11 December 2020
Your privacy is incredibly important to us at Tortoise Media. Whilst we can’t promise that this policy will be a scintillating read, we’ve tried to make it as short and simple as we can, so that you know you can trust us to look after any personal data you choose to share with us. We’ve tried to strike the balance between collecting, using and storing the data we need to help you to get the best out of Tortoise’s journalism on- and offline, without compromising your privacy in any way.
It applies to our members, anyone who signs up to receive marketing communications from us, anyone who visits www.tortoisemedia.com (the “Site”) and indeed anyone who interacts with anything else that we make.
Here’s the official bit:
For the purposes of applicable data protection laws, including the EU General Data Protection Regulation and the Data Protection Act 2018 (the “Data Protection Laws“), the “controller” of personal information collected through the “Site” is Tortoise Media Limited, company number 11100473, registered office: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ.
Please read the following carefully if you’d like to understand how we will use your personal data. If you want to, please check back regularly – we will update our policy if we need to reflect any changes to our operations and services.
If you have any questions about all this privacy stuff, write to us at firstname.lastname@example.org.
1. Information we may collect about you
When you become a member
When you join, we need a bit of personal information about you to set up your membership and provide you with our products and services. For example, we may collect your:
- Email address
- Postal address (including postcode)
- Telephone number
- Date of Birth
- Payment details
We will use the personal information we collect about you to:
- create and maintain your account with us;
- perform obligations arising from your membership and any contracts entered into between you and us;
- send you basic info about your membership account, such as when you need to renew, password resets or order confirmations;
- notify you about any changes to our services or any updates to our policies;
- send you stories and/or event reminders via push notifications, newsletters and so on;
- deliver Tortoise products to you;
- process payments;
- detect and reduce fraud, including fraudulent orders; and
- comply with any legal obligations to which we are subject, and to protect and defend Our rights and interests.
When you become a registered user
If you register on the Site, but do not become a member, we will collect your email address and we will use this information to contact you about Tortoise’s products and services, and any content available to registered users.
When you sign up to receive our marketing communications
If you sign up to receive marketing communications from us, we will collect your name, email address and telephone number.
We will use this information to contact you about Tortoise products, services and events that we think you might like.
You can opt-out of receiving marketing communications at any time by contacting member services at email@example.com; or clicking the unsubscribe link at the bottom of our emails.
Please note that if you unsubscribe from marketing communications, we will still send you important service notifications (things that affect your ability to use the website, for example, if you are a member) or where we have some other legal basis for contacting you.
When you contact us
If you call, email, use our ‘live chat’ function or write to us about anything, we will collect any information that you choose to share and use it to review, investigate and respond to whatever it is you contacted us about.
2. Information we may collect automatically
When you visit the Site, use our app or engage with any of our digital services, we collect information from the things you look at. This is done through cookies and other types of technology.
The types of information we may collect are:
- browser type
- email provider
- pages you read on our websites and how you got to them
- the third party website from which you linked directly to the Site (if applicable)
- the device you use
- your IP address
- your location
We use this information both to provide and improve Tortoise’s products and services. We may also use data about your browsing behaviour (such as what you read) to personalise what you see on the Site or mobile app and to tailor any marketing communaications that we send to you.
As you know, we don’t carry advertising on Tortoise so you can rest assured that any information we collect will not result in you being stalked around the internet by a bunch of irritating adverts.
If you do not want us to personalise what you see and receive, write to us at firstname.lastname@example.org including the words ‘opt-out’ in the subject line.
3. Information we collect from third parties
We work closely with third party service providers including, for example, Kickstarter, Eventbrite,our corporate partners, and analytics providers. We may receive information about you from such third party service providers.
For example, if you sign up (via www.eventbrite.co.uk) to attend a ThinkIn we will receive your name and email address in order to contact you about the ThinkIn.
If you would like more information about information we may receive from third parties, please contact us using the details below.
4. Our legal basis for collecting your personal information
If you have given us your personal information in order for us to send you marketing communications vie email or SMS, then our legal basis for using your personal information is your consent.
Entering into and performing a contract with you
Our legitimate business interests
If you contact us or simply browse the Site, our legal basis for processing your personal information is that we have a legitimate interest in administering, monitoring and improving our Site and responding to your queries. This information helps us to run and improve Tortoise products and services, analyse member engagement with our content and make sure our products (including websites and apps) are compatible with browsers and operating systems.
5. Social media
Tortoise media publishes content on social media platforms e.g. Twitter, Facebook, LinkedIn through both “organic” and “paid” methods, to help us reach current and potential members.
- “Organic” is what we call it when we publish content and/or offers onto a social media platform so that they may appear ‘naturally’ in your feed on that platform, without being promoted or artificially ‘forced’ to appear more prominently.
- “Paid” is what we call it when we pay the social media platform owners to make sure that our content and/or offers appear prominently in your feed, or to make sure our content appears in the feeds on people who do not currently follow us on that platform. These types of placements are always marked as ‘promoted’ or ‘advertising’, so you know which is which.
We may place one or more social media platform “tags” on our Site so we can figure out which Tortoise Media content will be most useful, relevant and valuable to you based on what else you have looked at on our Site. These tags only record information that identifies whether or not you are already registered or already a member, so that we can use your reading preferences to show you relevant content and/or offers e.g. we will remove subscription offers from your feed if you are a current subscriber.
We do not have direct access to your personal information on your social media platforms.
6. Disclosure of your personal information
Under some circumstances, and only when we need to do so, we may share your personal information with selected third parties including:
- third party service providers that help us operate our business, our Site and app, or administer activities on our behalf. One such third party provider is Piano, the technology company we work with to build and serve your member experience.
- payment processors that collect payments on our behalf;
- marketing platforms that help us send you messages or push notifications, and give us feedback on message opens, clicks and how we can improve the formatting of our emails;
- analytic providers to carry out statistical analysis and surveys about our journalism;
- courier and postal service providers, so you can receive (for example) Tortoise Quarterly and your Welcome Pack.
Occasionally we may also disclose your personal information to third parties for the following reasons:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and other agreements; or to protect our rights, property, or safety, or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
7. Retaining and storing your information
How long we keep your personal information for depends on why we collected it, as well as what any applicable law or regulation requires.
For example, if you join as a member, we will store your personal information and details about your membership for as long as necessary to fulfil with any contract we have with you and to comply with applicable laws and tax legislation.
Whereas, if we haven’t heard from you – that is, you’ve not opened an email, looked at a story, been to an event or interacted with Tortoise Media in any other way – we will generally no longer hold your information after 5 years, unless there is a legal or regulatory reason why we have to.
If you ask us not to contact you anymore, we will make sure we remove you from any future communications but will keep a minimum amount of information about you in our records. This way, if you go on to use our products and services at a later date we will be able to tell that you’d previously asked us not to include you in marketing communications.
8. International transfers
The personal data that we collect from you may be transferred to third parties located in countries outside of the European Economic Area (“EEA” ) including the United States.
If you would like more information about how this happens, and the safeguards applied, please contact us using the details below.
9. Your rights
You may have certain rights in relation to the personal information we collect about you. These may include the right to ask for us to update or delete the information we hold about you, the right to request access to it or to see a copy of it in machine readable format. You may also have the right to object to or to ask us to restrict our processing of your personal information, or to withdraw your consent to how we process your personal information. If you would like to do any of this, please write to us.
You also have the right to complain about the use of your data to the Supervisory Authority, which in the UK is the Information Commissioner’s Office (www.ico.org.uk).
10. Individuals under 16
Tortoise Media does not intentionally, or knowingly, collect or otherwise process personal information relating to people under the age of 16. We will make every effort to delete any such personal information where a parent or guardian has let us know that we’ve collected such details.
11. External links
Tortoise Media is not responsible for the privacy policies or the content of any Third Party Service and we strongly recommend that you read the privacy policies on each Third Party Service that you choose to use or interact with.
12. Changes to this policy
If we make changes, we will let you know by revising the date at the top of this policy. If the changes are significant, we may give you with additional notice, such as adding a statement to the homepage of the Site or sending you an email with the updated version.
13. Contact us
If you have any questions about this policy or about your personal information, please write to us at the following address:
22 Berners Street
Alternatively, you can email us at email@example.com. To help us respond to you quickly, please include a brief description of what you’re emailing us about in the subject line of the email.