Privacy Policy
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Privacy Policy

Last reviewed: July 2021

At First Draft, we aim to work in a spirit of openness and cooperation with all of our partners, collaborators and audiences.  This doesn’t work without trust, and that’s why your privacy is vital to us.  This Privacy Policy outlines the steps First Draft takes to protect both your privacy and your data.

If you are a First Draft  customer or subscriber, or just visiting our website, this policy applies to you. Eyewitness Media Hub, trading as First Draft, acts as the ‘data controller’ of personal data, which means we determine how and why your data is processed. Eyewitness Media Hub is registered in England and Wales at 2nd Floor, Stanford Gate, South Road, Brighton, BN1 6SB, United Kingdom.

The data we collect about you

From the moment you interact with First Draft, we are collecting data. That’s just the simple fact of operating in the online world. Sometimes you provide us with the data, sometimes it’s collected automatically. But it’s always protected and never for sale.

We collect data when:

You browse any page of our website

You receive emails from us

We call you

You connect integrations (like Slack)

You sign up to events and training

You sign up to receive emails from us

 

You give us data when:

You browse any page of our website

You enquire about First Draft and our work

You connect integrations (like Slack)

You opt-in to marketing messages

You sign up to events and training

You submit forms or surveys (e.g. taking part in market research or submitting tips)

 

The types of data we collect

Personal details

Your name, address, telephone number, email address, job title, place of work.

Data that identifies you

Your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information, operating system and version.

Data on how you engage with First Draft

Your URL clickstreams (the path you take through our sites), pages viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions.

What about really sensitive data?

We don’t collect any “sensitive data” about you (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences) except when we have your specific consent, or when we have to to comply with the law.

What about children’s data?

First Draft’s work is directed to and intended for use only by those who are 18 years of age or over. We do not target our work at children, and we do not knowingly collect any personal data from any person under 16 years of age.

How and why we use your data

Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. These reasons are:

Providing our services

Administering the First Draft websites, managing your preferences and delivering journeys, login and authentication, remembering your settings, hosting and back-end infrastructure.

Legal basis Contract, legitimate interests.

Measuring our impact and improving the way we work

Testing features, interacting with feedback platforms and questionnaires, managing landing pages, heat mapping our site, traffic optimization, data analysis and research including profiling and the use of machine learning and other techniques, which in some cases might use third parties.

Legal basis: Legitimate interests

Support

Providing notifications to you in relation to our services, responding to queries via phone or email.

Legal basis: Contract

Marketing purposes (with your consent)

Sending you emails and messages about new initiatives, products and services, and content.

Legal basis: Consent

Your privacy choices

You can choose not to provide us with personal data

If you choose to do this, you can continue to use the website and browse its pages, but there may be certain limitations.

You can turn off cookies in your browser by changing its settings

You can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use the website and browse its pages.

You can ask us not to use your data for marketing

We will inform you if we intend to use your data for marketing and if third parties are involved. You can opt out from marketing by emailing us at [email protected]

Your privacy rights

You can exercise your rights by sending us an email at [email protected]

You have the right to access information we hold about you

This includes the right to ask us supplementary information about:

  • The categories of data we’re processing
  • The purposes of data processing
  • The categories of third parties to whom the data may be disclosed
  • How long the data will be stored (or the criteria used to determine that period)
  • Your other rights regarding our use of your data

We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if that’s the case.

You have the right to make us correct any inaccurate personal data about you

You can object to us using your data for profiling you or making automated decisions about you

We may use your data to determine whether we should provide you with information that might be relevant to you (for example, tailoring emails to you based on your behavior). Otherwise, the only circumstances in which we will do this is to provide the First Draft service to you.

You have the right to port your data to another service

We will give you a copy of your data in CSV or JSON so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you. Please note that we won’t do anything that involves disclosing data about another individual.

You have the right to be ‘forgotten’ by us

You can do this by asking us to erase any personal data we hold about you, if it is no longer necessary for us to hold the data for you to use the services off First Draft.

You have the right to lodge a complaint regarding our use of your data

Please tell us first, so we have a chance to address your concerns. If we can’t make it right, you can address any complaint to the UK Information Commissioner’s Office, either by calling their helpline or as directed on their website at www.ico.org.uk.

How secure is the data we collect?

We have physical, electronic, and managerial procedures to safeguard and secure the information we collect.

And please remember:

  • You provide personal data at your own risk: unfortunately, no data transmission is guaranteed to be 100% secure
  • You are responsible for any usernames and passwords: please keep them secret and safe!
  • If you believe your privacy has been breached, please contact us immediately on [email protected]

Where do we store the data?

The personal data we collect is processed at our offices and in any data processing facilities operated by the third parties we work with.

By submitting your personal data, you agree to the transfer, storing or processing by us. If we transfer or store your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

How long do we store your data for?

Personal identifiable information is kept only as long as is necessary for the purposes for which it is used, or for as long as we are legally required to keep it.

Third parties who process your data

Businesses often use third parties to help them with things like hosting applications, communicating with customers or managing emails. We partner with third parties who we believe are the best in their field at what they do.

When we do this, sometimes it’s necessary for us to share your data with them so these services work well. Your data is shared only when strictly necessary and according to the safeguards and practices detailed in this Privacy Policy. Where personal data is transferred to a third party in the United States we take steps to agree the standard contractual clauses with them in advance. We continually monitor this transfer mechanism. Any data transfers to the US are encrypted and generally consist of insensitive personal data.

Cookies

Unless you adjust your browser settings to refuse cookies, we (and these third parties) will issue cookies when you interact with First Draft. These may be ‘session’ cookies, meaning they delete themselves when you leave First Draft, or ‘persistent’ cookies which do not delete themselves and help us recognize you when you return so we can provide a tailored service.

How can I block cookies?

You can block  and delete cookies through your browser settings.If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully. In some cases, our website may not be accessible at all. Please note that where third parties use cookies we have no control over how those third parties use them.

Changes to This Policy

This privacy policy is current as of the date stated above. We will review this policy regularly and place any updates on this web page.