Rombalds Radio - privacy policy

Privacy and data (GDPR) compliance

Rombalds Radio is committed to respecting and protecting your data whilst it is in our care. We collect your personal information because it helps us to understand your needs and guides the way in which we interact and communicate with you about our products and services now and in the future. We have strict policies and procedures in place to protect your data when you send it to us, when we process it in order to provide you with the services you have requested or, where you have given us your permission to do so, to send you information that we think you will find interesting, and thereafter when we store your data on our secure servers. 

We abide by the requirements of the Information Commissioner's Office, the regulator of the Data Protection Act 1998. Rombalds Radio complies with the GDPR, which came into force on the 25th May 2018.

The following document outlines our policies on:

  1. Data protection

  2. Lawful basis

  3. Data retention

  4. Cyber security

  5. Data requests

  6. Privacy

  7. Changes to our policies

  8. Contacting us about your data

This policy explains how we will collect information about you through interaction with us over the radio, at events or through any sales channel and what we will use it for. 

Please note, this policy does not apply to websites, text services or apps operated by third parties, who will have their own policies covering the use of your personal information.

1. Data Protection Policy

Collection of information
We collect personal information from you through your interaction via our websites, text services or other media such as giving your information to one of our team in person at an event. This may occur when you participate in, or sign up to, any of Rombalds Radio’s services, such as competitions, research panels, or if you use any of our apps.

The information we collect will vary depending on the service you request but could include name, address, phone number, email address, username, password, age, gender, date of birth, household composition, comments, competition answers. We may also ask for additional information depending on the nature of the service provided. We will not normally collect any sensitive personal information from you, and in any event, will request your express consent to do so. We do not aim to collect any personal information from individuals under the age of 16. We may obtain additional information about you from third parties, data brokers and from social media links.

Our apps
If you use any of our apps, we may collect the following information:

(i) your location – upon your first use you may be prompted for permission for us to use your location (which you may decline) in order to offer you relevant services (we cannot offer relevant services if you do not permit us to detect and use your location); and

(ii) your device - if you access our services from a device such as a mobile telephone running an application, we will uniquely identify each instance of the application, but we will not be able to personally identify you from this information.

(iii) your contact information - if you send an email or make a phone call to us using the Contact section of our app, your email address or telephone number is likely to be displayed to us and retained in order for us to be able to respond to you or follow-up a message that you have submitted.

Cookies
We also collect certain information through the use of “cookies” and other similar automated means. Cookies are small pieces of information that are stored by your browser on your computer's hard drive. For more information about cookies and how they are used, please read our Cookie Policy.

Rombalds Radio uses cookies for a number of reasons: 

  1. To provide you with a more personal and interactive experience on our sites.

  2. For statistical purposes to track how many users we have and have often they visit our websites.

  3. To collect anonymous user information so we can analyse how our website is being used and the number of visitors.

  4. To track who has seen an advert and clicked on it.

  5. To show you adverts that you may be interested in and to control the number of times you see them and measures the effectiveness of the ad campaign.

  6. We may use 'Flash' cookies to store your preference for your media player. If we do not use them, it may not be possible for you to watch some video content.

You have the ability to accept or decline cookies, but please be aware that for some parts of our sites to work, you will need to accept cookies. For more information please visit www.allaboutcookies.org and/or www.youronlinechoices.com

Use of information
We will use your personal information for a number of purposes including the following:

  • to provide, administer and communicate with you about our services and promotions (eg. to enable you to log in to your account and/or enter competitions on our website);

  • to create statistics, profiles and marketing opportunities, and analyse information to formulate opinions. To do these things, we might use information about you from other organisations;

  • to help prevent fraud and loss;

  • to train our staff;

  • to get in touch with you about products, events, promotions and services that we or our third party partners are offering.

This could be by email, phone, text, or another form of electronic communication. We will only do so if you have told us that you want to hear from us or our third party partners. If you call into one of our broadcasts and make rude or offensive remarks, we will keep a record to block further live calls from you.

Sharing information

  • We will not sell, trade, rent or otherwise pass on your personal information to others, including any personal information that we collect through the use of cookies, except as described here or with your prior consent.

  • We may share personal information with service providers who perform functions and services on our behalf. Such third parties will be provided with personal information necessary to perform the services on our behalf but are not authorised to use such information for any other purposes.

  • If you sign up for one of our partnered services, you will be providing your information directly to our third party partner and you should read their privacy policy to fully understand how your personal information might be used. They may share certain information with us (but not sensitive personal information or financial information) which we will only use for the reasons set out in this Policy.

  • Only where you have agreed to receive marketing communications from third parties, will we pass on your personal information for this purpose.

  • We may disclose your personal information when you enter a competition (for example to the competition sponsors or to provide winners with their prize).

  • We will always ask for your consent before we publish any material provided by you or information about you.

  • We may carry out research or analysis, which uses your personal information, via our sites and share "pooled" responses to questions with our partner organisations.

  • We may also disclose personal information about you to comply with applicable laws and when requested to do so by law enforcement agencies or government bodies.

  • We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any enquiries concerning the processing of that information.

Use of aggregate information
We may share anonymous aggregate statistics about our users, sales and traffic patterns with our advertisers and other third parties. However, it will not be possible to identify you from this information. For example, we might report to potential advertisers that a certain percentage of our users are interested in its products, based on information requests. Some of this information may be collected using cookies as described above and in our Cookie Policy.

Data transfers
We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect the information as described in this Privacy Policy.

2. Lawful basis

Rombalds Radio collects and holds data under the following types of lawful basis:

Legitimate interest
Data collected on sales contacts, active and former clients, prospective and current employees is held on the basis on legitimate interest in the station and the services it provides.

Consent
Data collected from competitions, marketing and promotional exercises is held on the basis of consent, all data collected in this manner is done on an opt-in basis, only used in accordance with data preferences submitted at the time and stored securely.

3. Data retention

We will keep personal information only for as long as we need it to maintain our relationship with you, provide you with the products, services or information you requested, to inform our research into the preferences of our listeners, to comply with the law, and to ensure we do not communicate with individuals that asked us not to.

When we no longer need the information, we will dispose of it securely, using specialist companies to do this work for us if necessary. Personal information is stored by us on computers located in the UK and the USA. We may also store information in paper files.

We may transfer personal information to reputable third party organisations situated inside or outside the European Economic Area. These organisations are required to safeguard personal information pursuant to their contractual obligations or participation in international data transfer mechanisms including the US-EU Privacy Shield framework.

Rombalds Radio reserves the right to retain data for a maximum of 10 years from collection.

4. Cyber security

All data held by Rombalds Radio is handled with strict security, we are committed to protecting your data both on and offline as a result we have implemented security measures to protect against the loss, misuse or theft of your data.

We review our cyber security procedures on a regular basis, all personal information is stored on password protected computers or on secure web-based systems using SSL encryption. The internet is not a totally secure medium and you acknowledge and agree that Rombalds Radio shall not be responsible for unauthorised use, distribution, damage or destruction of personal data, except to the extent that we are required to accept such responsibility under the Data Protection Act 1998.

When we ask another organisation to provide a service for us, we ensure that they have appropriate security measures in place. If we or our service providers transfer any information out of the European Economic Area (EEA), it will only be transferred with the correct protection in place, as stated UK law. 

5. Data requests

Under the Data Protection Act 1998, you have the right to see what information we hold about you and you may ask us to make any changes that you consider necessary to make the information accurate. You have the right at any time to request that Rombalds Radio stops using your data. You may request access to the personal information we hold about you.

Data complaints: We endeavour to respond to you within 30 days from receipt of your correspondence related to privacy matters. However, you have the right to contact the data protection supervisory authority to lodge a complaint with the UK Information Commissioner’s Office online at https://ico.org.uk/concerns/handling/

Data access: You have the right to request us to provide you details of the personal information we hold about you.

Data correction: You have the right to ask us to correct our records if you believe they contain incorrect or incomplete information about you.

Data erasure: You have the right to erasure (deletion), without undue delay, of your personal information for which you later withdraw your consent to processing, or when it is no longer needed for purpose it was originally collected.

Data processing restrictions: You have the right to temporarily restrict our processing of your personal information if: you contest the accuracy of your personal information; you prefer we restrict its use rather than erase it; you need it to be preserved to establish, exercise, or defend a legal claim; whilst you are verifying whether we have overriding legitimate grounds to use it. You have the right to be informed before we lift the processing restriction.

Data portability: You have the right to ask us to provide you (in a structured, commonly used, and machine-readable format without hindrance) personal information about you that we have which you had provided to us. You may ask us to transmit it directly to another controller if it is technically feasible.

If you would like to submit a request please contact us on admin@rombaldsradio.com and we will endeavour to respond within 30 days of the request being made.

6. Privacy Policy

How we collect and use your personal data

We collect your details when you register on our website, subscribe to our service; place an order on our website; search for a product; correspond with us by phone, e-mail or otherwise; participate in discussion boards or other social media functions on our website, enter a competition or promotion, or make a phone call to our studio or office number.

With regard to each of your visits to our websites we may automatically collect the following information: 

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; 

  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. 

We will always be transparent about how we plan to use your data so that you have the choice whether or not to give it to us. We respect your preferences and will do our best to make sure that we keep our promises. If you give us your consent to send you further marketing messages we may contact you from time-to-time with carefully selected offers and promotions from ourselves or from our network of carefully selected partners, from which you may always opt-out or unsubscribe. It is not our practice to contact you if you have made it clear that you do not wish to hear from us about our products and services. 

We may need to authenticate your identity to provide you with access to subscriber-only services. We might also send you surveys or invite you to enter a competition or receive a newsletter, for instance. If you do not wish to participate you may simply decline our invitations. 

Apps
Our iOS, Android, Amazon and other "apps" may collect user data, which we use to learn about our listeners, improve our apps or - if you have sent us a message - use to contact you in order to respond to your communication, as set out above in our Data Protection Policy.

Google Analytics
Google Analytics is implemented on this website and collects various data points from visitors to the website. IP Addresses are used to distinguish visitor numbers to the website. Google Analytics will record the country you access this website from using your IP Address. Data gathered by Google Analytics allows us to analyse visitor numbers on this website, track users' movement around the website and from page to page. We use this information see how visitors use and interact with our website. Google Analytics data is stored for a period of 26 months which allows us to build a year upon year picture of visitor numbers to our website.

Data gathered by Google Analytics may be stored outside of the European Union in line with its undertakings through the EU-US Privacy Shield Program. Further information can be found here.

You can find out more about Google’s position on privacy as regards its analytics service here.

We use this information collected by Google Analytics for reporting purposes and to advertise online. Third-party vendors, including Google, may show your ads on sites across the internet. We may use the cookies relating to Google Analytics together with third party cookies to inform, optimise and serve ads based on a user's part visits to our website. 

Emails
If you submit an enquiry through our contact form, that enquiry will be emailed to a mailbox monitored by our team at Rombalds Radio. The email is then stored securely on our email server or a Gmail secure server, which enables us to respond to your enquiry.

Your enquiry may be forwarded to one or multiple mailboxes within Rombalds Radio to ensure it is dealt with and acted upon by the appropriate person.

Sharing your data with other companies

Except as otherwise stated in this Privacy Policy or in the data collection statements that will always be visible when we collect your information and where we give you the opportunity to select your preferences, we may release your data to external companies that we use to process your orders, or charge your credit card, run our SMS services, for instance. Every supplier we use has to go through a rigorous up-front process to ensure that their processes are at least as good as our own, and expected to sign a contract that defines what their responsibilities and liabilities are. We make site visits regularly whether our suppliers are in the UK, the EEA or outside the EEA, where we require an EU approved model contract to be signed. 

However, you expressly consent to the sharing of your personal data with those suppliers with whom we contract in order to provide services to you, otherwise we may not be able to provide the level of service that we know you'll require. 

If you send in a comment, we may post it on our website or use it as a testimonial without mentioning your full name or publishing any information that would identify you. Furthermore in some circumstances we may display some of your information such as your username and age. Others may be able to see your personal data if you post any information on comments sections, bulletin boards or forums and may be used to send you unsolicited communications over which we have no control. 

Please take care when using social networking sites to which we may invite you to join that you do not disclose anything that you might later wish to retract. 

There are certain times when we may be legally required to disclose your data in good faith where it is required by law or to respond to subpoenas or warrants served on us, or where we have a requirement to protect or defend the rights of Rombalds Radio or any users of our servers. We will always ensure that those requesting the information have the legal right to do so. 

If another company should acquire any of our assets, including our database, that company will have the right of possession to the personal data collected by us and will assume the rights and obligations formerly attributable to us and will use the data in line with the terms under which you submitted it or as described in this Privacy Policy. 

The information we may collect from you about others

Sometimes we may offer you the chance to invite a family member or a friend to enjoy a particular service or competition prize. In such circumstances we will collect both your personal details and those of your friend or family member. We will ask your consent to mention your name when we contact the person or persons you have recommended and we will only use this information once and not save it in our database, unless they have entered a competition, for example, when the information will be stored purely for that purpose. If they decide to take up any of our invitations then their data will be treated exactly the same as your own, using the terms under which the data was collected and the information as described in this Privacy Policy. 

Leaving our website and moving on to third party websites

When you click on advertisements or links on any of our website, you will leave and go to a third party site, which is outside of our control. When we place an advertisement on our website, it does not signify that we are endorsing that advertiser's product or service. We do not accept responsibility for content, have no control over and our Privacy Policy does not apply to these companies, sites or content and if such third party sites collect Personal Data, we cannot control how this data is processed, stored or used. We advise that you read their data collection statements, which accompany any registration and their Privacy Policies before you submit your personal information. 

Logging in using social networks

If you login to our sites using a Facebook login or a Google login, you are granting permission to Facebook and or Google login to share your user details with Rombalds Radio. This will include your name, email address, date of birth and location which will then be used to form a Rombalds Radio identity. This will also allow Rombalds Radio and Facebook and/or Google login to share your networks, user ID and any other information you choose to share according to your Facebook and/or Google account settings. If you remove Rombalds Radio from your Facebook and or Google settings, we will no longer have access to this information. 

7. Changes to our Privacy and Data policies

We reserve the right to change our Privacy and Data Policies and all changes will be posted here. Where the changes are significant, we may also choose to email all registered users of our websites with the new Privacy Policy. We may notify you by sending an email to your last known email address or writing to your last known postal address to direct you to the Privacy Policy if the changes are material. Our despatch of a communication to you will, in any event, constitute notification.

8. Contact us

If you have any questions or comments about this Privacy Policy or if you would like to exercise your rights, please contact us on admin@rombaldsradio.com.

We will require that you satisfactorily identify yourself to demonstrate your entitlement to view this data. 

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