Introduction and contents

This is the privacy policy for Guardian News & Media Limited (“ Guardian”), our sites such as theguardian.com (“our sites”), and our associated apps. Some of our other sites and services have their own policies, which will be relevant to you when you are using those sites and services.

Our values guide everything that we do – including our editorial approach and how we use personal data. We are strongly committed to keeping your personal data safe. This commitment exists throughout the lifecycle of your personal data, from the design of any Guardian service which uses personal data to the deletion of that data.

To complement our global approach to privacy protection, this policy also incorporates specific information privacy rights granted to individuals under Californian and Australian privacy law. This reflects our relationship with our readers in these locations where we provide localised editions of our editorial content.

We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics:

Find out more about how we manage your personal data below:


About this privacy policy

This privacy policy explains how we collect, use, share, transfer and sell (for California residents only) your personal data when you use the services provided on our sites and our apps or interact with us. This privacy policy also explains your data privacy rights. This includes subscriptions, vouchers and contributions.

Personal data is any information about you by which you can be identified or be identifiable. This can include information such as:

When we refer to “personal data” in this policy, we are also referencing “personal information,” as it is defined under California law, which you can read more about here, and as it is defined under Australian law, which you can read about here.

Some of our other sites provide additional privacy information. You can read that information using these links:

Sometimes our sites and apps may contain links to sites and services that are not part of the Guardian family of offerings. These sites and services have their own privacy policies. If you follow a link to these non-Guardian sites and apps, you should read the privacy policy shown on their site.

Who we are and how to contact us

Guardian News & Media Limited, Kings Place, 90 York Way, London N1 9GU is the data controller in respect of your personal data that you share with us. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can find our contact details in the “Contact us for information about how we use your personal data” section below.

The types of personal data we collect about you

We collect your personal data when you visit our sites and apps, subscribe for products or services, contribute to the Guardian or when you interact with us. We will only collect your personal data in line with applicable laws. We collect your personal data in various ways:

More detail about these three categories of personal data are provided below.

The personal data we collect when you register for a Guardian account

When you register for a Guardian account on theguardian.com, we collect:

You can change or remove these details using the profile and settings area of your Guardian account.

Personal data we generate about you

When you register for a Guardian account or sign up for a newsletter, we assign you a unique ID number. This allows us to manage your preferences, for example, the newsletters you have subscribed to. When you register for an account we use your unique ID to recognise you when you are signed in to our services. This will recognise you if you sign in using the same account on a new device or through a different application such as the Guardian app on mobile devices.

When you use our sites or apps we may also use cookies or similar technology to collect extra data, including:

We will not collect special categories of data from you - such as personal data concerning your race, political opinions, religion, health or sexual orientation - unless you have chosen to provide that type of personal data to us.

When you use our apps

The Guardian apps use personal data based on the content you have viewed. Information on bugs and crashes is also sent to us when you use our apps. A list of the articles that you have recently viewed is also cached in the local storage on your device. You can delete this reading history in the settings of the app. You can choose to receive notifications on your device via the app, and manage these notifications in the settings of the app.

Using your social media details to sign into your Guardian account

When you sign in to our sites or apps using your Facebook login details, you give permission to Facebook to share with us your email address and certain aspects of your Facebook profile if you have made these public on your Facebook profile. This only includes your first and last name, age range, link to your Facebook profile and profile picture. We do not have access to updates on your Facebook profile. If you use your Google login details, you give Google permission to share the personal data that you have made public in your Google profile. This only includes your first and last name, your email address and whether your email address has been validated, your age range, a link to your Google profile and, if you have one, your profile picture. If you register or sign in with your Apple ID, you give Apple permission to share your personal data with us. You can also choose to hide your email and Apple will create a random email address so your personal email can stay private. This email address will be linked to your Guardian profile and will be used to retrieve your subscribed content.

We will then use this personal data to form a profile for your Guardian account. If you remove the Guardian app from your Facebook settings, or from your Google settings, or your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your Guardian account using your Facebook, Google login, or Apple ID.

Personal data when you post comments about the Guardian on other social media sites

If you have mentioned the Guardian in posts on social media sites, then we may collect your social media handles. For example, when you mention the Guardian in a tweet, we may collect your Twitter handle.

When you post publicly (comments) on our sites

When you post on a discussion board or comment publicly on an article on one of our sites, the personal data you post, including your username and other information about yourself, are publicly accessible. This personal data can be viewed online and collected by other people. We are not responsible for the way these other people use this personal data. When contributing to a discussion, we strongly recommend you avoid sharing any personal details, including information that can be used to identify you directly such as your name, age, address and name of employer. We are not responsible for the privacy of any identifiable information that you choose to post in our online community or other public pages of the site.

How we collect personal data

We collect personal data when you:

How we use your personal data

We use personal data collected through our sites and apps only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.

Legal grounds for using your personal data

The legal ground may be one of the following:

Where we rely on cookies to collect any personal data please see our cookie policy for more information and how to manage your cookie choices through our Privacy settings link on our sites in the footer of every page.

The Guardian is a media organisation and publisher. Data protection law includes certain exemptions when personal data is processed for the purposes of journalism. Those exemptions apply to some of the ways the Guardian uses personal data. This privacy policy does not cover personal data that the Guardian processes for the purposes of journalism.

Access permissions when you are using the Guardian app

When you use the Guardian app, we will ask for permissions to access particular functions of your mobile device. When we ask for permissions will depend on the operating system of your mobile device, but can include:

Updating your personal data and your profile page on our sites

When you register for an account with theguardian.com, you have access to a profile page. Under “edit profile” you can review and update what personal data is public when you comment on our articles, or if people look up your profile. For more information on how to manage your account please see https://manage.theguardian.com/help-centre.

You may also update your marketing preferences in the “emails and marketing” tab in your account.

Personal data that we receive about you from other organisations

Adding to or combining the personal data you provide to us

When you sign up to our services we may add to the personal data you give us by combining it with other personal data shared with us by other trusted organisations. This includes, for example, the region that you are located in, so that we can show you the prices for subscriptions or other products in your local currency. We may also add personal data to improve the accuracy of your delivery address when we send out mail. We may also obtain your personal data from partners whose offers we include in some of our marketing communications and we use this personal data to ensure that we do not send you irrelevant marketing and to ensure the accuracy of the information we hold.

We also use personal data based on the content you have viewed on our sites and apps and your interaction with the content to add you to groups with similar interests and preferences, so that we can make our online advertising more relevant. Sometimes we use data about your interests or demographics that some of our global third parties have collected from you online to add you to these groups, such as Comscore and Nielsen. Please refer to our cookie policy for more information on how we use cookies.

Personal data shared by event partners

When you register or book a ticket for a Guardian event organised by an event partner, your registration data may be shared with us by the event partner.

Children’s personal data

We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal data about children under 13 in providing our services. Some of our services may have a higher age restriction and this will be shown at the point of registration.

We also note and comply with the California law which prohibits sale of personal data of consumers between 13-16 years of age unless their guardian has authorised the sale.

Security of your personal data

We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending any information, including personal data, via the internet is not completely secure. We cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.

When we share your personal data

Within the Guardian group of companies

Depending on where you live, we may share your personal data within the Guardian group of companies in the UK, US, or Australia. We may share it in order to perform a contract with you, for administrative purposes, or when we have a legitimate interest in doing so. For example:

With external organisations

We share your personal data with other organisations that are not directly linked to us under the following circumstances:

Service providers - We may share your data with other organisations that provide services on our behalf. We may do this to perform a contract we have entered into with you, where it is in our legitimate interests or with your consent. Examples of when we may share your data with service providers include sharing with:

Advertising partners - We may also share your data collected through our websites and apps with our advertising partners, as set out in our cookie policy. These partners help us deliver relevant advertising across our websites and apps. For example, we use Google Ad Manager to assist us with the delivery of relevant ads.

Agencies and authorities if required by law - We may reveal your personal data to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if we are required to do so to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect our rights or the rights of anyone else (for example, in response to a valid and properly served legal process such as subpoena or warrant). If we have your contact details, we will take reasonable steps to attempt to notify you prior to disclosing your data unless (i) prohibited by applicable law from doing so, or (ii) there are clear indications of unlawful conduct in connection with your use of Guardian services.

Event sponsors and partners - We may share your personal data with sponsors of Guardian events and partners who we hold events with for marketing purposes when you have given your permission for us to do so. We may also share your personal data with these sponsors and partners for event administration purposes.

Prize draws, competitions and bids - We may share your personal data with sponsors and partners for the purposes of selecting and notifying winners when you participate in any of our prize draws, competitions and bids. We may also share your data with entities offering any prize you have won in order for that entity to contact you about such a prize.

Social media organisations - We may share your personal data with other organisations when our web pages use social plug-ins from these organisations (such as the “Facebook Recommend” function, Twitter’s retweet function, Google+ function). These other organisations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, personal data they collect may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies.

Organisation/s that buy any of the Guardian group companies - We may share your personal data to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with our privacy policy.

When we share your personal data, as specified above, with any organisation which accesses your data in the course of providing services on our behalf, they will be governed by strict contractual restrictions to make sure that they protect your data and comply with applicable law. We may also independently audit these service providers to make sure that they meet our standards.

California resident - Do not sell

These transfers to third parties may constitute “sale” of your personal information under California law. A California resident can halt these sales at any time by pressing the “California resident - Do not sell” link that is located in the footer of every page on our site. Third-parties do not sell personal information that has been sold to them by the Guardian unless you have first received explicit notice and are provided an opportunity to exercise the right to opt out. You can read further about your California rights here.

International data transfers

Data we collect may be transferred to, stored and processed in any country or territory where one or more of our Guardian group companies or service providers are based or have facilities. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal data that we transfer in line with this privacy policy.

Whenever we transfer your personal data out of the UK or the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:

If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the UK or the EEA.

How long we keep your personal data

We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.

How we may contact you

Service communications

From time to time we may send you service emails, for example, telling you your subscription is coming to an end or thanking you when you contribute or place an order with us.

Marketing communications and editorial newsletters

If we have your permission or you have not opted out, we may send you materials we think may interest you, such as new Guardian offers and updates. Depending on your marketing preferences, this may be by email, phone, SMS or post.

We offer a range of editorial newsletters. You can manage your subscription to these emails through your profile page when you are signed in to your Guardian account.

You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email or through your email preferences in the tab “emails and marketing” when you are signed in to your Guardian account.

For more information on how to manage your account please see https://manage.theguardian.com/help-centre.

Market research

Sometimes we may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by signing into your Guardian account and going to the tab “emails and marketing”.

Responding to your queries or complaints

If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.

Special Note to California Users

If you elect to use the “California resident - Do not sell” button, we will not recontact you about that choice for at least 12 months.

Cookies and similar technologies

When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technologies.

This privacy policy includes our cookie policy, where you can find more information about our use of cookies.

Your privacy and data protection rights with regard to the personal data that we hold about you

You have a number of rights with regard to the personal data that we hold about you and you can contact us with regard to the following rights in relation to your personal data:

If you would like to exercise any of your rights specified above, please email [email protected] or write to the Data Protection Officer at Guardian News & Media Limited, Kings Place, 90 York Way, London N1 9GU. We will respond to requests within one month.

We may need verification of your identity to proceed with a request. If you provide us with proof of identity containing information that does not match our records, we may request further proof of identity from you.

If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, for any further copies requested by you, we may charge a reasonable fee based on administrative costs.

Your California privacy rights

Under the California Consumer Privacy Act, California Civil Code Section 1798.100, if you are a resident of California you may contact us with regard to the following rights in relation to your personal data:

If you want to make any of these requests, please contact [email protected]. We will deal with requests for access to your personal data within forty-five (45) days for California-specific requests.

To help us respond as you expect, please specify that you are making a request under the California Consumer Privacy Act. We may need to request specific information from you to help us confirm your identity. If you provide us with proof of identity containing information that does not match our records, we may request further proof of identity from you.

Your rights under the Australian Privacy Act

The Australian privacy Act has rules around how we handle your personal information that may be different to rules in other regions. These rules are set out in the Australian Privacy Principles in force under the Privacy Act 1988 (Cth) (the Australian Privacy Act). We are required to treat your personal information in line with those principles, including to disclose to you what personal information we collect and how we use it, to store your information securely and to support you in exercising your rights.

Personal information we collect and use

When we refer to “personal data” throughout this policy, we are also referencing “personal information,” as it is defined under Australian law, which you can read about here.

Details about the personal information that we collect, use and disclose is set out throughout this privacy policy. You can navigate these relevant sections by going to the contents section at the top of the page.

Your rights

Your rights to privacy are also protected by the Australian Privacy Act, including your:

These principles and rights are reflected throughout this privacy policy.

Opt out of personalised advertising

Under the Australian Privacy Act, you have the right to opt out of the use of your personal information for the purpose of direct marketing, including in relation to personalised advertising. You can opt out of personalised advertising across our website and apps at any time by going to the Privacy settings link on our sites in the footer of every page. You will still see non-personalised advertising.

We and our partners use cookies and similar technologies to collect information about your use of the website to help create reports and statistics on the performance of the website. Analytics cookies such as Google Analytics collect information such as your IP address, device type and operating system, referring URLs, location and pages visited. If you don’t want Google Analytics to be used in your browser, you can install the ‘Google Analytics Opt-Out Browser Add-On’, provided by Google.

For a complete description of our use of cookies and similar technologies globally, please see our cookie policy.

If you have contacted us at [email protected] with a privacy related complaint and you are not satisfied with our handling of that complaint, you may refer that complaint to the Office of the Australian Information Commissioner:

GPO BOX 5218, Sydney NSW 2001

T 1300 363 992

https://www.oaic.gov.au/

Contact us for information about how we use your personal data

If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection Officer at Guardian News & Media Limited, Kings Place, 90 York Way, London N1 9GU. Or, email [email protected].

Complaints will be dealt with by the Data Protection Team, and will be responded to within 30 days.

If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.

If you have a question about anything else, please see our Contact us page here.

For individuals based in the European Union:

Since we do not have an establishment in the European Union, we have appointed an EU based representative to serve as a direct contact for data protection authorities and individuals on our behalf, who can be contacted at [email protected] or MCF Legal Technology Solutions Limited, Riverside One, Sir John Rogerson’s Quay, Dublin 2, Ireland.

Changes to this privacy policy

If we decide to change our privacy policy, the updated privacy policy will be posted on this page. If the changes are significant, we may also choose to email all our registered users with the new details. If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your data.

Changes to this privacy policy to date

The most recent changes to this privacy policy were made on:

A list of all previous changes are available upon request.