This page governs the manner and outlines our policy by which CW Publishing Ltd collects, uses, maintains and discloses information collected from users (each, a “User”) of the www.cwpg.com website (“Site”). This applies to the Site, manual subscriptions and all products and services offered by CW Publishing Ltd.
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site and in connection with other activities, services, features or resources we make available on our Site.
Users may, however, visit our Site anonymously.
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
We will collect personal identification information from Users only if they voluntarily submit such information to us, fully aware of what our intention is and how we intend to use it in line with GDPR. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities and subscription offers and promotions.
CW Publishing Ltd uses incentives to collect and process Users personal information legally based on consent and legitimate interest for subscriptions to our publications for the following purposes:
- To improve our Site
We continually strive to improve our website offerings based on the information and feedback we receive from you.
- To send periodic emails
It may also be used to respond to their inquiries, and/or other requests or questions. We also reserve the right for Users to receive emails that may include company news, updates, related products and new subscriptions they may be interested in or third party service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
We may from time to time supply an individuals information to third parties when they have actively opted to receive information by specifically giving us permission to share with them once we have made them aware of who they will be according to the company name by which they identified themselves on the agreement with us . The main purpose for this is to allow the specifically stated third parties to provide you with information about goods and services which said third party deem to be of interest to you. Such information may be provided by marketing communications or advertising which is tailored to your interests. Your data may also be used in the way described below. Be assured that any third parties will only be allowed to use your data in accordance with GDPR and the Data Protection Act 2018 and other applicable law relating to privacy, a list of third parties who may contact you is again available upon request.
Those third parties (specifically available upon request) who would wish to send you marketing communications will fall into the following categories, as they are relevant to the market CWP operate within:
|Sector||Description and examples|
|Retail||· Online retail
· General stores
· Automotive (including dealerships and accessories)
· Home furnishings
· Home improvement
· Fashion and clothing(adults/kids)
· Baby/Toddler care
· Telecoms and utilities
· Loans, credit cards and mortgages
· Investments & savings
· Other insurances
· Travel booking
· Health & Well-being
· Beauty & Grooming products
· Media & publishing companies
· Legal Services
· Educational institutions
For third party processors
In the interest of DPA 2018, we adopt appropriate data collection (subscription data is collected via manual paper forms), storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information, username, password, transaction information and data stored on our Site. Any data shared is the sole property of CWP and the processor will be granted for a limited period only.
For data sharing purposes CWP remains the data controller for information disclosed to third parties (data processors) stipulated by the name on our agreement unless specified otherwise, throughout the term of the agreement within which time we would recommend you contact the audience no more than once a quarter and upon expiry of the 6 month data license all processors must ensure to securely delete the shared data from their network save for data subjects they can prove have actively opted to receive additional / continued communication from them, in writing or positive reaction. If you are granted joint controller status our policy will govern all matters relating to subject access requests, with CWP solely communicating with the subject regarding the collection of their information. If your agreement is renewed we will reissue you with a new license allowing you continued use of our data disclosed to you for another term. Processors of our data must adhere to CWP terms and conditions from the moment our agreement is confirmed/data is downloaded and these will supercede all other personal practices internal or otherwise.
CWP warrants and undertakes that it will ensure that the Shared Personal Data are accurate, in line with GDPR processing regulations and DPA 2018.
The data will be for marketing communications relevant to the publication within which you have contributed and the fields included again will be applicable to the publication but in most cases include name, email address and Title. As controllers we may retain fields for our own purpose and will not disclose to processors. Once data is received processors of the information immediately are bound to CWP’s data sharing policy and collection processes, by downloading the data you are committing to having the ability to use the data and ensure that it will be kept in storage on a managed IT network with the required security level and protocols.
As controllers we regularly conduct audits, which includes where applicable suppression of files against MPS and TPS, cleansing of any de-dupes and removal or redundant entries prior to disclosure. At times records may become redundant without our knowledge and if you believe this to be the case please inform CWP immediately of those exact records and we will look into the matter, replacing only when CWP agrees a record has become redundant. Data processors do not need to inform us of unsubscribes from their own communications, as this does not constitute unsubscribing from the publication. If a subject unsubscribes from your own communications you must delete their record from your network immediately.
The Data Recipient warrants and undertakes that it will not disclose or transfer Shared Personal Data to any third parties outside its organisation either within or outside the European Economic Area (EEA).
The Data Recipient warrants it will process the Shared Personal Data in compliance with all applicable laws, enactments, regulations, orders, standards and other similar instruments that apply to its personal data processing operations.
The Data Recipient warrants it will process data breaches, complaints and access requests in line with GDPR requirements and that it will inform CWP within 1 business day (that being a Monday – Friday) submitting all data subject(s) information so that CWPG can reach an amicable resolution directly with an aforementioned subject(s) if so required.
CWP upon receipt of a request or complaint from a data subject, processor or the ICO will contact the data subject direct and confirm the nature of the issue, when and where consent was received and determine an amicable resolution, communicating the conclusion to all relevant parties. Data processors will have no involvement here.
CWP as data controller will inform all relevant parties of any changes to the dataset it has shared. The data recipient does not need to inform CWP of changes to its own dataset.
Sensitive and private data exchange between the Site and its Users happens over a TSL secured communication channel and is encrypted and protected with digital signatures, our information security framework is managed by our ISO27001 accredited partner.
Users may find content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
By using this Site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
If you have any questions about this policy, the practices of this site, or your dealings with this site, please contact us
If you have registered on our site and wish to access the data we hold about you and / or have it deleted please email your request to email@example.com
Last Edited September 2018