(Version 2.0 August 4th 2022)
We use your information to provide you with the products and services you request, as well as to understand how and why our audiences engage with us. This allows us to personalise content, show you relevant adverts that support our journalism and content, and generally improve your experience of our products and services.
The Data Controller for your personal information while you interact with www.polskiobserwator.de and related websites – www.polskiobserwator.uk, www.polskiobserwator.nl, www.polskiobserwator.it – (hereinafter, “Site”) is the UK company New European Media Ltd. Company no. 7212256 | VAT GB159109891 (hereinafter, “Data “Controller).
How to contact us
The Data Controller takes the utmost account of the right to privacy and protection of the personal data of its Users.
For any information in relation to this privacy statement, Users can contact the Data Controller at any time:
- By sending a registered letter with return receipt to the registered office of the Data Controller (Suite C 4-6 – Canfield Place – London NW6 3BT – United Kingdom);
- By sending an e-mail message to [email protected].
The Data Controller has not identified the figure of the Data Protection Officer (RPD or DPO).
The type of personal information we collect
By browsing www.polskiobserwator.de and related websites, Users can always stay up to date with news, insights and guides from Germany, UK, Europe and all over the world (hereinafter, „Service”).
In relation to these activities we currently collect and process the following information automatically from your devices when you interact with our Site :
- Information about your device type, operating system, hardware, software, display settings and browser type to tailor your experience to your device (tablet vs phone)
- URI (Uniform Resource Identifier) with the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the IT environment of the User.
- Other unique identifiers like IP address, so that we can recognise if you have been to our websites before
- Device settings such as general geographic location (this can be to provide services that have copyright restrictions, to show you content that is relevant to where you are, and tailor advertising to your interests)
- Device operations, such as information about how you’ve used the device on our sites
This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to allow it to function correctly. Without prejudice to the provisions elsewhere in this privacy statement, in no case will the Data Controller make the Users’ personal data accessible to other Users and / or third parties.
How we get the personal information and why we have it
Most of the personal information we process is provided to us directly by you when you access our Site and when you sign up for newsletters or alert notifications.
We use the information that you have consented to give us in order to obtain anonymous statistical information on the use of the Site to operate, provide, develop and improve our Service.
This involves facilitating content production and various types of advertising and marketing to make them more effective, more relevant, and more likely to engage and interest our Users.
In particular, we use your information for the following reasons:
- To provide our services: we use the information to allow the Site to function correctly, to detect and prevent security incidents, for anti-fraud purposes, for debugging, short-term and transient use, quality control, and legal compliance.
- Analytical purposes: we use the information to analyse our Users and make content production more relevant and engaging for our Users
- Relevant advertising: we use the information to facilitate and provide various types of advertising and marketing to make them more effective and relevant for our readers
The provision of personal data for the processing purposes indicated above is optional but necessary, since failure to provide them will make it impossible for Users to access the Site and use the Service.
The legal bases for processing your personal information
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
(a) Your consent.
You will have the right to withdraw that consent at any time, however, if you withdraw consent, we may not be able to provide the product or service you have requested.
You can withdraw your consent by contacting our Data Controller by mail at the registered address Suite C 4-6 – Canfield Place – London NW6 3BT – United Kingdom or by email [email protected].
(c) We have a legitimate interest.
We may use your information where there is a legitimate reason to do so, such as where it would help achieve our business objectives or to facilitate a benefit to you or someone else.
Our legitimate interests in processing personal data include:
- to support a free press, including journalistic activities of societal importance;
- to support individual and societal rights to receive information;
- to develop, deliver and maintain relevant and engaging products services and advertising;
- understanding when our audiences engage with us or other organisations;
- to build a clearer understanding of who our audiences are in order to better serve them;
- to carry on the business of a commercial organisation; and
- to demonstrate that we provide services and products to agreed industry standards.
(d) We have a legal obligation.
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims.
We may also disclose your information where we are allowed to by law to protect or enforce our rights or the rights of others and for the prevention and detection of crime, such as fraud.
How we store your personal information
Your information is securely stored.
We will retain your information for the time strictly necessary to carry out the purposes set out in this Policy, or while there is a legitimate reason for doing so, in such a way as to guarantee the security and confidentiality of the data. We will immediately afterwards dispose of your information. If you ask us to delete your information before that time, we may not be able to do so due to legal, regulatory or contractual constraints.
Where can your data be transferred
Your personal data may be transferred outside the European Union. In this case, the Data Controller will ensure that the transfer takes place in accordance with the Applicable EU Regulations and, in particular, in accordance with Articles 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to adequate guarantees) of the Regulation.
The Data Controller’s collaborators in charge of managing the Site may become aware of the Users’ personal data. These subjects, who have been instructed to do so by the Data Controller pursuant to art. 29 of the Regulation, will process the Users’ data exclusively for the purposes indicated in this statement and in compliance with the provisions of the Applicable Regulations.
Third parties who may process personal data on behalf of the Data Controller as Data Processors pursuant to art. 28 of the Regulation, such as, by way of example, IT and logistic service providers functional to the operation of the Owner Site, outsourced or cloud computing service providers, professionals and consultants.
You have the right to obtain a list of any data processors appointed by the Data Controller, by making a request to the Data Controller.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact our Data Controller by mail at the registered address Suite C 4-6 – Canfield Place – London NW6 3BT – United Kingdom or by email at [email protected] if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to our Data Controller, New European Media Ltd. by mail at the registered address Suite C 4-6 – Canfield Place – London NW6 3BT – United Kingdom or by email at [email protected].
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Changes to this Policy