Privacy Policy

Introduction

This Privacy Policy explains how personal data is collected and used by The New European Ltd (company number: 13096229) and any other entities within our group or under common ownership from time to time (referred to as “TNE”, “we”, “us”, “our” throughout this Privacy Policy).

In this Privacy Policy, any reference to you includes:

you personally; and
any legal entity (such as a company, partnership, LLP or similar) which you represent,

undertaking any of the following:

using our website (https://www.theneweuropean.co.uk/) (our “Site”) for any purpose (including uploading any material to the Site in accordance with our terms and conditions);
placing an order for any of our products or individual content (our “Products”);
subscribing for or otherwise accessing any of our services, publications, podcasts, articles, blogs, opinion pieces, letters, insights, newsletters, content or otherwise (in whatsoever form produced) (our “Services”), as are listed on our Site from time to time;
engaging or communicating with us by email, telephone, post or through our Site;
engaging with us in any manner through any of our social media accounts; or
otherwise engaging with us in any other manner.

At TNE, we respect your privacy and are committed to protecting your personal data. We recognise that in providing you with our Products and Services, we will collect and use personal data about various categories of individuals. We take data protection very seriously and will ensure that we uphold the trust that our users, subscribers and others place in us when they provide us with their personal information.

This Privacy Policy will inform you as to how we collect, use, handle and disclose your personal data, as well as telling you about your privacy rights and how the law protects you. If you need any more information about our data protection practices, please contact us using the details below.

This Privacy Policy contains the following sections:

Important information
Third Party Links
Data protection principles
How we collect information about you
What information we collect and how we use it
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary

Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy, including “personal data” and “personal information”.

Important information

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal data, including any data you may provide when you contact us via e-mail, telephone, post or through our Site or social media, or any data that you provide through our Site (or other applications, whether owned by us or third parties) when you subscribe to or access our Services, or order our Products, register and access your account on our Site, when you interact with us in person, respond to a survey or otherwise get in contact with us.

Unless expressly stated otherwise, our Site is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller

We are the “controller” for the purposes of data protection law, and are therefore responsible for your personal data.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (see section 10 below), please contact the data compliance manager using the following details:

Contact details

E-mail address: ContactUs@tnepublishing.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 17 June 2021.

We keep this Privacy Policy under regular review and may amend it from time to time. Please check back regularly to view the latest version.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Site may include links to third-party websites, plug-ins and applications such as Facebook, Twitter, Instagram and Audioboom (and therefore indirectly applications such as Spotify, Shopify, Amazon Music and Apple Podcasts). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, save for where these links are to our own brands, and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy or notice of every website you visit.

Data protection principles

We adhere to the principles set out in data protection legislation when handling personal data. These principles require personal data to be:

Processed lawfully, fairly and in a transparent manner.
Collected only for specified, explicit and legitimate purposes.
Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
Accurate and where necessary kept up to date.
Not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed.
Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Not transferred to another country without appropriate safeguards being in place.
Made available to data subjects and allow data subjects to exercise certain rights in relation to their personal data.

We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

How we collect information about you

We may collect, use, store and transfer different kinds of personal data about you. We collect and process personal data about you when you:

subscribe to, or access any of our Services or other content or e-mail communications;
request or order any of our Products;
attend an event run by us;
register for, and access, an account or a subscription on our Site, or otherwise provide information which is consistent with registering for and/or accessing an account or subscription;
provide us with any content or material created by you (in accordance with our terms and conditions), such as letters for publication or comments on an article or blog;
respond to a customer survey;
request information from us about our Products, and/or Services;
are billed or invoiced by us for our Products and/or Services, or any other content or items (whether this is done separately from you placing an order or otherwise);
contact us via e-mail, telephone, post or through social media;
follow us, comment on our posts, or interact with us in any way using social media; and/or
submit an enquiry to us, or otherwise provide information and/or documentation to us in respect of our Products, Services, or otherwise.

Personal data is usually collected from you through direct interaction with us (either in person, by phone, by e-mail, by post, via social media or through our Site). For example, you will provide your personal information when you subscribe for or access any of our Services.

We may collect personal data from our partners or third parties, including through your LinkedIn, Twitter, Spotify, Apple Podcasts, Amazon Music or other online profiles, or from other businesses or sub-contractors that we work with and collect personal data about you, who have provided your personal information to us, either with your consent or on some other lawful basis.

We may also collect personal data when you use this Site, through automated technologies, analytics providers or search engine providers. We use cookies to assist the site running as effectively as possible. For further details, please see our Cookies Policy here: [●].

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of our contract with you, and you fail to provide that data when requested, we may not be able to provide our Products and/or Services (including managing any account and/or subscription which you have with us). If so, we may have to terminate our contract with you but we will notify you if this is the case at the time.

What information we collect and how we use it

The personal data that we collect will include:

Contact details including your name, address, job title, telephone number, e-mail address, account log-in details and social media details;
Payment information, including credit/debit card details and bank account details;
Contact history, such as any communications with us by telephone, e-mail, post, through our Site or via social media;
Transaction history, including information about any previous Products you have ordered, or Services which you have accessed or subscribed to;
Website profile and account data, including usernames, passwords or other details used to access an account or subscription which you hold with us;
Social media account details, including (but not limited to) linking your account to any website, Twitter, Facebook, LinkedIn, Instagram, Spotify, Amazon Music or Apple Podcasts, or other similar pages or accounts you may hold;
Marketing preferences;
Information about your visit to our Site, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information, the type of content which you access (paid for content, or free to access), which podcasts you listened to or downloaded, and which third party links you accessed; and
Technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, session replay data and other technology on the devices you use to access our Site.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data under data protection law, as this data does not directly or indirectly reveal your identity. For example, we may aggregate data about your use of our Site to calculate the percentage of users accessing a specific feature on our Site. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We may collect or process Special categories of Personal Data (as defined in the Glossary) about you in certain situations, for example where you write a letter to us which may be published on our Site. Where we process such data, we will always usually rely on a legal basis for processing other than obtaining your consent or explicit consent if possible. However, we may rely on your explicit consent where required, and in the absence of any other legal basis, will always obtain such consent in advance.

We will generally use your personal data to:

Help us identify you when you contact us, or access our Site, your account or subscription;
Provide you with the Products and/or Services that you request from us;
Provide you with information regarding our third party partners (such as Audioboom, Spotify, Shopify, Amazon Music and Apple Podcasts);
Provide you with access to the relevant content applicable to the Products you have ordered, or the Services you are accessing or subscribing to;
Personalise your experience on our Site, and in providing our Products and/or Services, and to provide you with information which is relevant to you;
Provide publications and content from our partners, where you have either requested to receive such content, or clicked on a third party link to access such content;
Develop and provide new products, services, publications and other content to you;
Allow you to participate in any interactive features on our Site, such as blogs and comment sections;
Contact you by post, e-mail, telephone and via social media regarding the Products, Services, and/or information that you have requested from us;
Process any financial transactions (including collection of payments, management of any additional charges and fees and administration of any refunds);
Create and administer your account on our Site;
Generally administer and keep a record of our relationship with you;
Respond to any enquiries that you submit to us;
Send you information by post or e-mail about new services, offers, updates and news (see the “Marketing” section below for further details);
Comply with our legal and regulatory obligations;
Prevent and detect fraud;
Provide customer service and support (including investigating complaints);
Train our staff and carry out quality control;
Review and improve our Products and/or Services;
Use data analytics to improve our Site, marketing, customer relationships, user experience and our organisation in general; and
Administer and protect our Site and our organisation (including troubleshooting, data analysis, testing and system maintenance and network security).

Lawful basis for using your information

In some cases, we will only use your personal information where we have your consent or because we need to use it in order to fulfil a contract with you (for example, because you have ordered Services from us and we need to provide them).

Generally, we do not rely on consent as the lawful basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you and may get your consent where we are collecting and processing Special categories of Personal Data. You have the right to withdraw consent at any time by contacting us, or by checking or unchecking relevant boxes on our Site, or in our communications to you, to adjust your marketing preferences.

Where you opt out of receiving marketing messages from us, this will not apply to personal data provided to us as a result of a purchase by you of our Products and/or Services, any experience you have had with our Products and/or Services, or any other transactions you have undertaken with us.

However, there are other lawful reasons that allow us to process your personal information, including where we have a “legitimate interest”. This means that the reason that we are processing information is because there is a legitimate interest for TNE to process your information.

Whenever we process your personal data on the basis of a “legitimate interest”, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is a disproportionate privacy impact on you.

Marketing

If you are a consumer, we will only contact you by e-mail for marketing purposes if you have given us your opt-in consent to do so. This may include information about products and/or services offered by us that are similar to those that we have already provided to you. You can manage your preferences at any time by contacting us using the details set out above.

Please note that we will continue contacting you about information that is connected to any contract that you have with us, including the provision of any Products, or the performance of the Services, or other content or items you may have requested from us.

If you are not a consumer and you have requested information from us or if you have ordered a Product, or signed up to our Services, we may also use your contact details to send you marketing communications unless you have opted-out of receiving that marketing.

We will not share your information for marketing purposes with any company or other entity outside of TNE, unless we have your opt-in consent to do so.

You can ask us or third parties to stop sending you marketing messages by contacting us at any time or clicking the “unsubscribe” button in the relevant e-mail.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 5 above.

Any suppliers, sub-contractors and/or agents we work with to provide you with the Products you have ordered, and/or Services that you have subscribed to or otherwise purchased from us.
Any designers who are involved in the creation or design of any of our publications, or our Site.

Service and infrastructure providers who provide IT, security, software, marketing, advertising and system administration services.
Any organisations who from time to time provide hosting services for our Site.
Professional advisers acting as processors or joint controllers including lawyers, bankers, experts, accountants, insurers and other third parties who provide legal, banking, consultancy, accounting, insurance and other related services.
HM Revenue & Customs, law enforcement agencies, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses, carry out a restructure or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
Any other entities in TNE’s group that may subsist from time to time.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We may provide third-party advertising companies with Aggregated Data so that you may receive tailored advertisements based on your visits to our Site. However, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not and will not sell your personal data to any third party.

International transfers

Some of our external third party service providers or partners may be based outside the United Kingdom, in which case, their processing of your personal data may involve a transfer outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection as it has in the UK.

Alternatively, we may transfer your personal data outside the UK where data protection law allows or requires us to do so.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data outside the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Our Site includes third party advertising and links to other websites. We do not provide any personal data to these advertisers or websites.

We cannot accept responsibility for any unauthorised access or loss of personal data that is beyond our reasonable control and we exclude all liability for loss that you may incur when using third party websites.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available on request by contacting us using the details above.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data (as set out further below).

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

“Special categories of Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and personal data relating to criminal offences and convictions.

LAWFUL BASIS

“Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service, the best products, content and publications, and provision of the same and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the privacy impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products and/or services to you, or otherwise service our relationship with you, including any orders and/or subscriptions you have with us. We will advise you if this is the case at the time you withdraw your consent.