This Data Protection Notice contains the information You need in order to understand how Your personal data is used by us. For further information please contact us with the contact details provided below in section 11 or view our website at https://foxhole.news/privacy-policy/
In this Data Protection Notice:
- ‘Foxhole’ means The Foxhole, a news and media organisation, reporting and commenting on real-time, past and future events.
- It is the trading name of Summit Media Management Limited a company registered in England. Registration number: 12904847. Registered office address: Henleaze Business Centre, 13 Harbury Road, Henleaze, Bristol, BS9 4PN. Summit Media Management Limited (Summit Media) is the management services company acting for The Foxhole for their outsourced management service needs. Registered with the ICO under ZA828841.
- You/Your refers to the person seeking to be involved in the New site, whether that is via completing any forms, pop-ups, registering your details on our website, donating to the news site, commenting on our website, purchasing merchandise from our news site, advertising on our news site or becoming involved in any other way with the New site.
In order to manage the site, The Foxhole and or Summit Media (collectively We, Our or Us) collect a certain amount of personal data. “Personal data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information.
This Data Protection Notice sets the basis on which we gather, use, disclose and process any personal data we collect from You, or that You provide to us. We will use Your personal data only for the purposes and in the manner set forth below which describes the steps we take to ensure our processing of Your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) (the GDPR) and any implementing legislation.
Please read the following carefully to understand our use of Your personal data.
Your Right to Object – Please note that You have a right to object to the processing of Your personal data where that processing is carried out for our legitimate interests.
1. What personal data we may collect about You?
If you sign up to receive news updates from us, or purchase merchandise from us, or complete any forms or pop-ups in relation to detailed questionnaires, we need to collect and process personal data about you. The types of personal data that are processed may include: Category Types of Data Collected Individual details namely, title, name, address, telephone number, email address and marketing preferences, IP address, bank account details or payment card details, transactional information from our website.
2. The purposes of, and legal basis for, the processing of Your personal data
We hold, disclose and process Your personal data in order to sell merchandise, analyse questionnaires and contact you with newsletters in regards to information we believe is relevant to you as provided by your marketing preferences. Providing you with this information involves using the following personal data:
- Information that you provide by filling in forms and pop-ups on our site: https://foxhole.news/ (our site). This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for news research purposes, although you do not have to respond to them.
- Details of transactions you carry out through our site and of the fulfilment of your orders.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access on our site.
- We may also use Your personal data where: a) it is necessary to comply with our legal and regulatory obligations (for example, complying with reporting obligations to the Information Commissioner’s Office); b) it is necessary to support our legitimate interests in (i) managing and or administering the news site (ii) improving our services (iii) prevention and detection of crime, (iv) analytics, provided in each such instance they are not overridden by Your interests and rights; and/or c) You have consented to processing Your information in such a way.
3. Who We share Your information with
In order to provide our services and to comply with legal obligations imposed on us, it may be necessary from time to time for us to disclose Your personal data to third parties, including without limitation to the following:
- With our agents and third parties who provide services to us to help us administer our website, processing of merchandise and other services
- With regulatory bodies and law enforcement bodies (where we are required to do so to comply with a relevant legal and regulatory obligation).
- Legal, financial, political and other professional advisors.
- With third-party advertising companies to serve ads when You visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you. Most browsers are set to accept cookies by default. You can remove or reject cookies by modifying your browser settings. See our cookies’ list below.
The below list details the cookies used on our website.
|_ga||2 years||This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assigns a randomly generated number to identify unique visitors. This cookie is only used if the user has given their consent to non-necessary cookies.|
|comment_author_[hash]||347 days||WordPress sets cookies on the devices of those who comment on the website. These cookies are used to remember the users so that the values are automatically filled in the corresponding fields. The user doesn’t have to enter their details every time they want to leave a comment. These cookies are only activated if the visitors check the checkbox on the comment form to save these details. The cookie comment_author_[hash] cookie remembers the value entered into the comment form’s name field.|
|comment_author_email_[hash]||347 days||WordPress sets cookies on the devices of those who comment on the website. These cookies are used to remember the users so that the values are automatically filled in the corresponding fields. The user doesn’t have to enter their details every time they want to leave a comment. These cookies are only activated if the visitors check the checkbox on the comment form to save these details. The cookie comment_author_email_[hash] remembers the value entered into the comment form’s email field.|
|comment_author_url_[hash]||347 days||WordPress sets cookies on the devices of those who comment on the website. These cookies are used to remember the users so that the values are automatically filled in the corresponding fields. The user doesn’t have to enter their details every time they want to leave a comment. These cookies are only activated if the visitors check the checkbox on the comment form to save these details. The cookie comment_author_url_[hash] remembers the value entered into the comment form’s URL field.|
|cookielawinfo-checkbox-necessary||11 months||This cookie is set by GDPR Cookie Consent plugin. The purpose of this cookie is to check whether or not the user has given the consent to the usage of cookies under the category 'Necessary'.|
|cookielawinfo-checkbox-non-necessary||11 months||This cookie is set by GDPR Cookie Consent plugin. The purpose of this cookie is to check whether or not the user has given the consent to the usage of cookies under the category 'Non Necessary'.|
|CookieLawInfoConsent||1 year||The cookie is set by the GDPR Cookie Consent plugin and is used to record the default button state of the corresponding category & the status of CCPA. It works only in coordination with the primary cookie viewed_cookie_policy.|
|trx_addons_is_retina||1 year||The cookie is set by the ThemeRex Addons plugin and is used to record whether or not the site should display 'retina' (higher resolution) images to the visitor or not. This is a site performance cookie.|
|wordpress_test_cookie||session||WordPress sets a cookie named wordpress_test_cookie to check if the cookies are enabled on the browser to provide appropriate user experience to the users.|
4. Online postings
When you post contributions to the Site, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.
5. Transfer of personal data outside the EEA
The personal data we collect from You may be transferred to and stored at a destination outside of the United Kingdom and the European Economic Area (EEA) for purposes described above. These countries may not provide an adequate level of protection in relation to the processing of Your personal data
However, in the case of Switzerland and the United States, the EU/Swiss-U.S. Privacy Shield acts as a safeguard for the protection, privacy and integrity of personal data.
The EU/Swiss-U.S. Privacy Shield is an agreement between the EU and the Governments of Switzerland and the US concerning the treatment of data concerning EU citizens. Some of the relevant third parties are certified under the EU/Swiss-U.S. Privacy Shield.
6. How Long we keep Your personal data
We are required to ensure that Your personal data is accurate and maintained in a secure environment for a period of time no longer than necessary for the purposes for which we are processing Your personal data. Information submitted for an initial discussion where you did not proceed with a claim or utilise our legal services may be retained by us for a period of up to 6 years from the date of the initial discussion.
7. Your data rights
You have several rights in relation to Your personal data. You have a right to:
- Access a copy of Your personal data held by us.
- Request rectification of Your personal data if it is inaccurate or incomplete.
- Request erasure of Your personal data in certain circumstances.
- Restrict our use of Your personal data in certain circumstances.
- Move (or port) personal data which You have given us to process on the basis of Your consent or for automated processing.
- Object to the processing of Your data where our legal basis for processing Your data is for our legitimate interests.
- And not to be subject to a decision based on automated processing, including profiling which has legal or similar significant affects.
However, these rights may not be exercised in certain circumstances, such as when the processing of Your data is necessary to comply with a legal obligation or for the exercise or defence of legal claims. If You wish to exercise any of Your rights in this regard please contact us using the details in Section 11. We will respond to Your request in writing, or orally if requested, as soon as practicable and in any event not more than one month after receipt of Your request. In exceptional cases, we may extend this period by two months, and if we do this, we will tell you why. We may request proof of identification to verify Your request.
You can select one of the of following two options in order to cease receiving emails from us:
- Update your preferences by clicking the “Unsubscribe” link in the footer in any of our emails;
- Contact us – see 11 section for contact details
9. Automated decision-making
You have a right not to be subjected to decisions based solely on automated processing, including profiling, which produce legal effects concerning You or similarly significantly affects You. However in certain circumstances we are entitled to make decisions based on solely automated decision-making and profiling. These cases are restricted to situations where the decision is necessary for the management of the site, where it is authorised by law or where You have provided Your explicit consent. Where we base a decision on solely automated decision-making You will always be entitled to have a person review the decision so that You can contest it and put Your point of view and circumstances forward.
10. Consequences of failure to provide information
If we or any of the parties detailed above cannot collect information requested from You, it may make it difficult, impossible, or unlawful for us to manage your involvement in the news site or to provide the product or services that you requested on our Website. If we or any of the parties listed above ask for information and You do not wish to give it to us, or if You wish to withdraw consent to the use of Your personal data, we will explain the consequences based on the specific information concerned including whether it is a legal or contractual requirement that we use such data. If You have any queries in respect of the consequences of not providing information or withdrawing Your consent, please contact us using the details in Section 11.
11. Further information
If You require any further information about how we use Your data or if You want to exercise any of Your rights under this Data Protection Notice, please contact us on the details below:
12. Your right to complain to the ICO
If You are not satisfied with our use of Your personal data or our response to any request by You to exercise any of Your rights in Section 7, You have the right to lodge a complaint with the Information Commissioner’s Office.
Please see below contact details:
England Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Phone: 0303 123 1113 (local rate) or 01625 545 745 (national rate) Email: firstname.lastname@example.org
Scotland Information Commissioner’s Office 45 Melville Street Edinburgh EH3 7HL Phone: 0303 123 1115 Email: email@example.com
Wales Information Commissioner’s Office 2 nd Floor Churchill House Churchill way Cardiff CF10 2HH Phone: 029 2067 8400 Email: firstname.lastname@example.org
Northern Ireland Information Commissioner’s Office 3 rd Floor 14 Cromac Place Belfast BT7 2JB Phone: 0303 123 1114 (local rate) or 028 9027 8757 (national rate) Email: email@example.com