This policy explains our approach to digital information collection, storage and use in connection with all our digital content. We are committed to protecting your privacy. GCN will ensure that it keeps all personal data you provide to us in accordance with our obligations under the Data Protection Acts 1988 to 2018 and General Data Protection Regulation (GDPR) (EU 2016/679).
We may update this policy occasionally, so please review it regularly. If you have any questions about this policy or the information which we hold, please contact us at: press@gc or write to us at GCN, 2 Exchange Street Upper, Dublin 8, D08 XW7D.
This policy applies to GCN’s digital services only and not to other websites, APPs, or social media sites linked to or from GCN’s digital services.
1. About GCN
GCN has been Ireland's free national LGBTQ+ media since 1988.
For over three decades, GCN has acted as a paper of record and key resource to inform, educate, connect, and entertain the LGBTQ+ community, platforming and amplifying their voices and advocating for positive change.
GCN’s presence spans print and digital through its monthly magazine, delivered across Ireland and available online, its daily news website, digital initiatives, campaigns to further LGBTQ+ rights and live events.
GCN will collect, use, store or otherwise process personal data per the Policy below.
2. The information we collect
GCN will never collect any unnecessary personal data from you and will not process your information in any way, other than as specified in this notice.
The personal data that GCN collects varies depending on the online activity you have consented to. Below lists the information GCN may collect when you register for a newsletter, take a survey, enter a competition or if you make direct contact with us:
- Contact Phone Number (where required for a competition entry or where you register to attend an event organised by GCN)
- Home Address (where required for a competition entry, when you purchase GCN merchandise for delivery or to reply to direct contact)
- Confirmation that you’re over 18 (where required for a competition entry or entry to an event)
- IP Address
- Information contained in a curriculum vitae (where sent directly to GCN)
GCN collects your personal data when you;
- subscribe (opt-in) to a newsletter,
- enter a competition
- participate in an online survey
- contact GCN directly
Lawful Basis for Processing
We process your personal data based on the following lawful basis.
- Newsletter Subscriptions are based on Consent.
- Direct Marketing emails are based on either Consent or Legitimate interest, where we use legitimate interest, we will have completed a legitimate interest assessment where we conduct a balance test between our legitimate interests and your privacy rights.
Automatic Data Collection
With your consent, we use marketing cookies to better target advertising and make it more relevant to you and your interests; we also use these cookies to frequency cap the number of times you will see an individual ad. Advertising cookies collect information regarding your use of both our website and other websites you may visit. This information allows advertising networks to target their audience.
Where consent is not provided, you will still receive ads, but they will not be targeted.
You can find more about Advertising cookies here: https://policies.google.com/technologies/partner-sites
You can also have control over what third-party cookies are used on your device by using tools like http://www.youronlinechoices.com/ie/your-ad-choices or http://optout.networkadvertising.org/
GCN uses Google Analytics to monitor the usage of its digital assets, which is an essential part of the running of any website. It provides the information we require to manage our server capacity and the popularity of our content. This information is anonymous. Please see: https://www.google.com/analytics/learn/privacy.html for more details.
You should be aware that you may be making available personally identifiable information about yourself when you submit material to our social media pages or other interactive digital services elements.
3. How we use the personal data we collect:
GCN takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
We do not employ automated decision-making methods to any of your personal data under our control.
The purposes and reasons for processing your personal data are detailed below: –
- We collect your data to administer a service to which you have subscribed and given consent for your personal data to be processed. This includes GCN Newsletter and/or promotional material.
- We collect your data as part of a competition entry to allow us contact you regarding the competition; this data is processed based on consent.
- We collect personal data to administer your personalised preferences, such as news content or preferred services.
- We collect the personal data that you provide us with when you contact us directly to respond to your specific inquiry or to administer the relevant site activity where we have a legitimate interest.
- We automatically capture your IP addresses to geo-fence our content.
- Comply with legal regulatory requirements and legitimate business purposes.
How we use marketing information?
- To help us to monitor, analyse and improve GCN. This information helps us to understand which GCN content, products and services are most interesting, enjoyable and useful to our users and if they are shared via social networks. The information also helps us to identify when errors occur within the digital products and services within GCN and test different versions of a page or feature to see which one works best. All of which help us improve our digital products and services for our users.
- We can create a more tailored experience by looking at the information we have about you. For example, we will do this by making content recommendations or telling you about relevant GCN events in your area.
- To inform the way we commission future content at GCN. We will use aggregated and anonymous user data to help our commissioning teams understand what type of content our users like.
- To sell advertising on GCN.
- We will send you information about the digital products and services within GCN or other marketing activities, but only where you have signed up to receive these from us. Similarly, sometimes, third-party partners will want to send you information about products and services, but only if you have agreed to receive them by ticking an opt-in box associated separately with a competition partner.
- We will email you occasionally about the digital products and services within GCN that you have signed up for (for example, to provide you with password reminders or to contact you about the content you have submitted to us via our digital products and services) so that we can deliver these services to you. We may also invite you to participate in surveys from time to time to help us understand what you think about our content, products and services, and in turn, improve them.
4. Your Rights
You have the right to access any personal information that GCN processes about you and to request information about:
- What personal data we hold about you.
- The purposes of the processing.
- The categories of personal data concerned.
- The recipients to whom the personal data has/will be disclosed.
- How long we intend to store your personal data for.
- If we did not collect the data directly from you, information about the source.
If you wish to make a Subject Access Request, please contact email@example.com.
You have the right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
You have the right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records.
You have the right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
You have the right of portability – you have the right to have the data we hold about you transferred to another organisation.
You have the right to object – you have the right to object to certain types of processing, such as direct marketing. (e.g. Newsletter Opt-out)
You have the right to object to automated processing, including profiling.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
5. Information collected for journalistic purposes
Under Article 85 of the GDPR (EU 2016/679), material acquired and used for journalistic purposes is exempt from certain Articles of GDPR, these include Chapter II (principles) other than Article 5(1)(f), Chapter III (rights of the data subject) Chapter IV (controller and processor obligations), Chapter V (transfer of data), Chapter V1, Chapter VII and Chapter IX.
Please note that the requirement to process personal data in a manner that ensures appropriate security remains when processing for journalistic purposes.
6. Sharing and Disclosing Your Personal Information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this policy or where there is a legal requirement. GCN uses third parties to provide services regarding subscriptions, surveys, competitions and events; however, all processors acting on our behalf only process your data in accordance with our instructions, comply fully with this privacy notice and are subject to the GDPR (EU 2016/679).
7. Our commitment to security
GCN takes your privacy seriously, and we employ appropriate technical and organisational security measures to prevent unauthorised access, alteration, disclosure or destruction of your information.
We use the following industry-standard methods to protect your data:
- SSL (HTTPS) Across all websites
- Enterprise firewalls
- Anti-virus & anti-malware software
Unfortunately, the sending of information via the internet is not completely secure. Although we will do our utmost to protect your information, we cannot guarantee the security of your data sent to our digital services within GCN; any sending of information is therefore at your own risk.
8. Transfer Outside the EEA
GCN utilise services (or parts of them) that may be hosted/stored outside the EEA , which means that we may transfer any information which you submit through one of our digital services outside the European Economic Area (“EEA”) for the below purposes:
- Newsletter Subscription
Data Processor is MailChimp; more info here: https://mailchimp.com/legal/privacy/
MailChimp has a proven track record of providing email marketing services across the globe. They are Trusted Certified and are Certified with the EU-US Privacy Shield Framework.
- Events Registration Forms
Data Processor is Eventbrite; more information https://www.eventbrite.ie/support/articles/en_US/Troubleshooting/eventbrite-privacy-policy?lg=en_IE
Therefore, when you sign up to our newsletter, enter a competition, register to attend an event, or participate in a survey, the personal information you submit may be stored on servers hosted outside the EEA. Where this is the case, we will ensure that those providers use an appropriate level of protection for your information and agree to abide by GDPR (EU 2016/679) through standard contractual clauses.
9. How Long We Keep Your Data
GCN only ever retains personal information for as long as is necessary to provide a service you have consented to or to adhere to certain warranties or proof of delivery for competition winners.
Where you have subscribed to a Newsletter we will retain your data until you unsubscribe or the Newsletter is cancelled. We include unsubscribe links on all newsletter emails.
Where you have registered for an event, we’ll retain your personal data for 13 months after the event as a record of attendance.
Where you enter a competition, we’ll retain your data for 12 months after successfully delivering the prize or after the date of the event.
We have retention policies in place to meet these obligations.
In the event that you wish to make a complaint about how GCN is processing your personal data, or how your complaint has been handled, you have the right to lodge a complaint directly with the Data Protection Commissioner and GCN.
The details for each of these contacts are:
Data Protection Commissioner
21 Fitzwilliam Square South
Phone: 1800 437 737 or +35317650100
2 Exchange Street Upper