INFORMATION WE COLLECT
This section details the information we may collect about you. We explain why, and how, we use it in later sections.
Account information
If you decide to create an account or enquire about one of our products or services, we’ll ask you to provide us with some specific information, for example:
- Basic personal details – such as name, title and date of birth;
- Personal contact details – such as home address, delivery address, home phone number, mobile phone number, and email address;
- Work details – such as job title, department, company name, company address, work email address and office phone number;
- Log in details – such as username and password.
Additional information
On occasion, we will ask you to voluntarily provide additional information, for example:
- Your opinion of our products and services;
- Your preferences, including newsletters or other content offerings;
Information we obtain from partners and public sources
In some circumstances, we collect information about you from our partners or from publicly available websites to help us better understand our audience and enhance the relevance of our content. For example, in some cases we obtain the contact details of potential speakers for our events from public websites.
Information we obtain through cookies and similar tools
We use cookies (and similar technologies) and analytics tools across our Sites to collect information about you. This information can be used to improve the performance of the site, make advertising more relevant and enhance your user experience. We provide detailed information about cookies and similar technologies within our Cookie Policy; examples include:
- Your usage – we use cookies to understand how our customers use our Sites and interact with our communications and journalism. For example, we use technology on our Sites, which records user movements, including page scrolling and clicks. (We do not record payment details.) This helps us to identify usability issues and improve the assistance we can provide to users and is also used for aggregated and statistical reporting purposes.
- Your device – we use cookies to understand what type of device you are using to show you the best version of the site.
- Your engagement with advertisements – we use cookies to understand what advertisements you have been shown, or clicked on to present you with advertisements that are more relevant to you.
- If you wish to manage your cookies, please follow the instructions in the “How to manage cookies” section within our Cookie Policy.
LAWFUL BASIS FOR PROCESSING
We only process personal information where we have a lawful basis for doing so, such as the following:
- User consent – This is where you have given us explicit permission to process personal information for a given purpose. For example, if you complete one of our general enquiry forms, we would ask for your consent if we wanted to use your personal information for any other purpose. You have the right to withdraw this consent at any time. You can manage your preferences by contacting us at [email protected].
- Legitimate business purposes – This is where we have a legitimate interest, as a business, to process personal information. We take due care to balance our interests against your right to privacy.
- Contractual necessity – This is where we have to process personal information to meet our contractual obligations. For example, if you are a print subscriber, we would need to process your delivery address to fulfil your subscription.
- Legal obligation – This is where we have to process personal information in order to comply with the law. For example, we process and retain customer invoice information to comply with financial regulations.
HOW WE USE YOUR PERSONAL INFORMATION
We collect personal information for the following reasons:
- To provide our service – We require some of your basic personal information so our services work as you would expect, for example, delivering the newspaper to your correct address, providing access to our digital content, notifying you of changes to our services and dealing with customer services queries. We keep records of communications with our customers for monitoring and training purposes.
- To improve and maintain performance – In order to provide you with the best possible user experience, we need to make sure that our products and services work as they should. Using personal information helps us understand how our readers use our Sites so we can make improvements. This includes testing proposed developments on our Sites, reaching out to our customers to communicate changes or new offerings.
- To bill our customers – We provide you with the ability to pay for subscriptions and other services through a third party payment processing service provider. We will also update your payment information in the event that a payment is unsuccessful. You can manage your payment information at any time by contacting customer services at [email protected]
- To monitor compliance with our policies and terms – For example, we monitor activity on our Sites to detect and prevent invalid or fraudulent traffic.
- To personalise our products and services – We improve your experience of our products and services by personalising parts of our Sites with the information you give us and what we learn about you. This includes showing you articles you may be interested in and recommending emails you may wish to sign up to. Where our Sites have such functionality, you can manage elements of personalisation in your account settings.
- To communicate product changes and offers – We want you to get the most out of our products and services, including showcasing our latest content and newsletters. On some occasions, we will contact you with offers and promotions, exclusive event invitations and feature announcements. You are able to change your preferences at any time by contacting customer services. We also personalise our communications for strategic purposes. For example, we might offer group subscriptions to certain companies.
- For the purpose of advertising – We rely on advertising revenue in part to support our journalism. We need to process your information to understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising. You may also see advertisements that are targeted to you based on other non-personal information, for example, the article that you are reading.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We disclose personal information to facilitate the running of our business or to provide specific services you have requested. Commonly, we will disclose information to:
- Service providers – We engage service providers who help to support our business and improve our products. These service providers include, for example, fulfilment providers for delivery of our digital content and marketing; customer service agencies; hosts, organisers and sponsors of our events; organisations that host our Sites or databases; and providers of online surveys. We also work with a number of distribution partners to deliver print editions. We have contracts in place with these data processors and they can only use your personal information under our instruction. For example, if you have a print subscription with us, we will disclose your information (address, contact details) to our distribution partners to facilitate delivery of the newspaper or magazine.
- Advertisers – We, and our advertising partners, use cookies to collect personal information and serve you with advertisements that we believe are relevant to you and your interests. There is more specific information about our advertising partners and data sharing in our Cookie Policy.
- Social media providers – Information will be shared with social media platforms where you log in to our Sites via a social media account, or use components on our Sites provided by social media platforms (e.g. the “Facebook Recommend” function). We also share the information of our subscribers with social media partners for the following reasons:
- To prevent existing subscribers from being targeted with subscription offerings on social media platforms;
- To create lookalike audiences for the purposes of targeted advertising on social media platforms
- To encourage users to get the most out of their subscription.
- Other users – Our Sites are publicly accessible and anyone around the world who accesses our Sites will be able to see anything you post, such as comments about an article. We encourage you to use a pseudonym when commenting on our Sites if you do not wish to be identifiable to other readers.
- Legal processes and successors in title – We may also disclose your information to comply with applicable laws, court orders or other valid legal processes, and to enforce or apply our terms of use, any subscription agreement, or any of our other rights. We may transfer or disclose your personal information to any entity which takes over or acquires Kyiv Post. We also share aggregated, non-identifiable information with third parties. Before sharing this information, we ensure that it cannot identify you as an individual. For example, we may release information about the size and growth of our audiences.
