Privacy Policy
The Independent renamed its 'Premium' content tier to 'member exclusive' articles and restructured reading options into three named tiers: free/registered 'Standard Access' (still requires consenting to ad-tracking), and two paid ad-free options, 'Ad Free subscription' and 'All Access membership'. The document does not state whether Standard Access costs money — it's grouped with free browsing as the ad-supported path. The free-account article allowance now appears to reset monthly instead of weekly. Separately, customer service records are now kept twice as long (six years instead of three), a couple of mandatory service-message examples were broadened, and a link labeled as going to Amazon's APS privacy policy now redirects through a marketing domain instead. Most remaining edits are cosmetic: contact details, typo fixes, an added 'right to complain' item, and a refreshed date.
Customer service records now kept twice as long
If you contact customer service, that record used to be deleted after three years. Now the company keeps it for six years.
“A record of a customer service query is retained for at least six years from the date it was submitted to us.”
Free article limit now resets monthly instead of weekly
If you read free 'member exclusive' articles with a registered account, your allowance used to refresh every week. It now refreshes once a month, which could mean fewer free articles over time unless the actual number allowed was also increased (the document doesn't say).
“If you want to receive a select number of member exclusive articles a month you will need to register for an account.”
Amazon privacy policy link now redirects through a marketing domain
A link that displays and is labeled as Amazon's APS privacy policy now actually sends you through a geni.us redirect link instead of straight to Amazon's page, making it harder to know exactly where you're being sent.
“The APS Privacy Notice can be found [here](http://buy.geni.us/Proxy.ashx): [https://aps.amazon.com/aps/privacy-policy/](http://buy.geni.us/Proxy.ashx)”
What you can do — To see APS's actual privacy policy, type https://aps.amazon.com/aps/privacy-policy/ directly into your browser instead of clicking the link.
More required messages you can't opt out of
The company already reserved the right to send certain service messages you can't unsubscribe from, like payment failures. Now that list explicitly includes messages about what's included in your subscription too.
“For example, to tell you what's included in your subscription or if your subscription is changing, or your payment method has expired.”
| 27 | 27 | Exercising your rights, asking questions and raising concerns |
| 28 | 28 | |
| 29 | 29 | Contact details for exercising your rights, asking questions and raising concerns |
| 30 | 30 | |
| 31 | 31 | At _The Independent_ we respect your privacy and are committed to protecting your personal information. This privacy policy is for visitors to our websites, apps and other digital platforms. It sets out how we collect, use, disclose, and protect personal data that we hold about you. It also gives information on how to exercise your legal rights. In this policy 'we' and 'our' means Independent Digital News and Media Limited. |
| 32 | 32 | |
| 33 | There are now two ways to read our content. Either you can choose to consent to us using your data to serve you targeted advertising, or alternatively we offer the choice to read our content ad free and without advertising tracking cookies enabled, by paying for a subscription. | |
| 33 | There are now several ways to read our content. If you wish to browse _The Independent_ website for free or with a Standard Access membership, we provide a choice for you to consent to the use of cookies and similar technologies which we will use to serve relevant personalised advertising and to improve our service. Alternatively we offer the choice to read our content ad free and without advertising tracking cookies enabled, by purchasing either an Ad Free subscription or an All Access membership. | |
± CHANGEDReading tiers restructured and renamed The policy now describes three ways to access content instead of two: browsing for free or with a 'Standard Access' membership (both still require consenting to ad-tracking cookies), or paying for an 'Ad Free subscription' or an 'All Access membership' (both ad-free). The text does not state whether Standard Access itself costs money — it's described alongside free browsing as the ad-supported option, while 'purchasing' is only tied to Ad Free and All Access. | ||
| 34 | 34 | |
| 35 | 35 | The majority of _The Independent_'s articles are free to read if you consent to us processing your personal data for advertising purposes. That means when you provide us with your personal data, you allow us to improve your experience of our products and services as well as helping to support our quality independent journalism. |
| 36 | 36 | |
| 37 | 37 | You can withdraw your consent at any time by clicking on the 'Privacy Settings' in the footer of any page. If you do withdraw your consent, the cookie banner will appear again and you will be asked to choose how you would like to browse _The Independent_. |
| 38 | 38 | |
| 39 | 39 | Personal information is any information that can identify you and can include: |
| 40 | 40 | |
| 41 | 41 | - Your name, email address, and year of birth, home address (if you've asked us to send something to your home address). |
| 42 | 42 | - Information about your device (your computer, mobile, tablet etc). For example your unique device ID, advertising ID, type of browser, and IP address. An IP address is a numerical code which identifies your device. It can provide information about the country, region or city where you are based. |
| 43 | 43 | - How you browse our websites, such as the pages you visit and links you click on. |
| 44 | - Details of products or services you buy, for example a subscription to _The Independent_. | |
| 44 | - Details of products or services you buy, for example a membership to The Independent. | |
| 45 | 45 | - Debit or credit card details if you buy a product or service (these are collected via a secure third party payment provider and are not held on our systems). |
| 46 | 46 | |
| 47 | 47 | When we refer to "personal information" in this policy, we are referencing "personal data" as defined under UK and EU data protection law, as well as "personal information" as it is defined under California law. |
| 48 | 48 | |
| 49 | 49 | We collect your personal information in one of the following ways, in line with the relevant data protection laws: |
| 50 | 50 | |
| 54 | 54 | 4. Information we receive about you from other organisations, including social media logins. |
| 55 | 55 | |
| 56 | 56 | More information about this is set out below. |
| 57 | 57 | |
| 58 | 58 | 1) Personal information you provide directly to us. |
| 59 | 59 | |
| 60 | _When you register for an account to read Premium articles._ | |
| 60 | _When you register for an account to read member exclusive articles._ | |
| 61 | 61 | |
| 62 | If you want to receive a select number of Premium articles a week you will need to register for an account. We will ask for your first name, email address, password and year of birth. Readers under the age of 18 should not register for an account. | |
| 62 | If you want to receive a select number of member exclusive articles a month you will need to register for an account. We will ask for your first name, email address, password and year of birth. Readers under the age of 18 should not register for an account. | |
± CHANGEDFree article allowance now resets monthly instead of weekly 'Premium articles' were renamed 'member exclusive articles', and the free allowance you get by registering an account now resets on a monthly basis rather than a weekly one. The document doesn't say if the actual number of free articles changed, so it's unclear if this means fewer free articles overall. | ||
| 63 | 63 | |
| 64 | 64 | _When you comment on our website_ |
| 65 | 65 | |
| 66 | 66 | If you plan to comment on our website, you will need to register for an account and provide us with a commenting name. When you comment publicly on an article on our site, we would recommend you don't share any sensitive personal information. We are not responsible for the information you choose to post online. Please see a link to our Community Guidelines on commenting [here](https://independent.co.uk/service/community-guidelines-a6075176.html). |
| 67 | 67 | |
| 68 | _When you take out a subscription or attend an event_ | |
| 68 | _When you purchase a membership or attend an event_ | |
± CHANGEDSection heading updated for membership terminology A section heading was reworded to use 'membership' language, consistent with the new tier names. | ||
| 69 | 69 | |
| 70 | 70 | If you are subscribing to one of our paid-for products, in addition to your name, email address, password and year of birth, you will also need to provide your billing address and payment card information. Your payment details are not held on our systems. Instead they are handled by a secure, trusted third party provider. |
| 71 | 71 | |
| 72 | 72 | We may also collect this information if you attend one of our paid-for ticketed events. |
| 73 | 73 | |
| 74 | 74 | If you attend one of our virtual events, we will share your full name, prefix and email address with the platform hosting the event. We may share your company name but only if you choose to provide this. |
| 90 | 90 | 2) Information from your devices |
| 91 | 91 | |
| 92 | 92 | _Cookies and other online identifiers_ |
| 93 | 93 | |
| 94 | 94 | We collect data about our website's visitors using technology such as cookies, device IDs, IP addresses and general location or country. This may include your IP address, information about your browser or operating system and will include your email (only ever in secure 'hashed', pseudonymous form). If you would like to know more about our use of cookies and how to manage them, please read our [Cookie Policy](https://independent.co.uk/service/cookie-policy-a6184186.html). |
| 95 | 95 | |
| 96 | If you have purchased one of our subscriptions, this next section does not apply to you. If you accept the use of advertising cookies on our website, then when you use our website and enter your email address on our website (either to log in, or to sign up for a newsletter, or similar), we may share information that we collect from you with trusted partners. This may include your IP address, information about your browser or operating system or your email (only ever in secure 'hashed', pseudonymous form). Our partners use this information to create an online identification code to be able to recognise you on your devices. This code may be shared with advertising companies to enable interest-based and targeted advertising, that is more relevant to you. This code does not contain any of your directly identifiable personal data and will not be used to re-identify you. We and the below partners process your data to create this code as joint controllers under data protection law. | |
| 96 | If you have purchased an All Access membership or an Ad Free subscription , this next section does not apply to you. If you accept the use of advertising cookies on our website, then when you use our website and enter your email address on our website (either to log in, or to sign up for a newsletter, or similar), we may share information that we collect from you with trusted partners. This may include your IP address, information about your browser or operating system or your email (only ever in secure 'hashed', pseudonymous form). Our partners use this information to create an online identification code to be able to recognise you on your devices. This code may be shared with advertising companies to enable interest-based and targeted advertising, that is more relevant to you. This code does not contain any of your directly identifiable personal data and will not be used to re-identify you. We and the below partners process your data to create this code as joint controllers under data protection law. | |
± CHANGEDAd-tracking exemption now names both paid ad-free tiers (cookie partners section) The section on sharing hashed data with ad partners (LiveRamp, Trade Desk) previously exempted anyone with 'one of our subscriptions'. It now names the two ad-free paid tiers specifically. This lines up with the new tier structure (there are now two ad-free paid options instead of one) rather than appearing to remove anyone's existing exemption. | ||
| 97 | 97 | |
| 98 | 98 | Detailed information on our partners' data processing activities is available in their privacy policies by clicking below. |
| 99 | 99 | |
| 100 | 100 | [LiveRamp](https://liveramp.com/opt_out/) |
| 101 | 101 | |
| 102 | 102 | To opt-out of your data being used by LiveRamp in this way, please visit [https://liveramp.com/opt\_out/](https://liveramp.com/opt_out/) |
| 104 | 104 | [Trade Desk](https://www.transparentadvertising.eu/) |
| 105 | 105 | |
| 106 | 106 | To opt out of your data being used by The Trade Desk in this way, please visit [https://www.transparentadvertising.eu/](https://www.transparentadvertising.eu/) |
| 107 | 107 | |
| 108 | 108 | When you enter your email address to create an account or sign-up to a newsletter or marketing, we may also share your email address in a hashed form with Amazon Publisher Services (APS). APS then links this hashed email to a profile which they may already hold related to that email address. The hashed email will be used in a secure, pseudonymised form within a cookie to flag to APS whenever you visit The Independent site. APS will use this to determine, in real-time, if any of their business customers want to market to a profile similar to yours. If this is the case they may initiate an advert which will appear to you on The Independent website. |
| 109 | 109 | |
| 110 | The APS Privacy Notice can be found [here](http://buy.geni.us/Proxy.ashx): [https://aps.amazon.com/aps/privacy-policy/](https://aps.amazon.com/aps/privacy-policy/) | |
| 110 | The APS Privacy Notice can be found [here](http://buy.geni.us/Proxy.ashx): [https://aps.amazon.com/aps/privacy-policy/](http://buy.geni.us/Proxy.ashx) | |
± CHANGEDAPS privacy policy link now redirects through a different domain A link whose visible text is Amazon's APS privacy policy URL now technically points to a geni.us redirect link instead of directly to Amazon's page. | ||
| 111 | 111 | |
| 112 | 112 | Please see our [Cookie Policy](https://independent.co.uk/service/cookie-policy-a6184186.html) for more information. |
| 113 | 113 | |
| 114 | 114 | We are signed up to the latest version of IAB Europe's Transparency and Consent Framework (TCF) version 2.2 and comply with its specifications and policies. What this means is that we treat the personal information that we and our partners collect through cookies in a transparent and data privacy compliant way. |
| 115 | 115 | |
| 116 | 116 | _Market research, user testing panel and surveys_ |
| 122 | 122 | We may ask you to attend face-to-face Zoom interviews with us or a partner that we have commissioned on our behalf. However, participation is voluntary and you are free to decline the invitations at any time. We may also send you links to short surveys and your responses to these surveys will be anonymous. If you agree to be a part of the panel, we will re-contact you after a year to ask if you wish to continue to be a part of the panel and give you a chance to opt out. |
| 123 | 123 | |
| 124 | 124 | We may use the feedback you provide in our surveys or as part of our user testing panel, as quotes on our website, or in internal and external presentations in connection with the research study and our publications. However where we do this we will ensure that the quote is anonymous - unless you give us your permission to use your name, photograph or screenshots of you during any Zoom interviews. |
| 125 | 125 | |
| 126 | 126 | 3) Information we generate about you. |
| 127 | 127 | |
| 128 | When you register for an Independent account, take out a subscription for The Independent or sign up for one of our newsletters, we assign you a unique ID number. We use your unique ID to recognise you when you are logged in. We also use it to ensure we remember your preferences such as which newsletter you have signed up to. | |
± CHANGED'Subscription' term clarified to include 'membership' The document clarifies that 'subscription' is now used as shorthand for both subscriptions and memberships. | ||
| 128 | When you register for an Independent account, take out a subscription or membership (subsequently referred to as a 'subscription') for The Independent or sign up for one of our newsletters, we assign you a unique ID number. We use your unique ID to recognise you when you are logged in. We also use it to ensure we remember your preferences such as which newsletter you have signed up to. | |
| 129 | 129 | |
| 130 | 130 | For readers who have not registered or subscribed, and are browsing our site anonymously, we assign you a unique ID number based on your device which remembers your browsing behaviour. This ID cannot identify you unless you then register or subscribe, after which we will link your anonymous browsing behaviour to your ID. This is so we can offer you a more personalised and engaging experience when you register or subscribe. |
| 131 | 131 | |
| 132 | 132 | We also assign you a unique ID number which remembers your browsing behaviour. This includes how long you spend on an article, what types of articles you read (e.g. travel, politics, sports and so on) and how many, as well as how often you visit our website or app. This is so we can personalise the site and our communications to you, and where you have consented to this, we also deliver tailored advertising that is more relevant to your interests. |
| 133 | 133 | |
| 134 | 134 | We provide each reader with a cookie ID for analytics purposes, so we can recognise when you come back on to our site using one of your devices such as your laptop or mobile phone. We do this so we know how many individuals come back to our site. |
| 154 | 154 | We only conduct market research and send you surveys if you have consented to this. |
| 155 | 155 | |
| 156 | 156 | We will send you push notifications from our apps, and/or send you browser notifications when you are visiting our app or website, only where you have consented. |
| 157 | 157 | |
| 158 | 158 | We will only process your data for marketing purposes to inform you about our products, services or promotional offers that you might find interesting where you have consented to this. |
| 159 | 159 | |
| 160 | Unless you have purchased one of our subscriptions, you will be required to provide your consent to us processing your personal data for targeted advertising in order to access our content. The remaining paragraphs of this section apply to such non-subscribers. | |
| 160 | Unless you have purchased an All Access membership or an Ad Free subscription, you will be required to provide your consent to us processing your personal data for targeted advertising in order to access our content. The remaining paragraphs of this section apply to such non-subscribers. | |
± CHANGEDAd-tracking exemption now names both paid ad-free tiers (advertising section) The same wording update appears again in the targeted-advertising section, replacing the generic 'one of our subscriptions' with the two named ad-free tiers. | ||
| 161 | 161 | |
| 162 | 162 | We may tailor advertising you see on our website based on the type of articles you read, so it is more relevant to your interests. We do this by allocating your ID to relevant interest groups or segments based on your reading behaviour. For example, if you have read three articles about travel or commented on a travel article in the last 30 days, or if you have visited a travel website prior to coming onto our website we may place your ID into the travel segment, and you will subsequently be shown more travel-related advertising. If your reading behaviour is similar to that shown for our travel audience, we may include your ID in our 'lookalike' travel segment for some campaigns. |
| 163 | 163 | |
| 164 | 164 | We will never use any sensitive data (also known as special category data) for this purpose. Please read our [Cookie Policy](https://independent.co.uk/service/cookie-policy-a6184186.html) for more information about this. |
| 165 | 165 | |
| 166 | 166 | We may personalise advertising to you based on the information that you provide us when you register for an account. For example, we may aggregate your age (based on year of birth that you provide us when you register) into groups e.g. 24-35 year olds, if an advertiser would like to target their ad campaigns to this demographic. As well as using your online browsing behaviour and your demographic information to personalise the advertising you receive, we may also use this aggregated information for reporting and analytics purposes. For example, to see how well a particular ad campaign has performed. |
| 182 | 182 | - Logging and using information about any service errors or interruptions that you have experienced in order to help us create fixes and to make technical improvements to our website. |
| 183 | 183 | - Security and fraud prevention. |
| 184 | 184 | - Verifying your identity and remembering you (for example when you return to the website and have already logged in). |
| 185 | 185 | - Enabling you to share our content with others using social media or email. |
| 186 | 186 | - Administering competitions and informing you if you have been successful in any competitions or promotions. |
| 187 | 187 | - Keeping you updated about our products and services, in line with your communication preferences. |
| 188 | - Monitoring the number of Premium articles you read as a registered user on The Independent website. This is so we can request users subscribe once they have read the maximum number of Premium articles over a given period of time. | |
| 189 | - Monitoring the number of articles you read on The Independent app. This is so that we can request users subscribe once they have read the maximum number of articles on the app. | |
− REMOVEDApp article-monitoring purpose removed from the list A bullet stating that the company monitors how many articles you read in the app (to prompt a subscription) was removed. The website equivalent bullet remains, reworded for 'member exclusive' articles. | ||
| 188 | - Monitoring the number of member exclusive articles you read as a registered user on The Independent website. This is so we can request users subscribe once they have read the maximum number of member exclusive articles over a given period of time. | |
| 190 | 189 | - Analysing what articles you have read so we can improve our content and make recommendations to you. |
| 191 | 190 | - Improving the design and style of the website. |
| 192 | 191 | - Responding to your feedback on our products, services and website and app functionality |
| 193 | 192 | - Ensuring that we are paid the correct amount of commission by our advertising partners if you buy a product or service from our website. |
| 194 | 193 | - Allowing us to measure advertising campaigns, ensure readers do not see the same advertisements too many times, and ensure advertisements are served in appropriate environments for our clients. |
| 195 | 194 | |
| 204 | 203 | ## **How can you access and update your personal information?** |
| 205 | 204 | |
| 206 | 205 | If you are a registered user or subscriber, you can update your personal information by signing in to your account page. In all other cases, please contact [Customer Services](https://help.independent.co.uk/hc/en-us). |
| 207 | 206 | |
| 208 | 207 | You can also ask for a copy of the personal information we may hold about you, or for your data to be deleted via the above Customer Services form. |
| 209 | 208 | |
| 210 | If you wish to contact us by telephone, our number is 0203 615 2990. | |
| 209 | If you wish to contact us by telephone, our number is **0204 634 5020**. | |
± CHANGEDCustomer service phone number changed The listed phone number for contacting the company was updated. | ||
| 211 | 210 | |
| 212 | 211 | We will keep your information only for as long as it is relevant and useful for the purpose for which it was originally collected. |
| 213 | 212 | |
| 214 | 213 | If your account appears to have not been used for two years, we will try and contact you to check whether it is still in use and/or we will delete it. Please note that any comments associated with your account will also be deleted. |
| 215 | 214 | |
| 216 | 215 | If you do not read the newsletters that you have subscribed to, we will suppress your name from the relevant list after six months. |
| 217 | 216 | |
| 218 | 217 | If you purchase a subscription, we will retain your data for at least 12 months after your subscription ends in case there are any outstanding billing or other customer service issues. |
| 219 | 218 | |
| 220 | A record of a customer service query is retained for at least three years from the date it was submitted to us. | |
| 219 | A record of a customer service query is retained for at least six years from the date it was submitted to us. | |
± CHANGEDCustomer service records kept twice as long Records of customer service queries are now kept for six years instead of three. | ||
| 221 | 220 | |
| 222 | 221 | We retain cookie data and corresponding third party data for 13 months from when it was collected from your device. For more information about cookies, please read our [Cookie Policy](https://independent.co.uk/service/cookie-policy-a6184186.html). |
| 223 | 222 | |
| 224 | We may need to retain your data for a longer period if there is a legal claim or if we are required to so by any regulation. We may also retain your personal information to ensure we do not contact you if you have asked us not to. | |
| 223 | We may need to retain your data for a longer period if there is a legal claim or if we are required to do so by any regulation. We may also retain your personal information to ensure we do not contact you if you have asked us not to. | |
| 225 | 224 | |
| 226 | 225 | We are fully committed to keeping your personal information safe and we take measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction. However, as you will appreciate, no data transmission or storage system can be guaranteed as 100% secure. |
| 227 | 226 | |
| 228 | 227 | _Sharing with the Group's companies_ |
| 229 | 228 | |
| 230 | 229 | We may disclose your personal information to our sister companies: Independent Digital News and Media LLC and Evening Standard Limited. |
| 260 | 259 | You should be aware that by using the website and those of our partners or any website we link through to, your personal data may be processed in or transferred to other countries, the USA for example, and you agree to your personal data being transferred or processed in this way. |
| 261 | 260 | |
| 262 | 261 | Your personal data will only be stored or transferred within the UK, EEA, US or other countries using Standard Contractual Clauses, or other safeguards that have been approved by the relevant regulatory body. |
| 263 | 262 | |
| 264 | 263 | If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the UK or the EEA. |
| 265 | 264 | |
| 266 | We will contact you in accordance with your preferences. From time to time we may contact you by email or browser or app push notification to give you service information. For example, if your subscription is changing, or your payment method has expired. You will not be able to opt-out from receiving these service messages unless you no longer wish to use the services. | |
| 265 | We will contact you in accordance with your preferences. From time to time we may contact you by email or browser or app push notification to give you service information. For example, to tell you what's included in your subscription or if your subscription is changing, or your payment method has expired. You will not be able to opt-out from receiving these service messages unless you no longer wish to use the services. | |
± CHANGEDMandatory service-message examples broadened The example list of service messages you cannot opt out of now also includes messages telling you what's included in your subscription, in addition to the existing examples. | ||
| 267 | 266 | |
| 268 | If we have your permission we may also send you newsletters or emails about our events, subscription benefits or new launches and website developments. | |
| 267 | If we have your permission we may also send you newsletters or emails about our events, new launches or website developments. | |
± CHANGEDOptional marketing email topics narrowed 'Subscription benefits' was removed from the list of topics covered by opt-in newsletters/emails, slightly narrowing what marketing emails may cover. | ||
| 269 | 268 | |
| 270 | You can manage your preferences and subscriptions to newsletters and emails by signing into to your Independent account. You can also unsubscribe at any time by clicking the link in the footer of the email (or also at the top of emails if you use Yahoo or Gmail). When you unsubscribe from marketing emails, we will add your email to a list to make sure we don't send you any marketing information going forward. For more help on managing your account, visit our [help centre](https://help.independent.co.uk/hc/en-us/categories/360000889833-My-Account). | |
| 269 | You can manage your preferences and subscriptions to newsletters and emails by signing into your Independent account. You can also unsubscribe at any time by clicking the link in the footer of the email (or also at the top of emails if you use Yahoo or Gmail). When you unsubscribe from marketing emails, we will add your email to a list to make sure we don't send you any marketing information going forward. For more help on managing your account, visit our [help centre](https://help.independent.co.uk/hc/en-us/categories/360000889833-My-Account). | |
| 271 | 270 | |
| 272 | 271 | Occasionally we may ask you if you would like to participate in market research or respond to you if you have made a complaint or have logged a query. |
| 273 | 272 | |
| 274 | 273 | Right of access - you can ask for a copy of the data that we hold about you. |
| 275 | 274 | |
| 276 | 275 | Right of rectification - you can ask us to correct data that we hold about you that is inaccurate or incomplete. |
| 282 | 281 | Right of portability - you can ask for us to transfer the data we hold about you to another company. |
| 283 | 282 | |
| 284 | 283 | Right to object - you can object to us using your data where we are relying on a legitimate interest to use it. |
| 285 | 284 | |
| 286 | 285 | Right to withdraw your consent - you can withdraw your consent at any time. |
| 287 | 286 | |
| 288 | Please note that these rights are not absolute and certain may exemptions apply. For more information about these rights, please visit the ICO's website at: [https://ico.org.uk/for-the-public/](https://ico.org.uk/for-the-public/). | |
| 287 | Right to complain - you can make a complaint if you are unhappy with how we've handled your data. | |
+ ADDED'Right to complain' added to the list of data rights A new right was added to the list explaining you can complain if unhappy with how your data was handled. | ||
| 289 | 288 | |
| 289 | Please note that these rights are not absolute and certain exemptions may apply. For more information about these rights, please visit the ICO's website at: [https://ico.org.uk/for-the-public/](https://ico.org.uk/for-the-public/). | |
| 290 | ||
| 290 | 291 | We will respond to your requests within one calendar month as per our statutory obligations. |
| 291 | 292 | |
| 292 | 293 | We may ask for proof of identity to be able to proceed with your request in order to meet our data protection obligations. We do not usually charge for making a request, but we may charge a fee in accordance with the relevant laws in certain circumstances. |
| 293 | 294 | |
| 294 | 295 | Please note the Independent is a media organisation and publisher. This means we may be subject to certain exemptions under data protection law when we process personal data for the purposes of journalism. These exemptions apply to some of the ways the Independent uses personal data. This privacy policy does not cover personal data that the Independent processes for the purposes of journalism. |
| 295 | 296 | |
| 302 | 303 | You provide this directly to us when registering or taking out a subscription. We also obtain this from partners, service providers or public sources. |
| 303 | 304 | |
| 304 | 305 | Purpose: To register or subscribe to the Independent, to manage your account; respond to your inquiries or requests and communicate with you; to send you email newsletters and push notifications if you choose to receive these; running our events; providing customer services; verifying customer information; administering competitions, customisation of ads to make the advertising on our sites more relevant. |
| 305 | 306 | |
| 306 | 307 | _Internet or other electronic network activity information_ |
| 307 | 308 | |
| 308 | Examples: Browsing history, search history, geolocation data and information regarding your interaction with website, app, or advertisement - through use of cookies or similar technologies. | |
| 309 | Examples: Browsing history, search history, geolocation data and information regarding your interaction with a website, app, or advertisement - through use of cookies or similar technologies. | |
| 309 | 310 | |
| 310 | 311 | Purpose: Personalising our site and advertising to make it more relevant to you, marketing and promoting products and services, tailoring our communications to you, improving our understanding of readers to ensure the best content and services |
| 311 | 312 | |
| 312 | 313 | _Personal Characteristics_ |
| 313 | 314 | |
| 314 | 315 | Examples: In some circumstances, we may collect PI that is considered protected under U.S. law, such as age and gender. We abide by the legal requirements imposed under applicable law in regard to such information. You either provide this to us or we infer it from information we hold about you. |
| 378 | 379 | You may also use an authorized agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify your identity, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney. |
| 379 | 380 | |
| 380 | 381 | We endeavour to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. |
| 381 | 382 | |
| 382 | 383 | Please note that some of these rights are not absolute and exemptions may apply in certain circumstances. |
| 383 | 384 | |
| 384 | ## **Exercising your rights, asking questions and raising concerns** | |
| 385 | ## **Exercising your rights, asking questions and raising complaints** | |
± CHANGEDComplaints section renamed and clarified A section heading was renamed from 'raising concerns' to 'raising complaints', and a sentence was expanded to explicitly reference making a complaint. | ||
| 385 | 386 | |
| 386 | 387 | If you have any queries or comments about this privacy policy, or you would like to make a request, please contact us using our online form available here: [Customer Services](https://help.independent.co.uk/hc/en-us/requests/new). |
| 387 | 388 | |
| 388 | If you're unhappy with how we've handled your data or your request, please get in touch with us in the first instance using our online form: [Customer Services](https://help.independent.co.uk/hc/en-us/requests/new). You may also get in touch with our Data Protection Officer. Their contact details are in the table below. If you're still not satisfied with our response, you have the right to complain to the Information Commissioner's Office (ICO) whose contact information is also provided in the table below. | |
| 389 | If you're unhappy with how we've handled your data or your request and you would like to make a complaint, please get in touch with us in the first instance using our online form: [Customer Services](https://help.independent.co.uk/hc/en-us/requests/new). You may also get in touch with our Data Protection Officer. Their contact details are in the table below. If you're still not satisfied with our response, you have the right to complain to the Information Commissioner's Office (ICO) whose contact information is also provided in the table below. | |
| 389 | 390 | |
| 390 | 391 | Contact Name: **Information Commissioner's Office** |
| 391 | 392 | |
| 392 | 393 | Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom |
| 393 | 394 | |
| 394 | 395 | Contact Info: 0303 123 1113; [https://ico.org.uk/concerns/](https://ico.org.uk/concerns/) |
| 395 | 396 | |
| 396 | 397 | Contact name: Nicola Mckilligan-Regan |
| 397 | 398 | |
| 398 | 399 | Address: Alphabeta Building, 14-18 Finsbury Square, London, United Kingdom, EC2A 1AH |
| 399 | 400 | |
| 400 | Contact info: [dpo@independent.co.uk](mailto:dpo@independent.co.uk) | |
| 401 | Contact info: dpo@independent.co.uk | |
| 401 | 402 | |
| 402 | 403 | If you are based in the EEA please contact our EU Representative: |
| 403 | 404 | |
| 404 | 405 | Contact name: IDNML EU Representative |
| 405 | 406 | |
| 406 | 407 | Address: IDNML EU REP c/o Kazient Privacy Experts, 77 Lower Camden Street, Dublin, Ireland, D02 XE80 |
| 407 | 408 | |
| 408 | Contact info: [idnml.eurep@kazient.eu](mailto:idnml.eurep@kazient.eu) | |
| 409 | Contact info: idnml.eurep@kazient.eu | |
| 409 | 410 | |
| 410 | 411 | We may make changes to this policy at any time, and where necessary we will inform you of these changes via email. We will display the date the policy was last updated on this page. |
| 411 | 412 | |
| 412 | **Last updated - July 2024** | |
| 413 | **Last updated - September 2026** | |
± CHANGEDMinor wording, typo, and formatting fixes; date refreshed Several small typo corrections (e.g. 'certain may exemptions' to 'certain exemptions may apply', 'sign into to' to 'sign into'), removal of mailto hyperlink formatting on two email addresses, and the 'Last updated' date changed from July 2024 to September 2026. | ||