Privacy and Cookie Policy

6.5 We may use selected data management providers for our own purposes such as and/or similar to those described in 6.4, above.

6.6 We have no access to third party cookies and third party organisations have no access to ours. The third party organisations that place cookies, including your browser (such as Google), Ozone, data management providers and the third party companies who pay for advertising and analytics services using this information, will have their own privacy policies.

7. Managing your cookies preferences

7.1 Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates. We also provide our own cookie management tool for you to make more specific choices about how cookies are used for your visits to our site.

7.2 We also use third party cookies, as will your browser. These are cookies that may be read by third parties (for example if you have used social sign-on and have the option to like or comment using your social media account). If you would prefer to just restrict third party cookies, here is our cookie management tool:

Alternatively, visit youronlinechoices.com or click on the AdChoices logo that you will see in the corner of advertisements that carry behavioural targeting cookies.

7.3 We use various third parties to provide us with information to help us learn about how users use our website. To find out more about how we use these third party services click on their names, below, to view their websites and privacy policies:

7.4 If you would like to disable ‘third party’; cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to the third party’s website and getting them to generate a one-time ‘no thanks’ cookie that will stop any further cookies being written to your device. Here is a link to the third party advertising platform we use, which has instructions on how to do this:

adssettings.google.com/authenticated

Please note that even after disabling this, you may still see “non-personalised” advertisements that may appear materially the same as the “personalised” ones. This is simply a function of what advertisers and partners we are working with, and does not mean your preferences have not been applied.

Please note also that the likes of Google, with whom we work to serve advertising, will still use cookies for necessary administrative purposes after you have amended your personalised advertising settings. These purposes include frequency capping (namely to stop users being served the same advertisements repeated), aggregated reporting of engagement (on a non-personal basis) and to combat fraud and abuse (for example, to prevent bogus click-throughs by web hosts to inflate the value of their platform).

7.5 We also use a data management platform. We use the data this platform records, including data gathered through cross-device tracking, to better understand our users’ interests, so that we can provide better and relevant Telegraph Media Group and advertiser services based on this information.

7.6 When you share stories using social media, for example Facebook, the social media company will drop cookies and identifiers to track this.

7.7 You can also visit the trade body representing these advertising companies for more information on how to opt out of these cookies: youronlinechoices.com

8. Ad Blockers

8.1 We use JavaScript to detect ad blockers.  We use the script in the source code of our website.  It confirms advertisements are correctly displayed on your device by simulating the display of the advertisement.

8.2 By detecting ad blockers, we do not store any information on your device and we do not process any of your personal data.

8.3 We may display a message to advise you that we have detected that you are using and ad blocker

8.4 We reserve the right to restrict your access to some or all of our website while you have an ad blocker turned on.

9. Protecting your information

9.1 The password you provide when registering with the website is encrypted to ensure protection against unauthorised access to your personal information.

9.2 We invest in high-quality security and do our utmost to protect user privacy. No data transmission over the Internet can be entirely secure, and therefore we cannot guarantee the security of your personal information and/or use of the website. Any information that you send is at your own risk and may be read by others. However once we have received your personal information we use strict procedures to protect the security of your personal information.

10. Disclosing your information

10.1 Selling our businesses. We may share your personal information with potential buyers, their advisers and connected third parties  in connection with the potential sale or transfer of our business or assets or of any part of our business or assets (including any of Our Brands).  If we sell, transfer or restructure any part of our business that holds your personal information, we may share or transfer that information to the buyer or new entity: for example, so that they can continue to provide continuity of service to you. We will use reasonable efforts to try and ensure that the buyer or new entity continues to use your personal data in the same way or a similar way to that outlined under our privacy policy.   We will always try and notify you of such a change of control or ownership, such as by way of public announcement and updates to this privacy policy or any new privacy policy.

10.2 Your internet browser or other accounts. Depending on which browser you use to visit our site, and in accordance with your browser cookie preferences (see above), your browser (such as Google) may collect information about you and your visit for its own services, including those services such as segmented or personalised advertising that it provides to us and other sites. If you use social media sign-on (such as with Facebook), you will be enabling sharing of information between us and that site in the manner set out in Section 3.1(5) above and any notices provided to you. You can de-link your social sign-in as set out in Section 5.2.

10.3 Our partners. Except as set out in Section 10.1 or 10.2 above, we never sell personal information, or pass it to third parties outside of the Telegraph Media Group for their own marketing purposes, without your permission. We sometimes provide your personal information to third parties who are our subcontractors or providers of various products and services on our behalf e.g. the providers of the branded services listed below (Our Brands and their Service Providers) and intermediaries, in order to fulfil those orders and providers of key services such as our customer care partners, First Source. Your personal information will always be subject to appropriate protections under contract. Where you are engaging with Our Brands for products and services, you will sometimes contract with our Service Providers and may choose to provide them with personal information or permissions directly.

10.4 Legal requirements. We may disclose your personal information if we are required to do so by law, or if in good faith we believe such action is necessary to comply with the law a legal obligation.

10.5 Verification of circulation figures. We may disclose subscribers’ personal information including: name, address, email address and telephone number and payment details (though no bank or credit card account details) to the Audit Bureau of Circulation (ABC) for the sole purpose of verifying our newspaper circulation figures.  ABC’s Privacy Policy can be found here.

10.6 Data processors. In common with most organisations, some of our functions using your personal information are outsourced to contractors (for example, Sourcepoint who manage our cookies consents or our other software providers). Any processing of personal information by these contractors will only be for these carefully defined purposes, and will be adequately and lawfully protected under contract, including requirements of confidentiality and data security.

11. Where we store your personal information

11.1 The personal information that we collect from you will sometimes be sent and stored outside of the UK or the European Economic Area (“EEA”) in order to carry out the activities listed in “Use of Your Information”. Except where this is on your specific instructions, this will always be subject to adequate safeguards as to the protection and security of your personal data. This means that we will only transfer your personal data outside of the UK or EEA:

(a) to countries that have been found to provide an adequate level of protection for personal data. This may include certain US organisations that have certified participation in the EU-US Data Privacy Framework including the UK Extension; or

(b) where we have used specific approved contracts that use approved clauses (such as Standard Contractual Clauses or the International Data Transfer Agreement) for the protection of personal data and where we have carried out assessments of the safeguards provided by those countries. These contracts give your personal data the same level of protection as the UK and EEA.

Further details on these safeguards are available on enquiry from data.protection@telegraph.co.uk.

11.2 We will only keep your personal information for as long as we need it for a lawful purpose: whether because of the products and services we have provided to you, for example as a subscriber or registered user (and to allow for reasonable retention of records afterwards to reflect legal requirements or limitation periods),or because we believe you still wish to hear from us. This is again separate from our role as a media organisation and the information we are lawfully able keep in the public interest because it is relevant to our journalism and publishing activities.

12. Changes to this Policy

12.1 If we change our Policy, we will post the changes on this page. Please check the website regularly for any changes to this Policy. However, from 25 May 2018 any significant changes will be provided to you directly where possible.

12.2 The previous Privacy Policy was dated 3rd August 2023.

13. If you don’t feel we’re adhering to this Policy, what should you do?

13.1 You have the following rights:

(1)  To obtain access to, and copies of, the personal data that we hold about you, or require that it is transmitted to another data controller;

(2)  To request that we restrict our data processing activities or cease processing your personal data in certain ways, for example because you do not consider it lawful;

(3)  To require us not to send you marketing communications;

(4)  To withdraw your consent, where we are relying on it to process your personal data;

(5)  To object to how we process your personal data, in particular where we are relying on our legitimate interests; and

(6)  To ask us to erase the personal data we hold about you, for example because it is causing you distress or you believe it to be no longer relevant, or to correct the information if it is incorrect. If you would like to exercise any of your rights as stated above, you can do so by emailing data.protection@telegraph.co.uk.

Please note that the above rights are not absolute, and we will be entitled to refuse requests where exceptions apply (including where we are processing it in our capacity as a media organisation). You can find out more about your rights at www.ico.org.uk.

Automated decision making

You also have the right to object to automated decision-making, including by means of profiling. Although we use various algorithms and automated criteria to help us serve advertising in the manner set out in this Policy, this results in segmented advertising (by category of user) rather than specific decisions being made about you. This can in any event be controlled through your cookie and ad preferences.

If we change how we use this technology in the future, we will let you know if it affects you via this Policy (and significant changes or effects we will notify directly).

14. If you don’t feel we’re adhering to this Policy, what should you do?

14.1 If you believe that we have not adhered to this Policy, please notify us by email at data.protection@telegraph.co.uk and we will try to solve the problem promptly. If you are not satisfied with our response, or have any other queries, you can also contact the Information Commissioner at www.ico.org.uk or 0303 123 1113.

This policy was last updated on 3rd July 2024.

Our Brands

Telegraph brands and their suppliers change from time to time. The following list was updated on 11th March 2024.

N.B. Telegraph Travel also uses the services of smaller organisations and individual hotels. These are clearly specified in our marketing communications.

US Privacy and Cookie Policy

 

NEW US PRIVACY POLICY 

Effective Date: December 20, 2023 

Your privacy is important to us. Telegraph Media Group Limited, Press Acquisitions Limited, and each of their respective subsidiaries (collectively, “Telegraph Media Group”, “we”, or “us” or “our”) created this Privacy Policy to inform you about how we collect, use, disclose, share, and protect Personally Identifiable Information (or “PII”, defined below) and otherwise comply with applicable U.S. consumer privacy laws.  We encourage you to read this Privacy Policy in its entirety before using or any other online service (e.g., website or mobile app) that posts a link to this Privacy Policy, opening our e-mails or otherwise submitting PII to us (collective the “Service”).

This Privacy Policy applies to visitors of our Service (defined below) in the United States.  If you are visiting the Service from another country, please refer to our General Privacy Policy.

By visiting or otherwise using the Service, you agree to the Service’s U.S. Terms and Conditions and consent to Telegraph Media Group’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy and any additional privacy statements that may be posted on an applicable part of the Service or otherwise provided at collection.  If you do not agree or consent, please discontinue use of the Service and uninstall Service downloads and applications.

Your U.S. State Privacy Rights  

California, Colorado (effective July 1, 2023), and Nevada residents have certain privacy rights detailed here. To the extent that there is a conflict between this Privacy Policy and the state privacy notices, the state privacy notices will control. 

About Ads and Tracking

Learn about certain choices you have regarding Tracking Technologies, including certain sharing of activities for interest-based advertising, including Location-Based Advertising and Cross-Device Matching.

 

TABLE OF CONTENTS

1. Information We Collect

A. Information About You That You Provide

B. Information Collected Automatically

C. Information Telegraph Media Group Collects From Other Sources

2. How We Use The Information We Obtain

3. Information We Share With Third Parties

4. Sweepstakes, Contests, and Promotions

5. Information You Disclose Publicly or to Others

6. Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics

7. Data Security and Monitoring

8. International Transfer

9. Children’s Privacy

10. Accessing and Changing Information

11. Choices: Tracking and Communications Options

A. Tracking Technologies Generally

B. Analytics and Advertising Tracking Technologies

C. Mobile Apps

D. Communications

E. Cross-Device Data

12. U.S. State Privacy Notices

A. Notice of Data Practices

i. PI Collection, Disclosure, and Retention – By Category of PI

ii. PI Use and Disclosure – By Processing Purpose

B. Your Consumer Rights and How to Exercise Them

i. Right to Limit Sensitive PI Processing (California Consumers)

ii. Right to Know/Access (California and Colorado)

iii. Do Not Sell / Share / Target

iv. Right to Delete (California and Colorado)

v. Correct Your PI (California and Colorado)

vi. Automated Decision Making/Profiling (California and Colorado)

vii. How to Exercise Your Consumer Privacy Rights

viii. Our Responses

C. Non-Discrimination/non-retaliation

D. Notice of Financial Incentive Programs

E. Our Rights and the Rights of Others

i. Additional Notice for California Residents

F. Contact Us

13. Changes to This Privacy Policy

14. Contact Telegraph Media Group

 

SCOPE

This Privacy Policy governs our practices with regards to PII collected when you access or use the Service.  This Privacy Policy will provide you with information as to how Telegraph Media Group collects, uses, and shares information about you, including the choices Telegraph Media Group offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it.  It does not apply to Telegraph Media Group’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection).  For certain Services, there may be additional notices about information practices and choices.  Please read those additional privacy disclosures to understand how they apply to you.

1.    INFORMATION WE COLLECT

A.    Information About You That You Provide

Telegraph Media Group, and/or its Service Providers (defined below), may collect information you provide directly to Telegraph Media Group and/or its Service Providers via the Service.  For example, Telegraph Media Group collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service.  In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties.  For more information on Third-Party Services’ data collection and practices click here.   For more information on Service Provider data collection and practices click here.

Information Telegraph Media Group, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number (“Personally Identifiable Information” or “PII”); and (2) demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases (“Demographic Information”).  Except to the extent required by applicable law, Demographic Information is “non-Personally Identifiable Information” or “non-PII” (i.e., data that is not Personally Identifiable Information under this Privacy Policy).  In addition, Personally Identifiable Information, including, without limitation, Telegraph Media Group-Collected PII (defined below), once “deidentified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements) including through anonymization, pseudonymization, and/or hashing, is also non-Personally Identifiable Information and may be used and shared without obligation to you, except as prohibited by applicable law.  However, we do not make assurances that deidentified data is not capable of re-identification. We will not reidentify or attempt to reidentify data that we maintain as deidentified or knowingly enable any third party to do so. To the extent any non-Personally Identifiable Information, or PII collected outside of the Service, is combined by or on behalf of Telegraph Media Group with Personally Identifiable Information Telegraph Media Group itself collects directly from you on the Service (“Telegraph Media Group-Collected PII”), Telegraph Media Group will treat the combined data as Telegraph Media Group-Collected PII under this Privacy Policy.  The definition of “personal information” under certain state laws differs from the definition of PII used in this Privacy Policy.  California and Nevada residents can learn more about their privacy rights here.

B.    Information Collected Automatically

Telegraph Media Group, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”).  Usage Information may include information regarding how you might browse our website, specifically, IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device).  Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Telegraph Media Group with Telegraph Media Group-Collected PII, Telegraph Media Group does not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or Telegraph Media Group-Collected PII.  For more information on Third-Party Services’ data collection and practices click here.   For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here. 

    The methods that may be used on the Service to collect Usage Information include:

• Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files. 
• Information Collected by Cookies and Other Tracking Technologies:  Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location–identifying technologies, device recognition technologies, in–app tracking methods, device and activity monitoring and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.

 

A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies.  Session cookies make it easier for you to navigate the Service and expire when you close your browser.  Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience.  Cookies may remain on your hard drive for an extended period.  If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work.  To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.  The Service may associate some or all these types of cookies with your devices.

• Web Beacons (“Tracking Pixels”)

Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages.  Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.

An embedded script is programming code designed to collect information about your interactions with the Service.  It is temporarily downloaded onto your computer from Telegraph Media Group’s web server, or from a third party with which Telegraph Media Group works and is active only while you are connected to the Service and deleted or deactivated thereafter.

• Location-identifying Technologies

GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content, including third party ads, based on your location.  If you have enabled GPS or use other location-based features on the Service, your device location may be tracked by us and third parties. 

• Device Recognition Technologies.

Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).

There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings.  Some use device identifiers, or other identifiers such as “Ad IDs,” or may use “SDKs,” to associate app user activity to a particular app and to track user activity across apps and/or devices.  SDKs are blocks of code that may be installed in our mobile application by third party companies with which we work.  SDKs help us understand how you interact with our mobile application and collect certain information about the device and network you use to access our application, such as the advertising identifier associated with your device and information about how you interact with our application. 

Some information about your use of the Service and certain other online services may be collected using Tracking Technologies across time and services and used by Telegraph Media Group and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services.  See Section 11 regarding certain choices regarding these activities.  

Telegraph Media Group is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.

C.    Information Telegraph Media Group Collects From Other Sources

Telegraph Media Group may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Telegraph Media Group-Collected PII.  Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of Telegraph Media Group with Telegraph Media Group-Collected PII, this Privacy Policy is not intended to limit Telegraph Media Group’s activities regarding such third-party-sourced, or non-Service-sourced, information (including Personally Identifiable Information), and such data will only be treated as Telegraph Media Group-Collected PII to the extend it is combined with Telegraph Media Group-collected PII. Telegraph Media Group is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.

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2.    HOW WE USE THE INFORMATION WE OBTAIN

Telegraph Media Group may use information about you, including Telegraph Media Group-Collected PII and other Personally Identifiable Information, for any purposes not inconsistent with Telegraph Media Group’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:

• Allow you to participate in the features we offer on the Service;
• Facilitate, manage, personalize, and improve your online experience;
• Process your registration, manage your account, and provide customer care and consumer compliance (e.g., fulfilling orders or returns, processing payments or refunds, and providing aftercare, as well as improving your customer experience);
• Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
• Telegraph Media Group Affiliates’ marketing and other purposes;
• Improve the Service and for any other business purposes;
• Tailor our content, advertisements, and offers; 
• Fulfill other purposes disclosed at the time you provide Personally Identifiable Information or otherwise where we are legally permitted or are required to do so;
• Determine your location and manage digital content rights (e.g., territory restrictions); and 
• Prevent and address fraud, breach of policies or terms, and threats or harm.

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3.    INFORMATION WE SHARE WITH THIRD PARTIES

Except as restricted by applicable law, this Privacy Policy, or any other representation Telegraph Media Group makes to you, Telegraph Media Group may share non-Personally Identifiable Information, and Personally Identifiable Information that is not deemed Telegraph Media Group-Collected PII hereunder (provided that Telegraph Media Group is aware of no restrictions of Telegraph Media Group’s use, if any), with third parties or Telegraph Media Group companies and their affiliates (“Telegraph Media Group Affiliates”) for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your Personally Identifiable Information, including Telegraph Media Group-Collected PII, to non-Personally Identifiable Information, including without limitation through hashing it or substituting a unique identifier for the Personally Identifiable Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources.  Any such third-party activities are subject to their privacy policies and practices.  Telegraph Media Group’s sharing of Telegraph Media Group-Collected PII is, however, subject to the following:

• Marketing:  Subject to your communications choices explained in Section 11.D, and the rights of California residents explained in Section 12, we may use your Personally Identifiable Information to send you marketing communications.  Telegraph Media Group will not share your Telegraph Media Group-Collected PII with third parties or Telegraph Media Group Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below) without your consent (which may be by means of third-party interaction described in the next bullet point). We sometimes provide your PI to third parties who are our Vendors of various products and services on our behalf to fulfill those orders.
• Your Disclosure or Consent:  As more fully described in Section 5  (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your Telegraph Media Group-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties.  Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not Telegraph Media Group.  

Telegraph Media Group may also share any information about you (including, without limitation, Telegraph Media Group-Collected PII) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:

• Telegraph Media Group’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to, your information, including, without limitation, Personally Identifiable Information, Demographic Information, and Usage Information, in connection with their work on Telegraph Media Group’s behalf, provided however, Telegraph Media Group does not authorize its Service Providers to use Telegraph Media Group-Collected PII provided by Telegraph Media Group to the Service Providers to send you direct marketing messages other than related to Telegraph Media Group and Telegraph Media Group Affiliates absent your consent.  For more information on choices Service Providers may offer you visit Section 11.  
• Third parties and their advisers if we are approached by a potential buyer in connection with the potential sale of our business or of any part of it.
• Your internet browser or other accounts.  Depending on which browser you use to visit our site, and in accordance with your browser cookie preferences (see above), your browser (such as Google) may collect information about you and your visit for its own services, including those services such as segmented or personalized advertising that it provides to us and other sites.
• Data processors.  In common with most organizations, some of our functions using your personal information are outsourced to contractors.  Any processing of personal information by these contractors will only be for these carefully defined purposes, and will be adequately and lawfully protected under contract, including requirements of confidentiality and data security.
• To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and 
• If Telegraph Media Group believes your actions are inconsistent with Telegraph Media Group’s terms and conditions, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Telegraph Media Group, the Service or its users, or any third party.

In addition, Telegraph Media Group may share your Telegraph Media Group-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Telegraph Media Group assets, or transfer of all or a portion of Telegraph Media Group’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).

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4.    SWEEPSTAKES, CONTESTS, AND PROMOTIONS

Telegraph Media Group may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personally Identifiable Information.  If you voluntarily choose to enter a Promotion, your information, including Personally Identifiable Information, may be disclosed to Telegraph Media Group, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list).  By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy.  Please review those rules carefully.

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5.    INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS

The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personally Identifiable Information.  If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Telegraph Media Group.  Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personally Identifiable Information included in UGC is not subject to Telegraph Media Group’s usage or sharing limitations, or other obligations, regarding Telegraph Media Group-Collected PII or other Personally Identifiable Information under this Privacy Policy or otherwise and may be used and shared by Telegraph Media Group and third parties to the fullest extent not prohibited by applicable law.  Telegraph Media Group encourages you to exercise caution when making decisions about what you disclose in such public areas.  For more information on how UGC is treated under the Service’s Terms and Conditions click here.  California minors should see Section 9 regarding potential removal of certain UGC they have posted on the Service.

Additionally, the Service may offer you the option to send a communication to a friend or other contact.  If so, Telegraph Media Group relies on you to only send to people that have given you permission to do so.  The recipient’s Personally Identifiable Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Telegraph Media Group for any other marketing purpose unless Telegraph Media Group obtains consent from that person.  Your contact information and message may be included in the communication.  

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6.    THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS

The Service may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)) or other services (“Third-Party Service(s)”).  These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personally Identifiable Information from you.  

Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”).  Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Telegraph Media Group’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service).  If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5 or by the Third-Party Service that you use.  Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with Telegraph Media Group or other Telegraph Media Group Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Telegraph Media Group and Telegraph Media Group Affiliates.  Also, both Telegraph Media Group and the third party may have access to certain information about you and your use of the Service and any Third-Party Service. 

Telegraph Media group may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on other online services.  Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”).  We may use Microsoft and Google for advertising Services.  See Section 11 for more information on your choices regarding certain personalized advertising.

Telegraph Media Group may use Google Analytics, Adobe Analytics or other Service Providers for analytics services.  These analytics services may use cookies and other Tracking Technologies to help Telegraph Media Group analyze Service users and how they use the Service.  Information generated by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage.  See Section 11 for more information on your choices regarding these services. 

Telegraph Media Group is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.  See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.

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7.    DATA SECURITY AND MONITORING

Telegraph Media Group takes reasonable measures to protect Telegraph Media Group-Collected PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.  Nevertheless, transmission via the Internet and online digital storage are not completely secure and Telegraph Media Group does not guarantee the security of your information collected through the Service.

To help protect you and others, Telegraph Media Group and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including Telegraph Media Group-Collected PII and other Personally Identifiable Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the Terms and Conditions and this Privacy Policy; investigate violations of or enforce these documents; improve the Services and your Services experiences, and to protect the rights and property of Telegraph Media Group Company Affiliates, third parties, and other users.  Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service.  If you do not consent to these conditions, you must discontinue your use of the Service.

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8.    INTERNATIONAL TRANSFER

 This policy is targeted towards users located in the U.S. and the information Telegraph Media Group and its Service Providers collect is governed by U.S. law.  If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S.  Data protection laws in the U.S. may be different from those of your country of residence.  Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, in the U.S. as set forth in this Privacy Policy.  If you are a user located in the U.K. or EU, please refer to the General Privacy Policy.

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9. CHILDREN’S PRIVACY

The Service is intended for a general audience and not directed to children less than 13 years of age.  For further information on how Telegraph Media Group treats Children’s Personal Information (defined below) in connection with any children’s or mixed-use portions of the Service (if any), please see the Children’s Privacy Policy posted thereon, which will be deemed incorporated herein for purposes of that part of the Service. 

Telegraph Media Group does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA.  If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.  

Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Telegraph Media Group here, detailing where the content or information is posted and attesting that you posted it.  Telegraph Media Group will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law.  This removal process cannot ensure complete or comprehensive removal.  For instance, third parties may have republished or archived content by search engines and others that Telegraph Media Group does not control.

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10. ACCESSING AND CHANGING INFORMATION

 Telegraph Media Group may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Telegraph Media Group-Collected PII, and potentially certain other information about you (e.g., profile and account information).  Telegraph Media Group will make good faith efforts to make requested changes in Telegraph Media Group’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all your information or public postings from Telegraph Media Group’s databases (California minors see Section 9 and residual and/or cached data may remain archived thereafter.  Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

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11.    CHOICES: TRACKING AND COMMUNICATIONS OPTIONS

A.    Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.  Browsers offer different functionalities and options, so you may need to set them separately.  Also, tools from commercial browsers may not be effective with regard to HTML5 cookies or other Tracking Technologies. Visitors in the U.S. may also manage cookies on our Service through our consent management platform 

Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app.  To uninstall an app, follow the instructions from your operating system or handset manufacturer.  Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective. 

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit.  Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context.  Like many online services, Telegraph Media Group currently does not alter Telegraph Media Group’s practices when Telegraph Media Group receives a “Do Not Track” signal from a visitor’s browser.  To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Telegraph Media Group is not responsible for the completeness or accuracy of this third-party information.  Some third parties, however, may offer you choices regarding their Tracking Technologies.  One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies.  Telegraph Media Group is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms.   For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.  We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Services, but such tools rely on third parties and third-party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective.  For instance, here is where you can find cookie controls for popular browsers:

We do not represent that these third-party tools, programs or statements are complete or accurate.  You will need to do this on each browser that you use to access our Services and clearing cookies on your browser(s) may disable your preference settings.  Also, our Services may not function properly or as intended if you block all or even certain cookies.  Accordingly, you may want to consider the more limited opt-out choices noted in the next section.

B.    Analytics and Advertising Tracking Technologies  

You may exercise choices regarding the use of cookies from Google Analytics by going to or downloading the Google Analytics Opt-out Browser Add-on.  You may exercise choices regarding the use of cookies from Adobe Analytics by going to under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.”

You may choose whether to receive some Interest-based Advertising by submitting opt-outs.  Some of the advertisers and Service Providers that perform advertising-related services for us, and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.  To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads).  Some of these companies may also be members of the Network Advertising Initiative (“NAI”).  To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/.  Please be aware that, even if you can opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads.  Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks).  Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective.  Telegraph Media Group supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Telegraph Media Group directly engages to serve you Interest-based Advertising will do so as well, though Telegraph Media Group cannot guaranty their compliance. 

We may also use Microsoft Advertising Services.  To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit here. We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit here.

In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”).  This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the other online services.  For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services.  We are not responsible for these Third-Party Services, including without limitation their security of the data.  If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads.  If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter.  We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.

Telegraph Media Group is not responsible for effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

C.    Mobile Apps

With respect to Telegraph Media Group’s mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app.  Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., tracking across apps and websites owned by other online services, location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings.  For example, to limit receiving Interest-based Advertising on your mobile device, for iOS 14, go to “Settings,” select “Privacy,” select “Tracking,” and then toggle off “Allow Apps to Request to Track.” For earlier versions of iOS dating back to iOS 6, go to “Settings,” select “Privacy,” select “Advertising,” and toggle on “Limit Ad Tracking.” For Android, go to “Settings,” select “Privacy,” select “Ads,” and then toggle on “Opt out of Ads Personalization.” Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist.  To learn more about how you can control certain location permissions, such as GPS, wi-fi, and network data, using your mobile device’s operating system settings, please visit the following links depending on which device you use:

Android: 

 

iOS: –

D.    Communications

You can opt out of receiving certain promotional communications (emails or text messaging) from Telegraph Media Group at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from Telegraph Media Group to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable.  Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions.  If you opt-out of only certain communications, other subscription communications may continue.  Even if you opt out of receiving promotional communications, Telegraph Media Group may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Telegraph Media Group’s ongoing business relations.  Except in connection with Corporate Transactions, to prospectively opt-out of our sharing of your Company-Collected PII with third parties, other than with Telegraph Media Group Affiliates, for their own direct marketing purposes, email us here

E.    Cross-Device Data

To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the prior section regarding the DAA’s Interest-based Advertising choices. 

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12. U.S. STATE PRIVACY NOTICES

This U.S. State Privacy Notice (“Notice”) applies to “Consumers” as defined under the California Consumer Privacy Act, including as amended by the California Privacy Rights Act, Colorado Privacy Act (effective July 1, 2023), and all laws implementing, supplementing or amending the foregoing, including regulations promulgated thereunder (together, the “CCPA”), and Chapter 603A of the Nevada Revised Statutes (collectively, “U.S. Privacy Laws”).  Capitalized terms used but not defined in this Notice shall have the meanings given to them under the CCPA. 

This Notice is designed to meet our obligations under U.S. Privacy Laws and supplements the U.S. Privacy Policy of Telegraph Media Group Limited. In the event of a conflict between any other Telegraph Media Group policy, notice, or statement and this Notice, this Notice will prevail as to Consumers unless stated otherwise.   

Applicability:

• Section A of this Notice provides notice of our data practices, including our collection, use, disclosure, and sale of Consumers’ Personal Information or Personal Data (collectively, “PI”), as that respective term is defined under US Privacy Laws. 
• Sections B-D of this Notice provide information regarding Consumer rights and how you may exercise them. Nevada “consumers” have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, the other Consumer rights only apply to California Consumers.
• Section E of this Notice provides additional information for California residents.

For California residents the term “Consumer” is not limited to data subjects acting as individuals regarding household goods and services and includes data subjects in a business-to-business context. 

Non-Applicability: This Notice does not apply to our job applicants, current employees, former employees, or independent contractors (“Personnel”), however, California Personnel may obtain a separate privacy notice that applies to them by contacting our human resources department by email here.  This Notice also does not apply to PI that we may process as a Service Provider/Processor on behalf of another Business/Controller.

A.    Notice of Data Practices

The description of our data practices in this Notice covers the twelve (12) months prior to the Effective Date and will be updated at least annually. Our data practices may differ between updates. However, if the practices are materially different from this Notice, we will provide supplemental pre-collection notice of the current practices, which may include references to other privacy policies, notices, or statements. Otherwise, this Notice serves as our notice at collection. 

We may Collect your PI directly from you (e.g., when you register for an account); your devices; our affiliates; service providers; public sources of data; credit reporting agencies; or other businesses or individuals.  As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We will not reidentify or attempt to reidentify data that we maintain as deidentified or knowingly enable any third party to do so.

Generally, we Process your PI to provide you services and as otherwise related to the operation of our business, including for one or more of the following Business Purposes: Performing Services; Managing Interactions and Transactions; Security; Debugging; Advertising & Marketing; Quality Assurance; Processing Interactions and Transactions; Security and Fraud Prevention; and Research and Development. We may also use PI for other Business Purposes in a context that is not a Sale or Share under U.S. Privacy Laws, such as disclosing it to our Service Providers, Contractors, or Processors that perform services for us (“Vendors”), to the Consumer or to other parties at the Consumer’s direction or through the Consumer’s action; for the additional purposes explained at the time of collection (such as in the applicable privacy policy or notice); as required or permitted by applicable law; to the government or private parties to comply with the law, legal process, to protect or enforce legal rights or obligations, or prevent harm; and to assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business (“Corporate Transaction”) (“Additional Business Purposes”). Subject to restrictions and obligations under U.S. Privacy Laws, our Vendors may also use your PI for Business Purposes and Additional Business Purposes, and may engage their own vendors to enable them to perform services for us. 

We may also use and disclose your PI under this Notice for Commercial Purposes, which may be considered a “Sale” or “Share” under applicable U.S. Privacy Laws, such as when Third-Party Digital Businesses (defined below) Collect your PI via third-party cookies, and when we Process PI for certain advertising purposes. 

We provide more detail on our data practices in the two charts that follow.

• PI Collection, Disclosure, and Retention – By Category of PI

We collect, disclose, and retain PI as follows:

There may be additional information we Collect that meets the definition of PI under applicable U.S. Privacy Laws but is not reflected by a category above, in which case we will treat it as required, but will not include it when we describe our practices by PI category. 

 

DATA RETENTION

As required by California law, we note our general PI retention rules by category of PI in the chart above.  However, because there are numerous types of PI in each category, and various uses for each PI type, actual retention periods vary. We will retain specific PI pieces based on how long we have a lawful purpose for the retention. For instance, we may maintain business records for so long as relevant to our business, and may have a legal obligation to hold PI for so long as potentially relevant to prospective or actual litigation or government investigation. We apply the same criteria for determining if we have a legitimate purpose for retaining your PI that you ask us to delete.  If you make a deletion request, we will conduct a review of your PI to confirm if legitimate ongoing retention purposes exist, will limit the retention to such purposes for so long as the purpose continues, and will respond to you with information on any retention purposes on which we rely for not deleting your PI.  For more information on deletion requests see the Right to Delete section.

• ii. PI Use and Disclosure – By Processing Purpose 

We use and disclose PI for the processing purposes described below: 

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B.    Your Consumer Rights and How to Exercise Them

As described more below, subject to meeting the requirements for a Verifiable Consumer Request (defined below), Telegraph Media Group provides Consumers the privacy rights described in this section.  For residents of states without Consumer privacy rights, we will consider requests but will apply our absolute discretion with respect to, if, and how we process such requests. Visitors in the U.S. may also manage cookies on our Service through our consent management platform. 

To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, use our Consumer Rights Request Portal, or e-mail us at data.protection@telegraph.co.uk, and respond to any follow-up inquiries we make. Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.).  More details on the request and verification process are in Section 3.  The Consumer rights we accommodate are as follows:

i. Right to Limit Sensitive PI Processing (California Consumers)

We only Process Sensitive PI for purposes that are exempt from Consumer choice under U.S. Privacy Laws.

ii. Right to Know/Access (California and Colorado)

Residents of California are entitled to access PI, up to twice in a 12-month period, collected and maintained about the Consumer on or after January 1, 2022, including beyond the 12-month period preceding our receipt of the request, unless doing so proves impossible or would involve a disproportionate effort.

(1) Categories 

California residents have a right to submit a request for any of the following:

• The categories of PI we have Collected about you.
• The categories of sources from which we Collected your PI.
• The Business Purposes or Commercial Purposes for our Collecting, Selling, or Sharing your PI.
• The categories of Third Parties to whom we have disclosed your PI.
• A list of the categories of PI disclosed for a Business Purpose and, for each, the categories of recipients, or that no disclosure occurred.
• A list of the categories of PI Sold or Share about you and, for each, the categories of recipients, or that no Sale or Share occurred. 

(2) Specific Pieces 

You may request to confirm if we are Processing your PI and, if we are, to obtain a transportable copy, subject to applicable request limits, of your PI that we have collected and are maintaining.  For your specific pieces of PI, as required by applicable U.S. Privacy Laws, we will apply the heightened verification standards as described below.  We have no obligation to re-identify information or to keep PI longer than we need it or are required to by applicable law to comply with access requests. 

iii. Do Not Sell / Share / Target

Under U.S. Privacy Laws there are broad and differing concepts of “Selling” PI for which an opt-out is required. California has an opt-out from “Sharing” for Cross-Context Behavioral Advertising (use of PI from different businesses or services to target advertisements). Colorado has an opt-out from targeted advertising. Nevada “consumers” have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes.  You may contact us here to be verified and learn more about your opt-out rights under that law. We may Sell or Share your PI and/or use your PI for Targeted Advertising, as these terms apply under U.S. Privacy Laws. However, we provide Consumers an opt-out of Sale/Sharing/Targeting regardless of state of residency. 

Third-Party digital businesses (“Third-Party Digital Businesses”) may associate cookies and other tracking technologies that Collect PI about you on our services, or otherwise Collect and Process PI that we make available about you, including digital activity information. We understand that giving access to PI on our services, or otherwise, to Third-Party Digital Businesses could be deemed a Sale and/or Share and thus we will treat such PI (e.g., cookie ID, IP address, and other online IDs and internet or other electronic activity information) collected by Third-Party Digital Businesses, where not limited to acting as our Service Provider (or Contractor or Processor), as a Sale and/or Share and subject to a Do Not Sell/Share/Target opt-out request. We will not Sell your PI, Share your PI for Cross-Context Behavioral Advertising, or Process your PI for Targeted Advertising if you make a Do Not Sell/Share/Target opt-out request.

Opt-out preference signals (also known as global privacy control or GPC): Some of the U.S. Privacy Laws require businesses to process GPC signals, which is referred to in California as opt-out preference signals (“OOPS”), which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the Sale or Sharing of personal information. To use an OOPS/GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the OOPS/GPC.  We have configured the settings of our consent management platform to receive and process GPC signals on our website. We process OOPS/GPC with respect to Sales and Sharing that may occur in the context of Collection of cookie PI by tracking technologies online by Third-Party Digital Businesses, discussed above, and apply it to the specific browser on which you enable OOPS/GPC. We currently do not, due to technical limitations, process OOPS/GPC for opt-outs of Sales and Sharing in other contexts (e.g., non-cookie PI). We do not: (1) charge a fee for use of our service if you have enabled OOPS/GPC; or (2) change your experience with any product or service offered by Telegraph Media Group if you use OOPS/GPC; (3) apart from notifying you that you opted out, display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the OOPS/GPC.

Opt-out for non-cookie PI: If you want to limit our Processing of your non-cookie PI (e.g., your email address) for Targeted Advertising, or opt-out of the Sale/Sharing of such data, make an opt-out request here.  

Opt-out for cookie PI: If you want to limit our Processing of your cookie-related PI for Targeted Advertising, or opt-out of the Sale/Sharing of such PI, you need to exercise a separate opt-out request on our cookie management tool or by clicking on the “Do Not Sell or Share My Personal Information” link on the banner of the website and app. This is because we have to use different technologies to apply your opt-out of cookie PI and to non-cookie PI. Our cookie management tool enables you to exercise such an opt-out request and enable certain cookie preferences on your device. A similar tool is available for our app, which you can access via the Do Not Sell/Share/Target option in the settings menu. You must exercise your preferences on each of our websites and apps you visit, from each browser you use, and on each device that you use.  Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to enable them again via our cookie management tool.  Please also refer to Section 11 for other ways to exercise preferences regarding Third-Party Digital Businesses.  Beware that if you use ad blocking software, our cookie banner may not appear when you visit our services and you may have to use the link above to access the tool. 

We do not knowingly Sell or Share the PI of Consumers under 16, unless we receive affirmative authorization (“opt-in”) from either the Consumer who is between 13 and 16 years old, or the parent or guardian of a Consumer who is less than 13 years old. If you think we may have unknowingly collected PI of a Consumer under 16 years old, please Contact Us.

We may disclose your PI for the following purposes, which are not a Sale or Share:  (i) if you direct us to disclose PI; (ii) to comply with a Consumer rights request you submit to us; (iii) disclosures amongst the entities that constitute Telegraph Media Group as defined above, or as part of a Corporate Transaction; and (iv) as otherwise required or permitted by applicable law.

iv. Right to Delete (California and Colorado)

Except to the extent we have a basis for retention under applicable law, you may request that we delete your PI. Our retention rights include, without limitation:

• to complete transactions and services you have requested;
• for security purposes;
• for legitimate internal Business Purposes (e.g., maintaining business records);
• to comply with law and to cooperate with law enforcement; and
• to exercise or defend legal claims.

Please also be aware that making a deletion request does not ensure complete or comprehensive removal or deletion of PI or content you may have posted.

Note also that, depending on where you reside (e.g., California), we may not be required to delete your PI that we did not Collect directly from you.

v. Correct Your PI (California and Colorado)

Consumers may bring inaccuracies they find in their PI that we maintain to our attention, and we will act upon such a complaint as required by applicable law. You can also make changes to your online account in the account settings section of the account. That will not, however, change your information that exists in other places.

vi. Automated Decision Making/Profiling (California and Colorado) 

We do not engage in Automated Decision Making or Profiling.

vii. How to Exercise Your Consumer Privacy Rights

To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, use our Consumer Rights Request Portal,  or e-mail us here, and respond to any follow-up inquiries we make. Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.). 

a. Your Request Must be a Verifiable Consumer Request

As permitted or required by applicable U.S. Privacy Laws, any request you submit to us must be an authenticated or Verifiable Consumer Request, meaning when you make a request, we may ask you to provide verifying information, such as your name, e-mail, phone number and/or account information. We will review the information provided and may request additional information (e.g., transaction history) via e-mail or other means to ensure we are interacting with the correct individual.  We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), Right to Delete, or Right to Correction request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.  We do not verify opt-outs of Sell/Share/Target or Limitation of Sensitive PI requests unless we suspect fraud.

We verify each request as follows:

• Right to Know (Categories) (available for California residents only):  We verify your Request to Know Categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. If we cannot do so, we will refer you to this Notice for a general description of our data practices. 
• Right to Know (Specific Pieces):  We verify your Request To Know Specific Pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you and may require a signed declaration under penalty of perjury that you are the Consumer whose PI is the subject of the request. If you fail to provide requested information, we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know Categories Request if you are a California resident. 
• Do Not Sell/Share/Target & Limit SPI:  No specific verification required unless we suspect fraud.
• Right to Delete:  We verify your Request to Delete to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized deletion.  If we cannot verify you sufficiently to honor a deletion request, you can still make a Do Not Sell/Share/Target and/or Limit SPI request.
• Correction:  We verify your Request to Correct PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized correction.

To protect Consumers, if we are unable to verify you sufficiently we will be unable to honor your request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

b. Agent Requests

You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority to submit requests on your behalf, and of you.  You can learn how to do this, emailing us here. In order to, submit an agent request, the agent must provide us with written permission signed by the Consumer or a lawful power of attorney, when you submit the request or in response to our confirmation email if you did not submit it with the request. In certain instances, we may require the Consumer to verify their own identity directly with us or directly confirm with the Consumer that they provided the agent with permission. In certain circumstances, we may require additional information or documentation. Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable U.S. Privacy Laws.

c. Appeals (Colorado)

Residents of Colorado, may appeal Telegraph Media Group’s decision regarding a request by replying to our Response.  

viii. Our Responses

Some PI that we maintain is insufficiently specific for us to be able to associate it with a verified Consumer (e.g., clickstream data tied only to a pseudonymous browser ID). We do not include that PI in response to those requests if we cannot associate it with a verified Consumer.  If we deny a request, in whole or in part, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer PI that we Process to respond to your Consumer request(s).  In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest.  We reserve the right to direct you to where you may access and copy responsive PI yourself.  We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.  If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision.  You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

Consistent with applicable U.S. Privacy Laws and our interest in the security of your PI, we will not deliver to you more sensitive PI such as your account password or payment information in response to a Consumer privacy rights request; however, you may be able to access some of this information yourself through your account if you have an active account with us.

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C. Non-Discrimination/non-retaliation 

We will not discriminate or retaliate against you in a manner prohibited by applicable U.S. Privacy Laws for your exercise of your Consumer privacy rights. If you wish to delete some or all of your PI, and wish to remain in a Notice of Financial Incentive Program (as explained below), you are able to do so. We may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable PI.

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D. Notice of Financial Incentive Programs

We may offer discounts or other rewards (“Incentives”) from time-to-time to Consumers that register to view articles (“Registrants”) on our Service. We collect certain pieces of PI from Registrants, such as name, phone number, e-mail address, IP address, or location which are used to administer the Incentives to Registrants and reasonably necessary to provide the Incentives. You may opt-in to Incentives by registering to access a limited number of free articles a month (subject to our standard terms and conditions, or other loyalty and Incentive programs we may offer from time-to-time (“Program(s)”). Each Program is subject to our standard terms and conditions and may have additional terms (“Program Terms”), available on the specific Program page or at Program sign-up. The Incentives will be described in the Program page, or at Program sign-up.  As the value of the Incentive may change from time to time, please review the current applicable Program Terms. We measure the value of your PI collected in the Program as value of the advertising revenue generated per article view by a U.S. Registrant. We value the Program as the additional revenue generated per article view. We deem the value of the PI to be reasonably related to the value of the Incentive, and by subscribing to these Programs you indicate you agree. If you do not agree to the Program Terms and do not agree that the value of your PI collected is reasonably related to the value of the Incentive, do not subscribe to the Programs. If you subsequently wish to withdraw from the Programs, the method for doing so will be explained in the Program terms or you may contact us by email at data.protection@telegraph.co.uk, and you may withdraw at any time. We do not limit Program participation to consumers that do not exercise their CCPA rights. However, if you submit a deletion request, and inform us that you wish to remain in the program, we will retain the PI necessary to administer the Program. If you do not want us to retain your information to administer the Program, then we will also terminate your participation in the Program.

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E. Our Rights and the Rights of Others

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your rights under U.S. Privacy Laws. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.

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i. Additional Notice for California Residents

In addition to the CCPA, certain Californians are entitled to certain other notices, as follows: 

This Notice provides information on our online practices and your California rights specific to our online services. Without limitation, Californians that visit our online services and seek to acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:

(1) California Minors

Although our services are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our services, and posted content on the service, can request removal by contacting us, detailing where the content is posted and attesting you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines we do not control.

(2) Shine the Light

We may share “personal information,” as defined by California’s “Shine the Light” law, with third parties for such third parties own direct marketing purposes. California residents may opt-out of this sharing by contacting us at data.protection@telegraph.co.uk. You must put the statement “Shine the Light Request” in the body of your correspondence. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. This right is different than, and in addition to, CCPA rights, and must be requested separately. However, a Do Not Sell/Share/Target opt-out is broader and will limit our sharing with third parties for their own direct marketing purposes without the need for making a separate Shine the Light request. We will not accept Shine the Light requests by telephone or by fax, and are not responsible for requests not labeled or sent properly, or that are incomplete.

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F. Contact Us

If you have any questions, comments, or concerns about our U.S. privacy practices, please contact as outlined in Section 14. Please note that e-mail communications will not necessarily be secure; accordingly, you should not include sensitive information in your e-mail correspondence with us.

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13.    CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use.  However, we will not treat your previously collected Telegraph Media Group-Collected PII, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. If you have a subscription to the Service, material changes to the Privacy Policy will only become effective with respect to the aspect of that subscription Service at the end of the then current term unless you otherwise consent to the new Privacy Policy. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

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14. CONTACT TELEGRAPH MEDIA GROUP

If you have any questions about this Privacy Policy, please contact Telegraph Media Group by email here. If you have any conditions requiring special accommodation, please let us know.  

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© Telegraph Media Group December 20, 2023.  All Rights Reserved.