Last Updated: May 28th, 2019
This is “our site” and related mobile applications. We use your personal data for many reasons, from understanding how our users engage with and use our site to making informed decisions about our marketing and advertising. These are the main reasons why we collect and use data about our users:
- To provide quality content;
- To provide the services you sign up for, such as subscriptions;
- To carry out marketing analysis and send you communications when we have your permission, or when permitted by law
- To enable us to show advertisements on our sites.
We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics :
- Information about your rights and our obligations
- Clarity about our dealings with you and transparency about how we collect and use your personal data
- Commitments on how we protect your personal data
- Commitments on how we will facilitate your rights and respond to your questions.
We will continue to examine how we can provide more clarity to our users about our use of data.
- your name, date of birth, email address, postal address, phone number, mobile number;
- credit card and debit card details;
- information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based); and
- information relating to your personal circumstances and how you use our sites, apps and services.
Who we are and how to contact us
The data controller for our sites and apps is Deltratraf Ltd. 3rd Floor, C & H Towers, Corner of Great Marlborough and Great George Streets, Roseau, Dominica. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us, you can find our contact details in the “How to contact us” section below.
What personal data we collect and how we use it
We collect personal data when you sign up for our services and when you browse our sites or use our apps. This information is used to provide our site and other services, display advertising and analyze how visitors use our sites or apps. The personal data we collect when you register for an account with our site.
- your email address;
- your username
- your photograph, if you add one to your profile page.
- your IP address
- a numerical code to identify your device and which can provide information about the country, region or city where you are based;
- your browsing history of the content you have visited on our sites, including information on how you were referred to our sites via another website; and
- details of your devices, for example, the unique device ID, unique advertising ID and browsers used to access our content.
Some of our services, may give you the option of providing more information about your preferences, so that we can tailor your experience. Signing up for membership may also mean you need to provide other details.
We will not collect special categories of data - such as information about your race, political opinions, religion, health or sexual orientation - unless you have chosen to provide that information to us.
Using our apps
Our app uses information on the content you have viewed. You can delete this history in the settings of the app. Information on what you have viewed in the app and information on bugs and crashes is also sent to us. You can choose to receive notifications on your mobile device via the app. You can manage these notifications in the settings of the app.
How we collect personal data
We collect personal data when you:
- register an account on our site;
- enter our competitions and surveys;
- sign up to our email list;
- sign up for marketing communications;
- use mobile devices to access our content;
- access our sites, through cookies and other similar technology; and
- when you contact us via email, social media, our apps or similar technologies or when you mention us on social media.
Why we use your personal data
We use personal data collected through our sites and apps for a number of purposes, including the following:
- To provide the services you sign up for. We also use the personal data for related internal administrative purposes - such as our accounting and records - and to make you aware of any changes to our services.
- To send marketing communications when we have your permission, or when permitted by law.
- To personalize our services (for example, so you can sign in), remembering your settings, displaying personalized advertising as well as measuring how effective our online adverts are, recognizing you when you sign in on different devices and tailoring our marketing communications based on what you view on our site.
- To carry out marketing analysis, for example we look at what you have viewed on our sites and apps and what products and services you have bought (including what you have looked at and what products or services you have bought on our other platforms) to better understand what your interests and preferences are, and to improve our marketing by making it more relevant to your interests and preferences. You can opt out from having your personal data used for marketing analysis by emailing.
- To improve our marketing communications, we use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email.
- To sell advertising space on our sites.
- For statistical purposes such as analyzing the performance of our sites and apps and to understand how visitors use them.
- To respond to your queries and to resolve complaints.
- To comply with applicable laws and regulations.
Access permissions that we ask from users of Our app
When you use our app, we ask for the following permissions to access particular functions of your mobile device:
- For the Android version, we ask for permission to access your contact details/profile on your mobile device, so that we can add or find your Account on your phone.
- For the iOS version, we ask for permission to save pictures to your photo library, so that you can save pictures that you find in our articles on your mobile device.
Legal grounds for using your personal data
We will only use your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal data. In every case, the legal ground will be one of the following:
- Consent: For example, where you have provided your consent to track your history of views. You can revoke consent any time you want just by clearing cookies in your browser. After cookies will be removed we will ask you again before tracking your history.
- Our legitimate interests: Where it is necessary for us to understand our users, promote our services and operate our sites and apps efficiently for the creation, publication and distribution of news, media and related content both online and in print form, globally. For example, we will rely on our legitimate interest when we analyze what content has been viewed on our sites and apps, so that we can understand how they are used. It is also in our legitimate interest to carry out marketing analysis to determine what products and services may be relevant to the interests of our readers. You can opt out from having your personal data used for marketing analysis by emailing.
- Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
Updating your personal data and your profile page on our sites
When you register for an account with our site, you may have access to a profile page. Under “edit profile” you can review what information is public when you comment on our content, or if people look up your profile. You can also update your information or provide extra information if you want.
Personal data that we receive about you from other organizations
Adding to or combining the personal data you provide to us
Data for persons under 18
This Website is not intended for minors. You will only access the Website or register if you are at least 18-years old and have reached the age of majority in the country where you live if that age happens to be greater than 18. We prohibit all persons who do not meet the age requirements from accessing the Website. Minors will not access the Website or use its services.
We do not knowingly collect any information about children, minors, or anyone under the age of majority. Nor do we knowingly market to children, minors, or anyone under 18-years old. If you are under 18-years old, we ask that you do not submit information to us. If we become aware that a child, minor, or anyone under 18-years old has registered with us and provided us with personal information, we will take steps to cancel that person’s registration. If we do cancel a registration because you breached our no children rules, we may keep your email and IP address to make sure that you do not try to get around our rules by creating a new account.
In accordance with 47 U.S.C. § 230(d), we notify you that parental control protections (including computer hardware, software, or filtering services) are commercially available that may assist in limiting access to material that is harmful to minors. You may find information about providers of these protections on the Internet by searching “parental control protection” or similar terms. If minors have access to your computer, please restrain their access to sexually explicit material by using any of the following products, which we provide for informational purposes only and do not endorse: CYBERsitter™ | Net Nanny® | CyberPatrol | ASACP.
Security of your personal data
We have implemented appropriate technical and organizational controls to protect your personal data against unauthorized processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.
Who we share your personal data with
We do not share your personal data with other people or organizations that are not directly linked or affiliated to us except under the following circumstances:
- To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- We may share your data with other organizations that provide services on our behalf such as dealing with online payments and other forms of payment processing, i.e. credit card transactions, online bank payments and preventing fraud.
- We may also share your data with our advertising partners, as set out in the section about Online Advertising below.
- We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organization if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
Any organizations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.
We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do this.
Some of our webpages use social plug-ins from other organizations (such as the “Facebook Recommend” function, Twitter’s retweet function, Google+ function). These other organizations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, information they collect may be connected to your account on their site. For more information on how these organizations use personal data, please read their privacy policies.
Third Party-Payment Processors
International data transfers
Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:
- We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.
- We may also use specific approved contracts with our service providers that are based in countries outside the EEA. These contracts give your personal data the same protection it has in the EEA.
- Where we use service providers in the United States, we may transfer personal data to them if they are part of the Privacy Shield scheme, which requires them to provide a similar level of protection of your personal data to what is required in the EEA.
If you are located in 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 EEA.
How long we keep your personal data
How we may contact you
Responding to your queries or complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
Cookies and similar technology
When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technology. A cookie is a small file that can be placed on your device that allows us to recognize and remember you.
Advertising on our sites that is based on cookies and similar technology.
We use personalized online advertising on our sites. This allows us to deliver more relevant advertising to people who visit our site. It works by showing you adverts that are based on your browsing patterns and the way you have interacted with our sites and apps. It then shows you adverts which we believe may interest you.
When you browse our sites or use our apps, some of the cookies and similar technology we place on your device are advertising cookies, so we can understand what sort of pages you are interested in. We can then display advertising on your browser based on these interests.
We do not collect or use information such as your name, email address, postal address or phone number for personalized online advertising.
We may also share online data collected through cookies and similar technology with our advertising partners. This means that when you are on another website, you may be shown advertising based on your browsing patterns on our site. We may also show you advertising on our site based on your browsing patterns on other sites that we have obtained from our advertising partners.
Online retargeting is another form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with a site away from our sites.
For example, if you have visited the website of an online clothes shop, you may start seeing adverts from that same shopping site displaying special offers or showing you products you were browsing. This allows companies to advertise to you if you leave their website without making a purchase.
Your California privacy rights
Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family or household purposes, you may ask us about the information we release to other organizations for their marketing purposes. To make such a request, please send an email with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal data we revealed to other organizations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal data shared in this way is covered by Section 1798.83 of the California Civil Code.
Canada Privacy Rights
We comply with Canadian Federal and Provincial privacy laws and regulations including the Personal Information Protection and Electronic Documents Act.
Residents of Canada are notified that the personal information they provide to us is stored in our databases outside of Canada including in the United States and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country.
If you need to contact us about your personal information or believe that we have violated your privacy rights, please email. You may visit www.priv.gc.ca for more information about your privacy rights.
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