Last updated: 13th January 2023
This privacy policy for Saga Publishing Limited (trading as Saga Exceptional) (‘Saga Exceptional’, ‘we’, ‘us’ or ‘our’) describes how and why we might collect, store, use, and/or share (‘process’) your information when you use our services, such as when you:
Introduction
This privacy policy gives you information about how Saga Exceptional collects and processes your personal data. It is important you read this document together with any other privacy or fair processing policies we give you on specific occasions where we collect or process your personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Saga Exceptional are committed to protecting your privacy. We comply with the principles of the UK General Data Protection Regulation (GDPR) and associated data protection legislation. We aim to maintain best-practice standards in our processing of personal, sensitive data and/or special category personal data.
The data we collect about you
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We do not sell, trade, or rent your personal information to others.
Lawful basis for using your information
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To make suggestions and recommendations to you about goods or services that may be of interest to you.
To personalise information sent to you. Both may involve the profiling of data. |
(a) Contact
(b) Technical (c) Usage (d) Profile (e) Marketing and Communications |
(a) Consent
(b) Necessary for our legitimate interests (to develop our products/services and grow our business) |
| For statistical purposes. | (a) Contact
(b) Profile |
(a) Necessary for our legitimate interests (to provide you with good customer services) |
| To manage our relationship with you which will include:
(a) Helping you if you contact our Customer Services |
(a) Contact
(b) Marketing and Communications |
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, statistical reporting and hosting of data) | (a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences, including customer value and retention
|
(a) Technical
(b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Sharing your information
As previously mentioned, we do not sell, trade or rent your information, and will never disclose information about you (including information obtained from our dealings with you) to third parties, except:
We use delivery email services to send our marketing, including Adobe, Thunderhead, Sitecore and Numero. For emails delivered by Adobe we use ‘tracking pixels’ which are similar to cookies to improve our emails. If you are unhappy with this but would still like to receive our emails you can block the pixels by switching off images in your email settings. You can unsubscribe from our marketing emails at any time using the link contained within emails you receive from us.
Keeping you informed about our products and services
When you contact us, we may ask for your permission to contact you about latest news, events and offers from The Saga Group and carefully chosen partners. Where we have obtained your permission, we may contact you by email to tell you about offers, products and services, plus expert product reviews, best buys and more that may be of interest to you.
You may contact us at any time to advise us that you do not want to receive such communications from us. You can update these preferences by clicking on the unsubscribe link in emails you receive or by calling us on 0800 092 3665.
We may process your information to send you communications that are tailored to your interests or to market products which we feel are like those you have shown an interest in previously. This is called “profiling for marketing purposes”. This might be in the form of display advertising you see on websites, social media (for example, using Facebook Custom Audiences and Google Custom Match), television or internet search results. We may also use profiling to tailor communications we send to you via post, telephone, email or text. If we run specific marketing campaigns through social media and digital advertising platforms you may see Saga advertising. These campaigns tend to be based on general demographics and interests and sometimes your contact details such as an email address or phone number. We would use this information to tailor the advertising you see. If you do not wish to see this advertising, you will need to adjust your preferences within the relevant social media settings and your cookie browser settings (please see our Cookie Policy for more information regarding how to do this).
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.
Amendment and retention of information
Please advise us in writing of any changes in your circumstances, or if you feel we hold inaccurate information about you so that we can update our records accordingly.
We will hold your personal information in accordance with the principles of the GDPR (and associated legislation) and for as long as reasonably necessary to fulfil the purposes for which it was collected. We may obtain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. We are obliged and permitted by law and regulation to retain certain types of data for a minimum period. The minimum period tends to be for six years but can be longer if the statute or regulation requires.
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.
Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Access to your information: You have a statutory right of access to personal data that we hold about you. In order to exercise this right, we ask that you apply in writing, either via letter or email. Please refer to the information you wish to see giving dates where possible. Please note that we may ask for further information from you including proof of identity.
We will not administer Subject Access requests made by a third party (such as a relative or friend) unless accompanied by written authority of the individual who is the subject of the request.
You will not have to pay a fee to access your personal information (or to exercise any other rights). However, in exceptional circumstances, we may charge a reasonable fee or refuse to comply with your request.
Request the correction or rectification 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.
Rights related to automated decision-making including profiling: We use the information we know about you to make decisions which inform the products and services we can offer. Automated decision making enables us to make efficient and fair decisions, providing a better service for our customers. Whilst you have the right to object to us using your information in this way, this could have an impact on the products or services we may be able to offer you. We use automated decision making in the following areas:
Tailoring our marketing communications – as mentioned previously, we use your personal information to make decisions about what products, services and offers we think you may be interested in. This ensures the communications you receive from us are tailored and relevant to your interests. You can opt out of this at any time by contacting the Data Protection Officer.
The right to erasure: 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.
The right to 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.
Right to restrict the processing of your personal data: this enables you to ask us to suspend the processing of your personal data in the following scenarios:
The right to data portability: you have the right to obtain and reuse the personal data that you have provided to us for your own purposes which includes transferring it to other service providers. 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.
The right to 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 or services to you. We will advise you if this is the case at the time you withdraw your consent.
What we may need from you: we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
We will try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case we will notify you and keep you updated.
Limits to your rights: some of your rights in relation to your personal data are not absolute, for example your right to erasure. Where this is the case, we will inform you of the extent we can comply with your requests and detail our reasons why. More information can be found by visiting the ICO’s website https://ico.org.uk/.
For further information regarding your rights, or to make a request; please write to the Data Protection Officer at HKX 3 Pancras Square, London, N1C 4AG or email data.protection@saga.co.uk.
Updates to our privacy policy and your comments
We keep our privacy policy under regular review, and we publish the date this privacy policy was last updated. If we decide to change our privacy policy, we will update all relevant documentation and post any changes on our websites so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.
We welcome your questions and comments about privacy. Please write to The Data Protection Officer, HKX 3 Pancras Square, London, N1C 4AG or email data.protection@saga.co.uk
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you feel your personal information has not been handled correctly. You can do this via ico.org.uk/concerns or by writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Third-party links
This website 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. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Glossary
| Processing | Anything that is done with personal data. Collecting, keeping, and using personal data are all examples of processing. | |||||
| Profiling | The processing of personal data in order to try and work out the subject’s situation, characteristics, and/or behaviour. | |||||
| Data controller | An entity (for example a person or an organisation), who determines for what purpose and how personal data is going to be processed. | |||||
| Third party | An entity who is not the data subject, a processor, or a controller. The third party may receive personal data but does not process it. | |||||
| Lawful basis – Legitimate Interest
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means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 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.
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| Lawful basis – Performance of Contract
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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.
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| Lawful basis – Comply with a legal obligation
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means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
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| Lawful basis – Vital Interests | means processing personal data where it is necessary to protect the vital interests of the data subject or another individual | |||||