Privacy Policy

PRIVACY POLICY

Important: please read this privacy policy as it applies to any personal data you provide us or we collect about you, for example if you access the website at https://headlines-network.com or any other website owned, operated or provided by Headlines Network Limited, incorporated in England, company number 13490727, registered office Cambridge House, 16 High Street, Saffron Walden, Essex, CB10 1AX (‘website’ and ‘Headlines Network’, ‘us’, ‘we’ respectively) or use any of our products or services or register for or attend one of our workshops (‘services’).  

We do not market to or enter into contracts with children nor do we collect personal data from any person under 18 years of age.  Please do not access or use the website or services if you are under 18 years of age.

This Policy

This Policy sets out what personal data we might collect, how we process and protect that data, the lawful grounds for that processing, and your related rights.  We always seek to comply with the data protection laws applicable to our processing of personal data. For example, the EU General Data Protection Regulation 2016/679 (‘EU GDPR’) may apply and, as a UK company, the UK Data Protection Act 2018, the UK e-Privacy Regulations (‘PECR’), and the UK-adopted version of the EU GDPR (‘UK GDPR’) apply directly to all our processing. 

We use ‘GDPR’ to refer to either the EU or UK version as they’re almost identical. The GDPR is the world-standard for data protection laws, inspiring legal developments around the world.

‘Personal data’ is a defined term in EU and UK law. We also use it here to cover ‘personally identifiable information’ as defined in US law, and other similar legal definitions. Essentially ‘personal data’ means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly from that information alone or in conjunction with other information.

In most cases, the lawful ground (or legal basis) for our processing will be that the processing is necessary: (i) for our legitimate interests in carrying out our business, including to maintain, improve and market our products and services, provided those interests are not outweighed by your rights and interests (‘Legitimate Interests’), (ii) to perform a contract with you (‘Contract’), or (iii) to comply with our legal obligations (‘Legal Obligation’). Where processing is based on your consent (‘Consent’), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent when we ask for your consent.

As data protection law and practice are constantly developing, we’ll need to update this policy from time to time, which we’ll do by posting a new policy on the Website that takes effect from the date stated.  It is your responsibility to return to the Website from time to time and check for changes.

How Do We Obtain Personal Data?

We collect or are provided personal data in the normal course of business. For example:

• you  may provide us with your details when you become a customer, such as your  name, contact details, employer and demographic data (‘Account Data’),
• we  may receive personal data from our customers when using our Services, such  as names of team members or data entered into the Services (‘Service Data’),
• you  may provide us with your details when you ask about using our products or  services (through the Website, by email or otherwise) and we may otherwise  lawfully obtain contact details of potential customers for our Services  for our marketing purposes, for example from publicly available business  contact information or your business website (‘Marketing Data’), 
• when  you visit the Website, we may collect information about your visit such as  your IP address and the pages you visited and when you use our Services,  we may collect information on how you use those Services (‘Improvement  Data’), and

In ‘GDPR-speak’, we are the ‘controller’ of Account, Marketing, Improvement Data as we determine the purposes (the ‘why’) and the essential means (the ‘how’) of the collection and processing. We are the ‘processor’ of Service Data as the customer remains the ‘controller’ of Service Data and we only process Service Data to fulfil our contract with the customer and on their instructions.  

Your Provision of Personal Data

When you provide us with personal data about yourself or another person, for example a colleague or a contact, you are confirming to us that you have their consent or are otherwise authorised to provide us with that information and that any personal data you give us is accurate and up-to-date.  

Provision of personal data to us is never a requirement, however if you do not provide us with the personal data necessary for us to carry out an action at your request or under a contract with or relating to you, for example to respond to your query or provide Services to you, we may not be able to respond to your query or provide Services to you.

Special Categories & Crime

 Given the nature of our business, we do not ask for ‘special categories of personal data’ such as information about your political opinions, racial origins or sexual life, or personal data relating to criminal convictions and offences - and we would ask you not to send any to us or upload any into the Services.  

We are not seeking your medical (health) information but due to the nature of the workshops, you may disclose information relating to your mental health. Where this is collected, we will maintain it in an anonymous fashion. In the unlikely event that we need to process that information, we would seek your consent.

How do we use personal data?

We use personal data in the normal course of our business, including to provide, secure, manage and improve our Services and to meet any binding contractual or legal obligations. This includes:

• to  respond to enquiries about the Services, to provide the Websites and  Services, to provide advice and support. Lawful basis: Legitimate  Interests or Contract.
• to   analyse and improve the Website, the Services, for example for technical  or security purposes and to improve the customer experience. Lawful basis:  Legitimate Interests, however where for example applicable law requires  your consent to use certain cookies, we will ask for your Consent having  provided you with relevant information.
• to  market our Services – if we do so, we will provide you with an easy and  free way to opt-out of receiving such communications in the future. Lawful basis: Legitimate Interests (or Consent as above).
• in  certain circumstances, to share it with a limited number of third parties  as described in this policy, for example for operational requirements and  business continuity purposes. Lawful basis: most processing will be based  on Legitimate Interests, some processing is based on Contract and, where necessary (as above) some processing may be based on your prior Consent.

Electronic Direct Marketing

Where we carry out electronic direct marketing – including phone calls, automated phone calls, emails, SMS and IM – we will comply with the relevant, applicable laws including the EU e-Privacy Directive, which has been implemented by national laws across the EEA and in the UK. This means for example that we will, where required, check national do-not-call registers and obtain your prior specific and informed consent, particularly where you are acting as a consumer. 

Sharing Data & International Transfers

We will not give, sell or rent your personal data to third parties so they can market their services to you. We may share personal data in the following limited circumstances.

• For  provision of the Services, and for our own disaster recovery and business  continuity purposes, we may store or transmit personal data to or through  third party providers, such as with our contractors and advisors to help   us operate, secure and analyse our business. Lawful basis: Legitimate Interests or  Contract.
• We   may be obliged to disclose your personal data to comply with a law, order  or request of a court, government authority, other competent legal or  regulatory authority or any applicable code of practice or guideline.   Lawful basis: Legal Obligation.
• If  we enter negotiations with a third party for the sale or purchase of all  or part of our business, we will only disclose personal data to that third  party to the extent it relates to that business and only under conditions  of confidentiality requiring the third party to be bound by the privacy      policy that applies to that data. Lawful basis: Legitimate Interests.

In each case, we share the minimum personal data necessary, and we have written contracts in place incorporating relevant wording to safeguard that personal data and comply with applicable laws, and we will only share such data as is necessary for the purpose in question.  Our starting position is always to keep personal data within the UK or European Economic Area (‘EEA’) where the UK GDPR or EU GDPR applies respectively.  However, in order to carry out the above purposes, we may use third parties and their facilities outside the EEA.  In all such cases we will ensure that appropriate security measures are in place to protect your personal data and a valid legal basis for the transfer applies.

Retention 

As a default position, we will only retain personal data for any statutory retention period, then a reasonable period (if any) necessary for the above purposes.  This is subject, for example, to any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights.

Security

The security of data is very important to our business.  In accordance with our legal obligations, we take appropriate technical and organisational measures to protect your personal data and keep those measures under review.  However, we can only be responsible for systems that we control and we would note that the internet itself is not inherently a secure environment.

Anonymised data

We may create anonymised data from personal data, and any anonymisation would be carried out in accordance with applicable law as well as relevant guidelines from regulators such as the UK Information Commissioner (‘UK ICO’).  Anonymisation may, for example, be achieved by aggregating data to the point that no individual can be identified such as aggregating website use statistics to see which web content is working well and which could be improved.  Anonymised data does not allow for the identification of any individual person and, as it is no longer personal data, neither data protection laws nor this Privacy Policy would apply to such data.

Third Party Services

If you access the services of another provider through our websites or services, for example through a link on the Website, your use of those services is entirely at your risk and governed by the terms and privacy policy of that third party provider.  If we resell a service delivered or provided by a third party (‘Third Party Service’), including any software that is delivered or owned by a third party (‘Third Party Software’), it is that third party’s separate privacy policy that will apply to your personal data and your use of the Third Party Service and Third Party Software. Your use of a Third Party Service is not covered by this Privacy Policy. Please therefore review the privacy policy for any Third Party Service and Third Party Software before using it.

Your rights

Under the UK and EU GDPRs, you have the following rights (some of which may be subject to conditions set out in the relevant GDPR):

• to know if we  process any personal data about you and, if we do, with certain  limitations, to a copy of that personal data,
• to ask us to  remove or correct any of that personal data that is inaccurate, 
• to object to  certain processing, 
• to withdraw  any consent you may have given us for any processing of your personal data,  
• to ask us to restrict processing certain of your personal data, 
• to ask us to  erase your personal data, and
• to ‘port’ certain  of your personal data to you or another provider, provided in each case that we have such data and certain conditions are met.

You have the right, at any time, to object to the processing of your personal data for direct marketing.

‘Do Not Track’

The Website does not use technologies that respond to ‘Do-Not-Track’ signals communicated by your internet browser.

Cookies

Our Website uses cookies and/or similar technologies.  You may decline cookies via the popup when visiting this website but may render some elements of the service inoperable, such as the Disqus platform.

Please see the  table below for the cookies that are enabled when you choose to accept them,

Headlines Network Platform Session Management Cookies – tccl_visit , dps_site_id Duration – Session Headlines Network Platform Cookie Management Cookies – Cookie_warning_dismissed, cookie_terms_accepted Duration – 2 months 

Headlines Network Platform Site Management Cookies – _tccl_visitor Duration – 1 year 

Disqus Platform Management Cookies – __jid, disqus_unique, disqusauth Duration – 1 year 

Google Marketing Cookies – NID Duration – 6 months

 _Secure-3PAPISID, _Secure-3PSID, _Secure-3PSIDCC Duration – 2 years 

SecureServer Site Management Cookies – OPTOUTMULTI, utag_main, _policy, market, visitor Duration – 1 year 

Contact Us

If you’ve any question you can always contact us at the address above or by email to info@headlines-network.com. You have the right, at all times, to notify a complaint to any regulator such as the UK Information Commissioner. We always welcome the opportunity to discuss and resolve any complaint with you firs