At Nimble Publishing Ltd, we understand that we have a responsibility to protect and respect your privacy and look after your personal data.
For clarity, Nimble Publishing Ltd may be both data controller and data processor for your personal data under certain circumstances.
We must advise that this policy is subject to change, so please check our website on a regular basis for any further changes.
Data Protection law will change on 25 May 2018
Nimble Publishing Ltd (“Nimble”, “HeavyTorque”, “we”, “us” and “our”) is a private company limited by guarantee registered in England and Wales (Registration no. 10963902), whose registered office is at Pinnacle House Business Centre, Newark Road, Peterborough, PE1 5YD. Andy Adams is the dedicated Data Protection Officer (“DPO”) for Nimble Publishing Ltd.
We are a “data controller” for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”). We are committed to protecting your privacy and processing your personal data fairly and lawfully in compliance with the GDPR.
- Publications: HeavyTorque (“HT”); Heavy Transport Association Yearbook (“HTA Yearbook”) and/or any other publication where the advertising sales and/or production are administrated by Nimble Publishing Ltd;
- Events: The Heavies; HeavyTorque LIVE! (“HT LIVE!”); and/or any other event where the sales, organisation and/or production are administrated by Nimble Publishing Ltd. And/or;
- Any other service or project that may be of interest to you as deemed by Nimble Publishing Ltd.
Third Party Links
Our websites may include links to third-party websites, plug-ins and applications. 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 and are not responsible for their privacy statements.
2. FAIR AND LAWFUL PROCESSING
We will process your Personal Data only, where:
- you have given your consent to such processing (which you may withdraw at any time, as detailed at section 14 and 15 below);
- the processing is necessary to provide our services;
- the processing is necessary for compliance with our legal obligations; and/or
- the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal data (as detailed below).
By “processing”, we mean the collection, recording, storage, use, disclosure and any other form of operations or dealings with your Personal Data.
3. WHAT PERSONAL DATA WE COLLECT ABOUT YOU?
3.1 We may collect, store, and use the following categories of personal data about you:
- your name, work email address and telephone numbers;
- your role, position and/or job title within your employment;
- your preferences in receiving marketing from us and our partners and your communication preferences;
- your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback;
3.2 In certain circumstances it will be necessary for you to provide us with your Personal Data, to enable us to manage our operations, to provide services to you and/or your employer or to comply with our statutory obligations. In other circumstances, it will be at your discretion whether you provide us with Personal Data or not. However, failure to supply any of the Personal Data we request may mean that we are unable to maintain or provide services or products to you and/or your employer.
3.3 We make every effort to maintain the accuracy and completeness of your Personal Data which we store and to ensure all of your Personal Data is up to date. However, you can assist us with this considerably by contacting us promptly if there are any changes to your Personal Data or if you become aware that we have inaccurate Personal Data relating to you (see section 10 below). We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.
4. HOW WE COLLECT PERSONAL DATA
We usually collect your Personal Data from the information you submit during the course of your relationship with us. This will typically be through you sending us emails and other correspondence, business cards, the forms and documents used when you sign up to our marketing or market data news lists, when you are named as an authorised person to trade on behalf of your employer, the sign up information you use to access any of our products or services either on your own behalf or on behalf of your employer. To simplify, personal data is also collected via:
- when you visit any of our websites;
- when you create an account with us to access online content;
- when you subscribe to our publication;
- when you use your account to buy subscriptions or services;
- when you attend one of our events, The Heavies or HeavyTorque LIVE!;
- when you use our website in response to a contact form;
- when you engage with us on our social media pages;
- when you provide us with your preferences to receiving marketing from us, or from one of our partners;
- you send us an email, or when you contact us through our Contact Us pages;
- when you choose to complete a postal survey, or complete a survey on our websites.
5. HOW AND WHY DO WE USE YOUR PERSONAL DATA
It is our responsibility to make sure you receive the best news content available within the heavy and specialist transport industry. In doing so, we sometimes need to use your personal data in a number of ways, depending on your interactions with us and the services you have requested. We will not process your personal data unless we have a legal basis to do so under data protection law. Below we detail what we do with your personal data, why we do it, and the legal basis on which we rely.
To provide you with our content and services, such as:
- process and fulfil a request or subscription to our e-newsletter or magazine;
- process and fulfil a request for an advert to be posted in one of our publications;
- to deliver your subscription to you by post or email;
- provide, activate and manage your access to our premium online content;
- to notify you of any changes or updates to your account or subscription;
- to process and fulfil a request for individual seats, or tables at our events;
- to process payments for subscriptions, adverts, award entries and other products or services;
- to provide customer service and support and to answer any enquiries or concerns;
- when you ask us to share your contact details and enquiry with a third party in response to an advert posted in one of our publications;
- to update your records and contact details, to contact you about your accounts or subscriptions, or to recover debts;
- to run a survey, competition or promotion.
Where it is in our legitimate business interests, such as:
- to manage your request or subscription for an e-newsletter, magazine, or other publication;
- to develop and improve our content, and our services;
- to send subscription renewal emails and letters to past subscribers, however, this will not be sent if you opt out of receiving these type of communication;
- for direct marketing communications, helping users and subscribers stay informed about our services and events. For instance, you sign up to HeavyTorque and we will keep you up to date about services and events provided by us and our selected partners in the heavy and specialist transport sector;
- to populate and maintain a database of direct marketing preferences. Effectively tailoring communication which may be of interest to you, and negating the need for communication you have opted out of receiving;
- to respond to requests, enquiries, comments or concerns;
- to protect our business and your account from fraud and other illegal activities;
- to carry out monitoring and to keep records of our communications with you;
- for research, analysis and industry statistics;
- subject to appropriate controls or anonymisation, to provide insight of our readers to business partners and our advertisers. For instance, providing our advertisers with statistics on the industry in which our readers work;
- to update your records and contact details, to contact you about your accounts or subscriptions, or to recover debts;
- to use data analytics and website cookies to improve our websites, products, services, marketing, customer relationships and experiences;
- to deliver relevant website content and advertisements, and measure or understand the effectiveness of the advertising;
- for management and audit of our business operations.
With your consent or explicit consent, such as:
- for direct marketing. Where you may request communication about our industry events;
- where you provide your consent for one of our industry partners, or advertisers to contact you about their services, events or industry content;
- to administer a competition, or an award category which you enter, we may rely on your consent given at the time of entering.
To comply with our legal obligations, such as:
- to process any orders you make whilst using our websites, email, over the telephone or by post;
6. SENSITIVE PERSONAL DATA
We will never ask you to provide sensitive personal data (known as special category personal data in the GDPR) about yourself such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
Information you make available in job applications or other communications via our websites is your responsibility, and you should think very carefully before including or sharing any sensitive personal data.
7. SHARING YOUR DATA
We sometimes share your personal data with trusted third parties or third-party service providers. We have data processor contracts in place with our third parties, which requires them to respect the security of your data, and to treat it in accordance with data protection legislation. Examples of the kind of third parties we work with include:
- external payment service providers to process any payments you send us;
- website platform and software providers to assist us with our internet content and services;
- operational companies such as delivery couriers, fulfilment agencies and the Royal Mail;
- IT companies, and developers who support our website;
- accountancy companies who administer our accounts.
We may also share your personal data with third parties where required by law or where we have another legitimate interest in doing so.
Our industry partners
In some instances we may provide your contact details to other companies in our industry for their own purposes. However, we will only ever provide your details in these circumstances where we have your informed consent.
Subject to appropriate controls or anonymisation, we may also provide limited data to our advertisers to provide them with insight of our readers.
We may wish to expand, reduce or sell our publication and this may involve the transfer of the business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, subject to data protection law.
8. INTERNATIONAL TRANSFERS OF PERSONAL DATA
The Personal Data we collect from you may be transferred to (including being accessed in or stored in) a country or territory outside the European Economic Area (“EEA”), including to countries whose laws may not offer levels of protection of Personal Data the same as are those enjoyed within the EEA. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the GDPR.
Examples situations where we may transfer your personal data outside the EEA:
- should you be based outside the UK and place an order with us,
- we may need to provide your contact details to a courier outside the EEA;
- you ask us to send an enquiry to an advertiser on our websites or in our magazine.
9. WHAT IF YOU DON’T WANT TO SHARE YOUR PERSONAL DATA WITH US?
If you fail to provide certain information when requested, we may not be able to provide you with our content, products or services.
10. WHAT SHOULD YOU DO IF YOUR PERSONAL DATA CHANGES?
11. HOW WE PROTECT YOUR PERSONAL DATA
We are committed to safeguarding and protecting Personal Data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any Personal Data provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted, stored or otherwise processed.
12. YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE COLLECT
12.1 If you wish to:
- update, modify, delete or obtain a copy of the Personal Data that we hold on you;
- restrict or stop us from using any of the Personal Data which we hold on you, including by withdrawing any consent you have previously given to the processing of such data; or
- where any Personal Data has been processed on the basis of your consent or as necessary to perform a contract to which you are a party, request a copy of such Personal Data in a suitable format.
you can request this by emailing us at the address set out in section 12 below. We endeavour to respond to such requests within 30 days or less, although we reserve the right to extend this period for complex requests.
12.2 In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.
12.3 We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your Personal Data, and for any additional copies of the Personal Data you request from us.
13. FOR HOW LONG WE WILL HOLD YOUR PERSONAL DATA
We will retain your Personal Data only for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
In some cases we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice. For instance, we may collect demographic information from our readers, anonymise it and provide it to our advertisers.
14. YOUR RIGHT TO WITHDRAW CONSENT
In the limited circumstances where we rely on your consent to process your personal data, you have the right to withdraw your consent for that specific processing at any moment in time.
To withdraw your consent, please contact the DPO by emailing email@example.com
15. YOUR RIGHT TO OPT OUT OF DIRECT MARKETING
There are several ways you can stop our direct marketing communication:
- opt out of receiving promotional emails and marketing when you create your account or subscribe to any of our content;
- if you have an account, log in and change your preferences;
- click the ‘unsubscribe’ link in any email communication we send you. We will then stop sending correspondence relating to that magazine, e-newsletter, and/or event;
- contact our DPO, Andy Adams via email: firstname.lastname@example.org or write to Andy Adams, Nimble Publishing Ltd, Pinnacle House Business Centre, Newark Road, Peterborough, PE1 5YD.
Please note that you may continue to receive communication for a short period, or until our systems are update with your preferences.
17. HOW YOU CAN CONTACT US
Post: Nimble Publishing Ltd, Pinnacle House Business Centre, Newark Road, Peterborough, PE1 5YD
18. HOW TO LODGE A COMPLAINT TO THE REGULATOR
You have the right to make a complaint about how we process your personal data to the Information Commissioner:
Information Commissioner’s Office
Tel: 0303 123 1113