terminate any of your accounts by deleting them in the account settings or by contacting us as provided in Section 9 of this Privacy Policy, your personal data will be deleted. Please note that The Lady is required to retain certain transactional data you used under statutory commercial and tax law for a period of up to ten (10) years.
  • If you exercise a right to object to the processing of your personal data, we will delete your personal data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.

7 Security

The Lady is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold.

8 Your rights under GDPR

In particular, but without limitation, you may have the following rights under applicable European data protection law:

  • Right of access: You have the right to obtain confirmation from us as to whether or not we process personal data from you and you also have the right to at any time obtain access to our personal data stored by us. To exercise this right you may at any time contact us as provided in Section 9 of this Privacy Policy. You can also access the information you provided in the settings of your Accounts.
  • Right to rectification of your personal data: If we process your personal data, we shall endeavour to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which we collected your personal data was collected. If your personal data is inaccurate or incomplete, you have the right to obtain the rectification of such data. To exercise this right you may at any time contact us as provided in Section 9 of this Privacy Policy. You can also change the information you provided in the settings of your Accounts.
  • Right to erasure of your personal data or right to restriction of processing: You may have the right to obtain the erasure of your personal data or the restriction of processing of your personal data. To exercise this right you may at any time contact us as provided in Section 9 of this Privacy Policy. You can also delete your information at any time by deleting your Accounts in the account settings. The deletion of your Accounts will lead to a termination of the Account Agreement and prevent you from using the The Lady’s online Services.
  • Right to withdraw your consent: If you have given your consent to the processing of your personal data or of the personal data of your child below the age of 16 years, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal. To exercise this right you may at any time contact us as provided in Section 9 of this Privacy Policy or you may use the withdrawal mechanism provided within the respective The Lady Services.
  • Right to data portability: You may have the right to receive the personal data concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit those data to another controller. To exercise this right you may at any time contact us as provided in Section 9 of this Privacy Policy.
  • Right to object: You may have the right to object to the processing of your personal data as further specified in this Privacy Policy.
  • Right to lodge a complaint with supervisory authority: You have the right to lodge a complaint with a data protection supervisory authority located in the European Union. You may contact the European Data Protection Supervisor (EDPS).

9 Data Controller

If you have any questions about this Privacy Policy, about The Lady’s data processing activities or if you want to exercise any of your rights under GDPR, please contact:

  • The Lady, 39-40 Bedford Street, Strand, London WC2E 9ER, United Kingdom.
  • info@lady.co.uk.

10 Data Protection Officer

11 Changes to The Lady's Privacy Policy

In the event that The Lady makes privacy policy changes (whether for business reasons or because of legislative changes) such alterations will be posted on these Privacy Policy and Data Privacy Notice pages and may also be announced via the website.