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Privacy Statement
 
Last Update May 24th 2018
 
1 INTRODUCTION
1.1 This website (the “Site”) is operated by Silver Spoon Media Limited (“Sheology” or “SSML”).
 
1.2 This Privacy Statement  together with the Cookie Policy and Terms and Conditions of the Site provides guidance and information to users/visitors of our Website regarding the processing of personal data by Sheology.
 
1.3 The documents referred to in the Privacy Statement and Terms and Conditions sets out the basis on which any personal data we collect from you or that you provide to us (“Data”) in connection with the Site will be processed by us. Please read this Privacy Statement carefully to understand our treatment and use of Data.
 
1.4 The Privacy Statement applies to the operations of this Site operated by Sheology, a company registered in the Republic Of Ireland under number 462564 and having its registered office at 51 Bracken Road, Sandyford, Dublin 18 (hereinafter "Sheology”, "us", "we" or "our").
 
1.5 Sheology and its associated companies are fully committed to protecting and respecting your privacy.
 
1.6 It is the intention of this Privacy Statement to explain to you the information practices of Sheology in relation to the information we collect about you and other users.
 
1.7 In this Privacy Statement, references to “you” means the person whose personal information we collect, use and process.
 
1.8 We will use your Data only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of your Data is in compliance with the Data Protection Acts 1988 and 2003 (as amended) and any subsequent data protection and privacy legislation, European Union Law including Regulation (EU) 2016/679, known as the General Data Protection Regulation or GDPR and any subsequent amendments (collectively referred to as “Data Protection Legislation”).
 
2. IDENTITY OF THE CONTROLLER OF PERSONAL INFORMATION
2.1 For the purposes of the Data Protection Legislation, the Data Controller of the Site is SSML.
 
3 CONTACT DETAILS OF THE DATA PROTECTION OFFICE
3.1 The contact details of the Sheology Data Protection officer are as follows: Email Address: data.protection@sheologydigital.com Address: Sheology Data Protection Office, Sheology, 51 Bracken Road, Sandyford, Dublin 18.
 
4 WHEN DOES THIS PRIVACY STATEMENT APPLY
4.1 This Privacy Statement applies to Data that we collect, use and otherwise process about you in connection with your use of our Website. The Data we process will depend on how you use our Website.
 
5 ACCEPTANCE OF THIS PRIVACY STATEMENT
5.1 By using this Site and by consenting to allow us to process your Data, you consent to the collection, storage, processing, use and disclosure of your Data by us as described in this Privacy Statement. If you do not agree with or are not comfortable with any aspect of this Privacy Statement, your only remedy is to discontinue using our Site. We reserve the right to modify this Privacy Statement at any time. Your continued use of any part of our Site following notification or posting of such changes will constitute your acceptance of those changes.
 
6 INFORMATION WE MAY COLLECT FROM YOU
6.1 When you visit or use the Site in any way, we may collect and process different types of information about you and/or your device.
6.2 We have set out below the different types of Data that we collect. Please note that if you do not provide us with your contact information we will not be able to provide you with any information you request.
 
We may collect technical information including your Internet Protocol (IP) address, browser type and version, operating system and device type. This is collected in an anonymous manner and helps us optimize the site for our users. We may also anonymously collect information about your visit, including the Uniform Resource Locators (URLs) of the pages you visit during your visit, articles you view, length of time on page and referring URL. This is the web page that you came from if you followed a link to our site. This helps us better understand what content appeals to our users and how to best structure our site. When you sign up or register for one of our services we will track and store information about you in order to provide that service. For example, when you subscribe to a newsletter we may collect:
• Your email address and name
• Details of the newsletter emails we send to you that you open, including any links in them that you click on.
 
If you register on our site to access special content, then we will track and store your registration and online identifier details in order to provide you with access to that content.
If you register through Google log in, you grant permission to Google to share basic data from your Google account with us, like your name, email address, and profile picture.
If you remove this website from your Google Settings, we will no longer have access to this information.
If you register through Facebook, you grant permission to Facebook to share your user details with us. This will include your name, email address, date of birth and location.
You can also use your picture from Facebook as part of your profile. If you remove this website from your Facebook Settings, we will no longer have access to this information.
 
If you take part in any competitions we store your contact details with your consent in order to deliver the competition prize if you win. When you enter a competition, survey or poll on this website we may collect;
 
• Your personal details, including your postal addresses, phone numbers & email address. These are required to contact winners.
• Information about you entry, for example type of competition, where you entered, how many times you have entered
 
When you contact us or we contact you or you take part in promotions, competitions, surveys or questionnaires about our Services, we may collect:
• Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email or post
or when you speak with us through social media.
• Details of the emails and other digital communications we send to you that you open, including any links in them that you click on.
• Your feedback and contributions to customer surveys and questionnaires
Our Web Sites may use JavaScript to detect the use of ad blocking extensions for web browsers but does not store or process any personal data.
 
6.3 The Data we collect, the basis of processing and the purposes of processing are detailed below. Sometimes, these activities are carried out by third parties, (see “Disclosure of your Data” section below).
 
7 WHERE WE STORE YOUR DATA
7.1 Your Data may be stored and transferred within the European Economic Area (EEA) or transferred to, and stored in, countries outside the EEA, for example, when one of our service providers use employees or equipment based outside the EEA. The EEA comprises those countries that are in the European Union (“EU”) and some other countries that are considered to have adequate laws to ensure personal data is protected.
7.2 When transferring your Data outside of Ireland or the EEA, we will (and will ensure that service providers acting on our behalf agree to) protect it from improper use or disclosure and ensure the same levels of protection are in place as are applied within Ireland and the EEA.
 
8 USE MADE OF YOUR DATA
8.1 We may use your Data that we hold to:
8.1.1 provide you with general information on our Site and to provide you with personalised services;
8.1.2 sell advertising space on the Site;
8.1.3 provide marketing information with your consent;
8.1.4 provide you with information about your registration or accounts;
8.1.5 provide paid services such as digital edition subscriptions;
8.1.6 provide you with information regarding our events, contests, competitions, promotions or newsletters chosen;
8.1.7 enable you to login to the site, using  your email address, username and the password that you have chosen or your social login;
8.1.8 analyse your online purchases on our websites or partner websites that we have redirected you to (for example, what you have bought, when and where you bought it and how you paid for it).
8.1.9 analyse your online browsing behaviour on our Site, Mobile Apps or email communications based on information about when you click on our content or one of our adverts (including those shown on other organisations’ websites) and information about when you open or click on any of our emails.
8.1.10 ensure that content from our Site is presented in the most effective, responsive and compatible manner for you and for your computer or device;
8.1.11 respond to your requests for information and other communication or correspondence you may submit to us;
8.1.12 improve the services that we provide to you;
8.1.13 provide you with information or services that you request from us;
8.1.14 carry out statistical analysis and market research;
8.1.15 allow you to participate in interactive features of our Site, when you choose to do so;
8.1.16 allow you to participate in competitions either through our Sites or through our Print publications;
8.1.17 investigate any improper use of our services or the network;
8.1.18 carry out activities necessary to the running of Sheology, including systems testing, network monitoring, staff training and quality control; and
8.1.19 notify you about changes to our Site, services or policies.
 
9 DISCLOSURE OF YOUR DATA
9.1 We consider your Data to be private and confidential. Your Personal data may be shared within Sheology, for any of the purposes set out in this Privacy Statement.
9.2 We may access and/or disclose your Data if required to do so by law or in good faith and belief that such action is necessary to: (a) conform with the law or comply with legal process served on us; (b) protect and defend our rights or property including, without limitation the security and integrity of our network and systems; or (c) act under exigent circumstances to protect the personal safety of users of our services or members of the public.
9.3 Service Providers
We use third party service providers who work for us in the provision of our services. In providing the services, your Data will, where applicable, be processed by the service provider on our behalf.
We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your Data. We will have written contracts with them which provide assurances regarding the protections that they will give to your Data and their compliance with our data security standards and international transfer restrictions.
9.4 Disclosure to Third Parties
In certain circumstances, we may share and/or are obliged to share your Data with third parties for the purposes described above and in accordance with Data Protection Legislation.
These third parties include:
• regulatory authorities;
• financial institutions;
• the Revenue Commissioners who, under the Standard for Automatic Exchange of Financial Account Information in Tax Matters (Common Reporting Standard) may share information with the tax authorities of other countries police, public prosecutors;
• auditors;
• relevant industry bodies;
• external professional advisors; and
• others, where it is permitted by law, or where we have your consent.
9.5 The organisations listed in 9.4 will also use your Data as a “Data Controller” – they will have their own privacy notices which you should read, and they have their own responsibilities to comply with applicable Data Protection Legislation.
 
10 RETENTION
10.1 We keep your personal data for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above. The criteria we use to determine data retention periods for personal data includes the following:
10.1.1 Retention in case of queries; we will retain it for a reasonable period after the relationship between us has ceased; and
10.1.2 Retention in accordance with legal and regulatory requirements.
10.2 If you would like further information about our data retention practices, please contact Sheology’s data protection officer (see the “Contact Us” section below).
 
11 LINKS TO OTHER SITES
11.1 Our Site contains links to and from other websites and web platforms. In addition, third parties websites may also provide links to the Site. If you follow a link to any of those websites or web platforms, please note that those websites and web platforms have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.
11.2 We do not accept, and we disclaim, any responsibility for the privacy policies and information protection practices of any third party website (whether or not such website is linked on or to the Site). These links are provided to you for convenience purposes only, and you access them at your own risk. It is your responsibility to check the third party website's privacy statement before you submit any personal data to their websites.
 
12 SECURITY
12.1 We endeavour to use appropriate technical and physical security measures to protect your personal data which is transmitted, stored or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access. Our service providers are also selected carefully and required to use appropriate protective measures.
12.2 As effective as modern security practices are, no physical or electronic security system is entirely secure. The transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Site. Any transmission of Data is at your own risk. Once we receive your Data, we will use appropriate security measures to seek to prevent unauthorised access. We will continue to revise policies and implement additional security features as new technologies become available.
12.3 In the event that there is an interception or unauthorised access to your personal data, we will not be liable or responsible for any resulting misuse of your personal information.
 
13 YOUR RIGHTS
13.1 You may have various rights under Data Protection Legislation. However, in certain circumstances, these rights may be restricted (Article 23 of the General Data Protection Regulation, which is transposed into Irish law by section 54 of the Data Protection Act 2018, sets out the circumstances in which your rights may be restricted).  In particular, your rights may be restricted where this is necessary: (i) for the prevention, detection, investigation and prosecution of criminal offences, and/or (ii) in contemplation of or for the establishment, exercise or defence of a legal claim or legal proceedings (whether before a court, tribunal, statutory body or an administrative or out-of-court procedure).
13.2 Subject to the above, your rights under Data Protection Legislation may include (as relevant): 
Your Right: Right of Access
What does it mean? Subject to certain conditions, you are entitled to have access to your personal data which we hold (this is more commonly known as submitting a “data subject access request”).
How do I execute this right? Requests for such information should be made in writing to to Data Protection Officer by email data.protection@sheologydigital.com and/or by post to Sheology Data Controller, Sheology, 51 Bracken Road, Sandyford, Dublin 18, Ireland. If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
Conditions to exercise? We must be able to verify your identity. Your request may not affect the rights and freedoms of others, e.g. privacy and confidentiality rights of other individuals and/or businesses.
Your Right: Right of Data Portability
What does it mean? Subject to certain conditions, you are entitled to receive the data which you have provided to us and which is processed by us by automated means, in a commonly-used machine readable format.
How do I execute this right? Requests for such information should be made in writing to to Data Protection Officer by email data.protection@sheologydigital.com and/or by post to Sheology Data Controller, Sheology, 51 Bracken Road, Sandyford, Dublin 18, Ireland.  If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
Conditions to exercise? The GDPR does not establish a general right to data portability. This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (e.g. not for paper records). It affects only personal data that was “provided” by you. Therefore, it does not, as a rule, apply to personal data that was created by the Sheology or supplied to the Sheology by any other individual and/or business.
Your Right: Rights in relation to inaccurate personal or incomplete data
What does it mean? You may challenge the accuracy or completeness of personal data which we process about you. If it is found that personal data is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate.
How do I execute this right? We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details. Please always check first whether self-help tools are available. Requests for such information should be made in writing to to Data Protection Officer by email data.protection@sheologydigital.com and/or by post to Sheology Data Controller, Sheology, 51 Bracken Road, Sandyford, Dublin 18, Ireland. 
Conditions to exercise? This right only applies to your own personal data. When exercising this right, please be as specific as possible.
Your Right: Right to object to or restrict our data processing
What does it mean? Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.
How do I execute this right? Requests for such information should be made in writing to to Data Protection Officer by data.protection@sheologydigital.com and/or by post to Sheology Data Controller, Sheology, 51 Bracken Road, Sandyford, Dublin 18, Ireland. 
Conditions to exercise? This right applies only if the processing of your personal data is necessary for the performance of a task carried out in the public interest (see “basis of processing” above). Objections must be based on grounds relating to your particular situation. They must not be generic so that we can demonstrate that there are still lawful grounds for us to process your personal data.
Your Right: Right to have personal data erased
What does it mean? Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”), e.g. where you think that the information we are processing is inaccurate, or the processing is unlawful.
How do I execute this right? Requests for such information should be made in writing to to Data Protection Officer by email data.protection@sheologydigital.com and/or by post to Sheology Data Controller, Sheology, 51 Bracken Road, Sandyford, Dublin 18, Ireland. 
Conditions to exercise? There are various lawful reasons why we may not be in a position to erase your personal data. This may apply (i) where we have to comply with a legal obligation, (ii) in case of bringing legal proceedings or defending legal proceedings, or (iii) where retention periods apply by law or under the Sheology’s internal data retention policies.
Your Right: Right to withdrawal
What does it mean? You have the right to withdraw your consent to any processing for which you have previously given that consent.
How do I execute this right? Requests for such information should be made in writing to to Data Protection Officer by email data.protection@sheologydigital.com and/or by post to Sheology Data Controller, Sheology, 51 Bracken Road, Sandyford, Dublin 18, Ireland. 
Conditions to exercise: If you withdraw your consent, this will only take effect for the future.
 
14 COMPLAINTS
14.1 In the event that you wish to make a complaint about how your personal data is being processed by Sheology, or how your complaint has been handled, you have the right to lodge a complaint directly to the Data Protection Officer by email data.protection@sheologydigital.com and/or by post to Sheology Data Controller, Sheology, 51 Bracken Road, Sandyford, Dublin 18, Ireland.
 
15 YOUR RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
15.1 If you are unhappy about any aspect of the way we collect, share or use your personal data, please let us know using the contact details below. 
15.2 You also have a right to complain to the Office of the Data Protection Commissioner at Canal House, Station Road, Portarlington, Co. Laois by telephone at 1890 25 2231 and/or by email to info@dataprotection.ie.
 
16 CHANGES TO OUR PRIVACY STATEMENT
16.1 We reserve the right to change this Privacy Statement at any time in our sole discretion. If we make changes to this Privacy Statement they will be posted on the Site so that you are always are of what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our website after we post any such changes, you accept and agree to this Privacy Statement as modified.
 
17 CONTACT US
17.1 In the event you have any Questions, comments and requests about the information set out in this Privacy Statement, please contact us by email data.protection@sheologydigital.com and/or by post to Sheology Data Controller, Sheology, 51 Bracken Road, Sandyford, Dublin 18, Ireland.
 
Cookie Policy
 
Last Update May 24th 2018
 
Sheology ("us", "we" or "our") uses a) "cookies" to help us remember details of your visits to our website which can be found at the site URL (the “Site”) and b) SDK (Software Development Kit) “trackers” to help us remember details of your visits to our apps including, but not limited to technical information about your visit e.g. traffic data, location data, browser language, your IP address, the previous website from which you reached us and the type of browser you use. Accordingly, our Privacy Statement will apply to our treatment of the information we obtain via our cookies and trackers.
 
What are cookies?
A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) which collects information, including personal information about you. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of websites. For example, a cookie could allow the Site to recognise your browser/login details, while another could store your preferences and other information and let you navigate the Site effectively. Cookies can also help to ensure that adverts you see online are more relevant to you and your interests.
Statistical and analytical information from cookies and trackers provides us with general and not individually specific information about the number of people who visit this Site; the number of people who return to this Site; the pages that they visit; where they were before they came to this Site and the page in the Site at which they exited. This information helps us monitor traffic on our Site so that we can manage the Site's capacity and efficiency. It also helps us to understand which parts of this Site are most popular, and generally to assess user behaviour and characteristics in order to measure interest in and use of the various areas of the Site.
We may partner with or receive services from third parties which you can visit from our Site. We may also embed external content and features from such third parties within our Site (e.g. social media networks such as LinkedIn, Facebook and Twitter). We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy statements and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
 
CHANGES TO OUR COOKIE POLICY
We can change this Cookie Policy at any time. If we make material changes to this Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Site or by sending you an email.
It is important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookies Policy, then we cannot continue to provide the Site to you, and your only option is to stop accessing the Site.
 
TYPES OF COOKIES
We may place our cookies on your device via our website. Our Privacy Statement will apply to how we treat the information we collect through cookies. The following are the main types of cookies used on the Site:
 
ESSENTIAL COOKIES
These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, filling in forms or serving contextual ads. The types of essential cookies used are:
GDPR Consent Cookie
A simple cookie to track whether you have reviewed and consented to the latest version of our privacy policies
Registration cookies
When you register with our Site, we generate cookies that signal whether you are signed in or not. Our servers use these cookies to work out which account you are signed in with, and if you are allowed access to a particular service. It also allows us to associate any comments you post with your username. While you are signed into this Site, we combine information from your registration cookies with analytics cookies, which we could use to identify which pages you have seen on our Site.
This website currently includes the use of the following first party cookies:
PHPSESSID – this identifies a user's session and allows them to provide relevant content through browsing experience. Also, it is required for login. Disabling it will prevent some functions from working properly, and login will not work.
remember_me – this remembers if a user has requested automatic login next time they visit the website. Disabling it will make automatic login impossible.
attention-closed, digest_closed and others - required to remember closed dialogs, like newsletter subscription, etc. Disabling them will make dialogs appear again.
 
In addition, this website uses Google Analytics (_ga), Facebook (fb) and certain third party cookies that are set by third parties we use for different services (for example, website analytics or advertising). These cookies are required to distinguish you from other users of our website, and help us to provide you with a good user experience when you browse our website, while also allowing us to improve our site. 
 
BEHAVIOURAL ADVERTISING COOKIES
These cookies may be set through our site and other sites you visit around the web by third-party advertisers. They may be used by those third parties to build a profile of your interests and show you relevant adverts here and on other sites across the web. These profiles are based on identifying your IP address, browser or internet device.
We create anonymous audience segments based on interactions with our Site which can be tied back to a single cookie or device ID. We use cookie technologies provided by Google DoubleClick for Publishers (DFP) to assist us in creating these audience segments. We have no possibility of linking any anonymous user of our Site who may be classified into an audience segment to an individual identifiable person.
We facilitate third parties to serve advertisements through our Site. Advertisers try to make these ads relevant to you by tracking the topics you are interested in and other ads that you like to engage with across the web. Most of these third parties participate in the Interactive Advertising Bureau (IAB) Transparency and Consent Framework, which means that you can in one place manage your privacy settings around behavioural advertising. Google DoubleClick for Publishers is our primary ad serving partner and Google provides its own mechanism for controlling how ads are personalised to you.
Manage your consent for advertisers participating in the Interactive Advertising Bureau (IAB) framework and Google ad settings in Privacy Settings below.
The expiry date for the IAB Advertising Framework Cookie is 6 months.
Google anonymize IP addresses in logs by removing part of the address after 9 months. After 18 months, they further anonymize log data by anonymizing or deleting cookie or advertising ID information in both logs and ad serving databases.
User data tied to cookies and advertising IDs is also used to detect and prevent ad fraud and ensure that users don’t see ads that they’ve blocked in the past. In these cases, or in cases where Google stores this data on behalf of its customers (e.g. in Google Analytics), data may be stored for periods longer than those specified above.
 
SOCIAL MEDIA COOKIES
Social Media providers use electronic tools including ‘Cookies’, ‘Social Plugins‘ and ‘Tracking Pixels’ to track your browsing habits, likes and social interactions across the internet in order to build up a profile about you. We enable these on our site to facilitate social sharing.
Cookies utilised on the Site are from:
The expiry date for Twitter cookies is 30 days and 90 days for Facebook cookies.
 
Change Your Privacy Settings
Your privacy is important to us. Please use the tools on this page to control how your data is processed on this website and around the web:
Change settings for cookies and trackers
Most of the websites and apps you visit use electronic tools including ‘Cookies’, ‘Social Plugins‘ and ‘Tracking Pixels’ to enhance your experience, to provide information to the owners of the site about how the site is performing, to serve more relevant content and advertising and to facilitate sharing of content on social media.
Some of these electronic tools may need to collect and process personal data in order to function correctly. If you switch off or block these tools, elements of our site will not work correctly for you
Cookies are set through this website for a number of purposes:
 
 
Essential Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems.
Click on a link below to see the privacy policy attached to each cookie type:
 
Analytics
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.
Click on a link below to see the privacy policy and manage your consent across the web for each cookie type:
 
Behavioural Advertising Cookies
These cookies may be set through our site and other sites you visit around the web by third-party advertisers.
If you do not allow these cookies, you will experience less relevant advertising.
You can manage your data settings for advertising across the web in two main ways:
Manage consent for advertisers participating in the Interactive Advertising Bureau (IAB) privacy framework http://www.youronlinechoices.com/ie/your-ad-choices
Manage consent for advertising served through Google https://policies.google.com/technologies/partner-sites
 
Unruly Group Ltd (https://unruly.co/privacy/)
 
 
Social Media Cookies
We enable these cookies on our site to facilitate social sharing of our content.
Click on a link below to manage your privacy around the web with these social media providers:
 
Browser Cookie Settings
Most web browsers allow some control of cookies through the browser settings. Find out how to manage cookies on popular browsers:
 
To find information relating to other browsers, visit the browser developer's website.
 
 

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