1. What is in this policy?
This policy tells you:
•who we are
•what information we might collect from you
•what information we might collect about you from other sources
•how we might use you information
•when we might use your details to contact you
•what information of yours we might share with others
•how long we might keep your information for
•your rights about the personal information you give us
We are Global, one of the world’s leading Media & Entertainment groups. As Europe’s largest radio group, we’re home to some of the biggest media brands broadcasting across the UK on DAB & FM and around the world on Global Player, including Capital, Heart, Classic FM, LBC, LBC News, Global’s Newsroom, Smooth, Radio X, Capital XTRA, Capital Dance, Gold, our pop and internet culture website, PopBuzz and our licensed broadcast partners, Communicorp and Quidem. Global is also one of the leading Outdoor companies in both the UK & Europe, with over 253,000 sites reaching 95% of the UK population.
Our services sometimes link to services or adverts run by other companies, for example, when you click on an online advertisement on one of our websites. These take you away from a Global website or brand app, and these companies have their own privacy and cookie policies. We have no control over the content or privacy practices of those other platforms and the information you give them will follow their policies and rules and not ours. We advise you to check their privacy policies before providing your information to them.
The information we may collect about you will vary depending on how you interact and engage with us. It may include the following:
a. General identification and contact information
We may collect and process your name, address, phone number, email address, IP address (a code given to devices connected to a computer network that uses the internet), username, password, age, gender and date of birth when you share them with us, for example, when you:
• create an account to listen to our radio stations, playlists and podcasts on Global Player;
• visit our websites;
• enter a competition; or
• sign up for a VIP account.
We will combine the information we collect about you so that we can tailor our communications with you such as emails or texts and bring you age appropriate content we think you might enjoy. We’ll also serve you adverts we think you would find relevant as long as you have given us your consent to do so. You can manage your advertising preferences through our Privacy Manager.
Please visit our FAQs page and refer to our “How Global Player uses your data” section for more detail on what personal information we collect when you register a Global Player account.
b. Financial information
We may collect your name, bank account and sort code, for example, to transfer a cash prize to you if you have won one of our competitions.
c. Device information
We may collect some technical information from devices (e.g. computer, mobile, TV, tablet, speaker or other voice-enabled devices) and web browsers. This might include your full IP address and Device ID attached to your device. This lets us to serve you personalised adverts, recommend content we think you’ll love, understand how many times you have visited our websites and when you have used our services.
We will not collect your Device ID and will anonymise your IP address if you have not consented to the use of them through our Privacy Manager.
d. Usage Information
We may collect information about how you have used our services or programmes, such as the types of articles you’ve read and the stations, shows and podcasts you’ve listened to.
e. Information if you communicate with any of our stations or website
If you call, text, email or communicate with us in some other way, we may collect your name, location and a brief summary of your contribution or opinion. We might then broadcast your contribution or opinion on one of our radio stations along with your first name and general location, unless it is given to us without this information.
We might also use your phone number to call you and invite you for further discussion about a topic on one of our shows. If you call in to talk on our radio stations, we might post a part of the discussion on our social media accounts such as Twitter, Facebook or Instagram. Please note, some of this information may include sensitive information (e.g. political opinion, trade union) when you provide that information to us as set out in section h. below.
f. Location information
When you create a Global Player account, we ask what country you’re in so we can comply with the relevant copyright rules according to the country you are in. We also ask for your postcode so we can serve you localised content, such as news and weather.
We will only collect information about your geographic location based on your full IP address and the GPS of your mobile device, if you have consented through our Privacy Manager.
If you have not consented to the use of your full IP address but listen to podcasts on Global Player, our ad serving systems may still make estimations on your general local area when you listen to podcasts in Global Player (for example, the country, town or county you are likely to be in) using your anonymised IP address and serve you podcast adverts based on those estimations. We will not be able to identify your precise location through an anonymised IP address.
g. Information on your activities outside Global services when you comment on Global
To monitor and understand what people are saying about Global and our brands on social media, we collect information from comments or other information you may have made publicly available about us e.g. comments made on social media platforms. If you use your social media account to directly engage with us (such as tagging one of our social handles in a public post or sending us a direct message), we may also use your social handle to reply to or engage with you, and to track interactions we have had with our listeners on social media.
h. Sensitive information
We will only collect sensitive personal information (also known as ‘special category personal data’) from you if you provide us with it. Sensitive personal information includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation.
For example, you may share your political opinions in a discussion on one of our shows or submit other sensitive personal information if you choose to participate in our surveys.
Please do not submit such sensitive information if you do not wish for us to process it.We will only collect sensitive personal information (also known as ‘special category personal data’) from you if you provide us with it. Sensitive personal information includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation.
We may obtain additional information about you from trusted third parties and public sources:
a. to assist us in our marketing, including Online Behavioural Advertising (“OBA”) (also known as “personalised advertising”), and to ensure that you receive adverts and other information that is relevant to you. For example, you may have entered a competition or completed a survey/questionnaire on a third-party website and agreed that this data may be shared with other parties, including Global. Alternatively, you may have consented to a third-party placing cookies on your device and sharing this information with Global. We only work with reputable third-party providers and take steps to ensure our providers respect your privacy rights.
Information provided to us in this way may include details about your demographics, interests, and other classifications such as gender, age bracket, social grade or hobbies according to your browsing interests. We then use this information to place you in particular groups or segments with other users with similar information (a process known as ‘profiling’ or ‘segmenting’) and may combine this information with other information we hold about you (such as general information, device information and usage Information described in section 3 above) or information we have collected when you signed up as a VIP, so that we can deliver advertising that is relevant based on your interests. For example, if you have been clicking on articles about pop music and listening to our radio stations which play primarily pop music, we may combine this information to understand you have an interest in pop music. As a result, you may be shown more adverts for live pop music events. You can manage personalised advertising settings through our Privacy Manager.
b. If you log in via Facebook or Twitter and other social media platforms, you will be giving the social media platform permission to share some of your details with us depending on your privacy settings on their site. For example, if your Facebook privacy settings are set to allow it, Facebook will provide us with your public profile which includes your name, email address and profile picture.
We have to have a valid reason to use your personal information. This is called a “lawful basis for processing”. We process personal information under the following legal bases:
We use your personal information where you have given us your consent. We rely on your consent for the following:
• to email or text you about products, events, services and promotions that we or our third-party partners are offering;
• to send you notifications on your device;
• to provide personalised messages and content if you are a member of our VIP programme; and
• o collect personal information about you through the use of non-essential cookies to deliver personalised advertising.
When we process personal information based on your consent, you have the right to withdraw consent at any time and we will no longer process your data after your consent is withdrawn.
b. The processing is necessary to fulfil a contract
We may process your personal information when we need to fulfil a contract with you. For example, when you enter a competition on our website and provide us with personal information, we will need to use this personal information to contact you should you win.
c. Legitimate Interest
We process your personal information when we have a legitimate interest to do so, provided that our interests are not overridden by your data protection rights.
Our legitimate interests include where we use your personal information to:
• improve or tailor our content, products, services and customer experiences by monitoring your use of our services and working with our suppliers to improve the products and services we offer, develop new content and services;
• meet our regulatory requirements by delivering age appropriate content;
• where there is an existing relationship between us, we may send you information about products, events, services and promotions that are similar to any you have received or bought from us (unless you have opted out to hear from us);
• ensure the security and integrity of our services
• deliver our services;
• ensure the security and integrity of our services;
• ensure that our websites and apps operate effectively;
• protect customers and other individuals, for example, from abuse and harassment and to maintain their safety, health and welfare;
• carry out market research; and
• deal with your requests, complaints and enquiries. For example, to answer your questions or to respond to a comment or complaint.
d. Necessary to comply with a legal and regulatory obligations
We may process your personal information to comply with our legal and regulatory obligations for example, preventing, investigating and detecting crime, fraud or anti-social behaviour and complying with law enforcement agencies.
a. Our group companies
If you enter a competition we may, if you have agreed, disclose your information to the competition sponsors. If you are a prize winner, we will give your information to the sponsors and share your information with the parties who assist us in providing prizes to the winners.
We may carry out research or analysis, which contains your personal information, via our websites, and share aggregated responses to questions with our partner organisations.
d. Our service providers
We may share your personal information with our external third-party service providers. These include accountants, auditors, lawyers, other professional advisors, IT systems, support and hosting service providers, printing, market research and analysis service providers, website analytics, technical engineers, data storage, cloud providers, outsourced service providers and other similar third-party vendors that assist us in carrying out business activities.
e. Government authorities and related third parties
We may need to share your personal information with Government bodies, law enforcement agencies or other regulatory bodies we are required to do so or where necessary to enforce our rights.
f. Online Behavioural Advertising (OBA)
If you have consented to the placement of non-essential cookies when visiting our websites and using our apps, we will share the personal information we collect via such cookies with third parties such as:
• potential advertisers who want to deliver their adverts to a particular audience and with agencies acting on their behalf. This will include information about particular segments that we have categorised you in, based on the information we hold about you; and
• other third parties who receive limited amounts of information (such as online identifiers) in order to assess whether you have seen an advertisement and whether you took any action based on that advertisement (such as clicking on a link).
When we share your personal information in this way, we ask the recipients to only use your information where necessary in order to choose whether to use our OBA services. However, we cannot control the use these advertisers and agencies will make of your personal information once it is received. For further information about how they may use your personal information, we’d recommend reviewing the privacy information provided by the third parties you have given your consent via the Privacy Manager for us to share your data with.
In addition, if you have registered with Global Player via one of our apps or websites, your user ID will be shared and matched with our insight tools to inform more relevant targeting of audio, video and display advertisements. This includes Nielsen Marketing Cloud, a data management platform which is used to select relevant advertising based on your online behaviour.
You can give and withdraw consent and control which third parties will receive your personal information for OBA purposes via our Privacy Manager.
g. When you use a device such as a smart speaker
You can access our services through voice-enabled devices, such as an Amazon Alexa or other smart speakers. You will be able to link your smart speaker account with your Global Player account. Once linked and provided you have agreed to receive personalised advertising from us (as explained above), you may also receive such advertising via our audio streams when you select them on your smart speaker. The company that provides your smart speaker service shares with us an identifier (in the form of a string of characters) to enable us to do this, but it does not share any other personal data about you with us. In turn, we also do not share information we hold about you with your smart speaker provider.
You can choose not to receive personalised adverts at any time by turning this option off in your Privacy Manager.
We hold personal information for different purposes and the length of time we keep your information will vary depending on the services or products we are providing. We will only keep your data for a reasonable period of time, which is based on the purpose for which we are using your data. Once that purpose has been fulfilled, we will securely delete your data or anonymise your information (so that we, or anyone else, can no longer tell that data relates to you) unless we are required to retain the data longer for legal, tax or accounting reasons..
To determine the period we store personal information, we always stick to these principles:
• we will only keep your information for as long as we need to, and
• we think about what type of information it is, the amount collected, how sensitive or intrusive it might be and any legal requirements.
The table below sets out in more detail the periods for which we hold certain types of personal information.
|Type of personal information||How long we keep it for|
|Personal information that allows you to stay logged into the website||1 year|
|Personal information that allows you to stay logged into the app||Until the app is updated or uninstalled|
|Personal information that relates to your activity whilst in the app||4 years|
|Personal information kept on our customer relationship manager database (including personal data related to competitions, ticketing, bingo and dating).||3 years|
|Personal information relating to entries to our premium rate competitions (i.e. when you text in to our competitions)||2 years|
8. International Transfers of Personal Information
Personal information which you supply to us is generally stored and kept inside the UK.
However, due to the nature of our business and the technologies required, your personal information may be transferred to certain third-party service providers in countries outside the UK. These countries (including the United States) may not have the same data protection laws and may offer a lower level of protection.
If we do need to transfer your personal information in this way, we take steps to ensure your level of privacy including data minimisation, anonymising data, pseudonymising data (a technique that removes or replaces certain information in a data set that could identify people), encryption (a security measure to protect data), undertaking due diligence on the recipients of data and putting in place contractual obligations on them to take care of your data, for example by using approved contractual clauses required by data protection laws. Please contact us for further information on international data transfers.
When you first visit our site or download our apps or after you have deleted our cookies from your device, you will be presented with the Privacy Manager pop up. You can also find the Privacy Manager link at the bottom of all our brand webpages or in “settings” on our apps, including Global Player. You can change your cookie preferences in Privacy Manager at any time.
Data Protection laws give you certain rights in respect of your personal information. Please contact us using the contact details below if you wish to exercise any of your data rights.
You have the following rights:
· Right to be Informed
· Right to rectification
You have the right to have your personal information corrected if it is inaccurate or incomplete. You can also correct personal information yourself if you have registered with us via an account on one or more of our websites.
· Right of access
· Right of erasure
You have the right of erasure (also known as the ‘right to be forgotten’) which allows you to request the deletion or removal of your personal information where there is no compelling reason for us to continue processing it. This right is not absolute, and there are circumstances where we may need to continue processing your data despite a request for erasure.
· Right to object and opt-out of marketing
You have the right to object to certain types of processing of your personal information. This includes the right to object to direct marketing. You can exercise your right to opt-out of further direct marketing when you receive such communications from us (via the ‘unsubscribe’ option we include in each email or you can contact us directly.
· Right to portability
You have the right to receive certain personal information from us in a commonly used electronic format (such as a Microsoft Excel file) so that this personal information can be used in a different service.
· Right to restrict processing
You have the right to restrict or ‘block’ the use of your information in certain circumstances such as when you think your data rights outweigh our legitimate interests in the processing of your data. When you exercise this right, we can still store your information but cannot undertake further processing.
· The right to withdraw consent
If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful).
If you wish to submit a request in relation to any of your rights above, please contact us at: email@example.com.
Please note you may be asked to supply us with proof of identity and other additional information before we will be able to provide you with a response. We aim to respond within one month of receiving your request or identifying information (if required), and we will let you know if we anticipate your request taking any longer.
While we usually act on requests, we can refuse to do so (or may charge a reasonable fee to cover our administrative expenses) where you make baseless, excessive or repeated requests or ask us for further copies of information we have already provided.
11. Contact Us and Complaints
If you do have any concerns, we would like you to give us the opportunity to know about them so we would encourage you to contact us first so we can help you. For a query or complaint, please email firstname.lastname@example.org or write to our Data Protection Officer at email@example.com.
If you do not think we are handling your personal information adequately, you have the right to lodge a complaint with the UK privacy regulator, the Information Commissioner’s Office. For further information, including contact details, please visit www.ico.org.uk.
If you are based in a country in the EU or EEA and would like to make a data privacy related query, please contact our nominated representative in the EU, Exterion Media (Netherlands) B.V. Karspeldreef 8, 1101 CJ Amsterdam, 33207193 by emailing firstname.lastname@example.org and stating the country you are situated in.
13. List of data controllers in Global’s group companies
|Global Media Group Services Limited||Global Outdoor Media Limited (was Exterion Media (UK) Limited)||Real Radio (North East) Limited|
|Atlantic Broadcasting Limited||Global Radio East Midlands Limited||Real Radio (North West) Limited|
|Birmingham Broadcasting Limited||Global Radio (AM) Limited||Real Radio (Scotland) Limited|
|BRMB Limited||Global Radio Hampshire Limited||Real Radio Limited|
|C E Digital Limited||Global Radio Holdings Limited||Smooth Radio London Limited|
|Capital Gold Manchester Limited||Global Radio London Limited||Smooth Radio Scotland Limited|
|Capital Radio Investments Limited||Global Radio Limited||Smooth Radio West Midlands Limited|
|Capital Radio Restaurants Group Limited||Global Radio Media Management Limited||South Hams Radio Limited|
|Capital Radio Restaurants Limited||Global Radio Midlands Limited||Southern Radio Group Limited|
|Capital Radio Telstar Entertainment Direct Limited||GWR (West) Limited||Southern Radio Limited|
|Capital Radio Trustee Limited||GWR Group Limited||Suffolk Group Radio Limited|
|Capital XTRA (previously Soul Media Limited)||Harlow FM Limited||Tainside Limited|
|Cardiff Broadcasting Company Limited||Juice Holdco Limited||Trustees of the Capital Radio plc Pension and Assurance Scheme|
|Chill Radio Limited||Lancashire Broadcasting Company Limited||Trustees of the Midlands Radio Group Pension Scheme|
|Chiltern Radio Limited||Lantern Radio Limited||Two Counties Radio Limited|
|Classic FM Limited||LBC Radio Limited||Wiltshire Radio Limited|
|Digital Audio Exchange Limited||Leicester Sound Limited||XFM Limited|
|Digital News Network Limited||Marcher Radio Group Limited||XFM Manchester Limited|
|Essex Radio Limited||Mid Anglia Radio Limited|
|First Oxfordshire Radio Company Limited||MXR Limited|
|Galaxy Radio Birmingham Limited||Now Digital (Southern) Limited|
|Galaxy Radio Manchester Limited||Orchard FM Limited|
|Galaxy Radio North East Limited||Outdoor Plus Limited|
|Galaxy Radio Yorkshire Limited||Plymouth Sound Limited|
|Gemini Radio Limited||Primesight Limited|
|Global Academy UTC Trust Limited||Radio Broadland Limited|
|Global Charities||Radio Invicta Limited|
|Global Charities (Trading) Limited||Radio Mercury Limited|
|Global Media & Entertainment Limited (previously known as This is Global Limited)||Radio South Limited|
|Global Music Television Limited||Radio Trent Limited|