This Privacy & Cookies Policy explains how The Carriage Commentator Limited and collects and uses your information and how you can influence this. The Carriage Commentator Limited is a company established in England with its registered address at Martin & Co., 25 St Thomas Street, Winchester SO23 9HJ (company number 11774112). This Privacy & Cookies Policy relates to websites and apps (“sites”) operated from time to time by The Carriage Commentator Limited. When we mention “we”, “us” or “our”, we are referring to the company responsible for processing your data. For the purposes of data protection law, the company operating the site on which you clicked on this Privacy & Cookies Policy will be the data controller of any personal data they collect about you. If you are unsure which company is the data controller, please get in touch using the details in the How to contact us section below.
This version was last updated on 14 June 2019. We have updated our Privacy & Cookies Policy in order to comply with new data protection laws in the UK which will come into force on 14 June 2019. Please check back regularly as we will need to make periodic changes to this policy to reflect updated guidance and requirements when they become available.
Information you give to us: In order to process your requests and orders, it is necessary to collect personal data from you. This includes, but is not limited to: your name, address, e-mail address, telephone number, credit/debit card information, PayPal details. We are unable to provide you with products and services if you do not provide certain information to us. You may also be asked to provide additional (non-mandatory) pieces of information such as your interests, preferences, age, gender, feedback, and survey responses so that we can better understand our customers. You can also choose to provide such information by posting on a forum, filling out a web form or when you communicate with us. We also obtain information about you that you have provided where we have the appropriate permissions to do so or as otherwise authorised by applicable law.
Information we collect automatically when you use our sites or services: We collect information about your interaction with our sites and services from the devices you use, such as your unique device ID, device type and advertising ID. We also collect information about your visits and activity on our site including the content and any advertisements that you view and interact with, the address of the site from which you arrived and other technical data about your equipment, browsing actions and patterns (such as the pages you view, the links you click, the items you add to your shopping basket, the length of your internet session, your IP address and approximate location at the time of browsing). This information is collected using cookies or similar technologies. To learn more about these technologies and your choices, go to the section on Cookies and other technologies below.
Information collected from other sources: We will combine your information with information we collect from third parties or public sources, including analytics providers, advertising networks, and publicly available sources such as Companies House and the Electoral Register.
Social Media: Certain sites offer services that require you to set up an account prior to receiving such services. To create a secure account you can use your email address and a password or, if the site offers a Facebook single-sign-on service, you will be able to register for and log-in to your account using your Facebook account. If you choose to use the Facebook single-sign-on service, you are granting permission to Facebook to share certain profile information with us. This will include your name, profile picture and list of friends and any other information notified to you by Facebook prior to you completing the single-sign-on authorisation process. You control what social media information you allow us to have access to using the privacy settings on the applicable social media platform and any permissions you give as part of the single-sign-on authorisation process.
Our site is not intended for children under the age of 13. If you are under 13, please do not provide any information to us and instead ask your parent or guardian to do this on your behalf. You must be at least 18 years of age to purchase products or services from us. If you are under the age of 18, you must ensure that your parent or guardian purchases the products or services on your behalf.
We will use your information for the following purposes:
Service Access and Registration: to register you as a new customer when you purchase a subscription, or other product or service from us or create an account on our site in order to access one of our services.
Sales and Fulfilment: to process and deliver your order; to manage payments, fees and charges; to collect and recover money owed to us; to provide you with services you have requested from us when we collected the information from you.
Customer Relationship Management: to contact you about your account, subscription or other order; to provide you with customer service (such as responding to questions, concerns and feedback and contacting you via email, telephone, SMS/text, post, direct message or other similar communication method for this purpose); to notify you of material changes to our terms or this Privacy & Cookies Policy; to send you service related communications; to ask you to leave a review or take a survey.
Competitions, Awards, Events, Product Trials, Surveys: to enable you to participate in competitions, prize draws, product trials, events, awards, surveys, polls and quizzes and to provide you with any prizes, products or awards as applicable.
Business Administration, Systems and Security: to administer and protect our business and our site such as troubleshooting, testing, system maintenance, support, reporting and hosting data; to ensure network and system security and prevent detect, mitigate and investigate fraud, security breaches and other prohibited or illegal activities; to verify your identity.
Data Analytics: to measure the performance of our marketing campaigns (for example, analysing open and click rates); to provide insight and analysis of our customers for ourselves and our business partners.
Marketing: to provide you with marketing via email, post, telephone, SMS/text, social media and other digital channels (including Facebook Custom Audiences and Google Custom Match); to make suggestions and recommendations to you about goods and services that could be of interest to you.
Advertising: to select and deliver advertising and content to you and measure the delivery and effectiveness of such advertising and content.
Personalisation: to personalise content, services and communications and target advertising, as further explained in Personalisation and Advertisingbelow.
Aggregation and Anonymisation: to aggregate and anonymise your data, so that we can use it to enable us to sell advertising and monitor the efficacy of our business partnerships.
Personalisation and Advertising
We want the ads and content displayed on our sites to be relevant to you. Personalising and targeting advertising, content, services and communications allows us to provide you with much of our sought-after online content for free.
We will use your information to provide you with personalised content, services and communications as well as targeted advertising on our site. We do this by matching, combining or linking the different sources of information we hold about you (e.g. linking your contact or subscriber information with your activity across our sites or by linking your activity on our site across all your devices using your email or social media log-in details) or by creating segments based on various factors such as your age and gender, your device details or your inferred interests. We work with data management platform providers to assist with this process.
We also use your information for retargeting (for example, you could see an advertisement on a partner site such as Facebook for a product that you have recently viewed on our sites).
Where we have the appropriate permissions or as otherwise authorised by applicable law, we will use your information to market and advertise our products and services, our group companies’ products and services, and occasionally third party products and services that could be of interest to you including third party offers, advertisements, competitions or commercial communications by telephone (mobile and landline when available), post, electronic messaging (including SMS and MMS), email, online or via applications. You could be contacted directly for these purposes.
You can always tell us that you wish to stop receiving direct marketing communications from us. But remember, if you do not want us to get in touch, you will miss out on offers.
If you would prefer not to receive direct marketing communications, simply let us know at any time by emailing email@example.com with the subject line “Privacy”, or by following the opt-out instructions in the relevant communication. Please note that this will not stop you from receiving service messages from us.
We rely on the following legal basis when processing your data:
Fulfilling a contract with you and providing you with our services, or to comply with a legal obligation, including to: register you as a new customer when you purchase a subscription or other product or service from us or create an account on our site in order to access one of our services; process and deliver your order; manage payments, fees and charges; collect and recover money owed to us; contact you about your account, subscription or other order; provide you with customer service (such as responding to questions, concerns and feedback and contacting you via email, telephone, SMS/text, post, direct message or other similar communication method for this purpose); send you service related communications; provide you with services you have requested from us when we collected the information from you; enable you to participate in competitions, prize draws, product trials, events, awards, surveys polls and quizzes and provide you with any prizes, products or awards as applicable; notify you of material changes to our terms or this Privacy & Cookies Policy; administer and protect our business and our sites such as troubleshooting, testing, system maintenance, support, reporting and hosting data necessary to ensure network and system security and prevent detect, mitigate and investigate fraud, security breaches and other prohibited or illegal activities; verify your identity.
Our legitimate interests (to run an effective and successful business), or the legitimate interests of a third party, where not outweighed by your interests, including to: measure the performance of our marketing campaigns (for example, analysing open and click rates); provide you with marketing via post, telephone, social media and other digital channels (including Facebook Custom Audiences and Google Custom Match); provide you with marketing via email where you have purchased goods or services from us; ask you to leave a review or take a survey; administer and protect our business and our sites such as troubleshooting, testing, system maintenance, support, reporting and hosting data; use data analytics to provide insight and analysis of our customers for ourselves and our business partners; make suggestions and recommendations to you about goods and services that could be of interest to you; select and deliver advertising and content to you and measure the delivery and effectiveness of such advertising and content; personalise content, services and communications and target advertising; to aggregate and anonymise your data, so that we can use it to enable us to sell advertising and monitor the efficacy of our business partnerships. The legitimate interests we rely on for this processing are: to keep our records updated; to study how customers use our products and services; to improve the customer experience; to develop our products and services; to develop and grow our business; to run our business; to provide administration and IT services; for network security and fraud prevention; in the context of a business reorganisation or a group restricting exercise; to inform our marketing and content strategy; to keep our sites and content updated and relevant.
Your consent, including to: provide you with marketing via email, SMS/text, post and telephone, including from our group companies and from third parties. You can withdraw your consent at any time – see Marketing.
We will not share your personal data with any other organisation other than for the following reasons – We may pass your personal data to third parties to enable them to process a request, order or service; to supply you with a prize in the event you win a competition; or in order to obtain professional advice. Any third parties employed by us to process your data on our behalf are subject to contractual obligations to protect the security of your data in accordance with the terms of this Privacy & Cookies Policy and, where your data is transferred outside of the European Union, we make sure there are adequate protections in place – see International Transfers for further information.
We could merge with or be acquired by another business. If this happens we share the information that relates to you. You will be sent notice of such an event.
We reserve the right to disclose your personal data in order to comply with the law, applicable regulations and government requests. We also reserve the right to use such information in order to protect our operating systems and integrity as well as other users.
Once we have received your data we will take steps to ensure that it is treated in accordance with any applicable laws. Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
We are required by law to keep certain information about our customers (such as financial and transaction related data) for seven years after they cease being customers for tax purposes.
Our data retention periods vary depending on the context of the services that we provide to you and our legal obligations. To determine the appropriate period for which we keep your data, we consider the amount, nature and sensitivity of your data, the potential risk or harm from unauthorised use or disclosure of your personal data, the purposes for which we process that data (and whether we can achieve those purposes through other means), and applicable legal requirements.
We are based in the UK and seek to keep your data within the European Economic Area (EEA). If we were to transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as to data that remains within the EEA. We do this by ensuring at least one of the following safeguards is implemented:
Adequacy decision: The data is transferred to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission.
Model clauses: We have used specific contracts approved by the European Commission in our arrangement with the third party, which give personal data the same protection it has in Europe.
Privacy Shield: The third party is based in the US and is part of the Privacy Shield, which requires them to provide similar protection to personal data when it is shared between Europe and the US.
You have certain rights in relation to the personal data we hold about you, which we detail below. Certain rights only apply in specific circumstances as set out in more detail below. We also set out how to exercise those rights. When you exercise your rights, we need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will also contact you to ask you for further information in relation to your request to speed up our response.
You have the right to:
Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction 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 need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. 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 could have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we are not always 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.
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 (more information on your marketing choices can be found in the Marketingsection above). In certain cases, we will demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
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.
Make a complaint at any timeto the Information Commissioner’s Office, the supervisory authority for data protection issues in the UK. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance by contacting us using the details provided in the How to contact ussection below.
If you wish to exercise any of the rights set out above, please contact us using the details provided in the How to contact ussection below.
We keep this Privacy & Cookies Policy under review and will update it to reflect changes in our privacy practices. Any updates will be made on this page so that you can always find out what information we collect, how we use it and under what circumstances we will disclose it.
If you have any queries relating to this Privacy & Cookies Policy please contact us by writing to The Editor, The Carriage Commentator Limited, The Coach House, Baughurst Road, Baughurst, Hampshire RG26 5LL or email firstname.lastname@example.org. Last updated: 14 June 2019
Cookies and other technologies
We use, and allow certain other companies to use, cookies, web beacons and other similar technologies on our sites, applications and communications. We do this to understand your use of our services, improve your user experience, enable personalised features and content, optimise our advertising and marketing and to enable third party advertising companies to assist us in serving you advertisements specific to your interests across the internet. The technologies we use do not collect any information which directly identifies you in the real world, such as your name, email address, address or phone number.
What are ‘cookies’?
A cookie is a small text file that we, and in certain circumstances third parties, place on your browser (for example, Internet Explorer or Safari) when you visit our sites or open some of our emails. Cookies are useful because, amongst other things, they allow us to recognise you each time you re-visit one of our sites. The entity that places cookies on your browser can then read the information on the cookie that it set.
Cookies are typically classified as either “session cookies” which do not stay on your device after you close your browser or “persistent cookies” which will usually remain on your device until you delete them or they expire.
You can find more detailed information about these technologies at:
Different cookies are used to perform different functions which we explain below. A visit to our site could generate the following types of cookie:
Site performance cookies
The information collected from these types of cookies can be used in conjunction with other information we hold in order to record specific browsing information (for example, regarding the way visitors arrive at our sites, pages viewed, options selected, information entered and the path taken through our sites). The data collected will generally be aggregated to provide trends and usage patterns for business analysis, site/platform improvement and performance metrics and to inform our advertising and marketing strategies.
Cookies can also be linked with other information we hold or infer about you for these purposes. For example, if you are a registered user or provide us with your name, email address, social media log-in details or other contact information (e.g. by entering a competition or signing up to our newsletter) or interact with our email communications (e.g. by clicking on links within the emails), this information can be linked with your browsing activity across all your devices to tailor content, services, advertising and offers for you.
We also obtain information from third party service providers such as demographics and interest categories created from a combination of sources that permit us to provide you with more relevant and useful content, communications and advertising. This information does not identify you personally.
Third party advertising cookies
We may partner with advertisers, ad network providers and ad serving companies to place cookies on our sites to allow them to show you advertisements both on and off our sites that are more relevant and useful to you, limit the number of times you see a particular ad and to customise ads. We do not share any information with these third parties that will directly identify you in the real world, such as your name, email address, address or phone number. However, these third parties can assume that users who interact with or click on a personalised advertisement or content are part of the group that the advertisement or content is directed towards. The third parties that generate these cookies have their own privacy policies and we have no access to read or write these cookies.
Social media cookies
How we and third parties use web beacons
We may use and permit selected third parties to use web beacons (usually in combination with cookies) to compile aggregate information about your site usage and your interaction with email and other communications to measure performance and to provide content and advertisements that are more relevant to you. A web beacon (also called a web bug, clear GIF or pixel tag) can be embedded in online content, videos and emails, and allows a server to read certain types of information from your device, to know when you have viewed the beacon and the IP address of your device. The type of information collected includes, but is not limited to, information relating to advertising responses, page views, promotion views and purchases made. We will include web beacons in certain promotional email messages and newsletters to determine whether the messages have been opened or acted upon and whether our mailing tools are working correctly. The web beacons can be used to recognise cookies generated by third parties and inform us and third parties of which advertisement or link brought you to our site, allowing us to monitor the efficacy of our business relationships with third parties.
If you do not want your browser to accept cookies and use them in the ways described above, you can change your browser settings. You can also delete existing cookies from your browser. However, blocking all cookies will affect your web experience and can result in parts of our site not functioning properly. Certain cookies are designed to help save you time by, for example, remembering your contact details when you place an order.
The procedure for modifying your privacy preferences is different for each internet browser and the following links will be helpful:
For general information about cookies and their use, please visit:
Alternatively, you can turn off third party cookies relating to interest based advertising by visiting www.youronlinechoices.eu. However, this will not opt you out of receiving adverts altogether – it simply means that the adverts will not be targeted to you. Please note that there are many more networks listed on this site than we use on our sites.
You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page. For Google Analytics Advertising Features, you can opt-outthrough Google Ads Settingsor by visiting the Network Advertising Initiative opt out page. You can find more information about how Google uses information from our sites here.
As web beacons are the same as any other content request included in the recipe for a web page, you cannot opt out or refuse them. However, you are able to disable web beacons in email messages by not downloading images contained in messages you receive (this feature varies depending on the email software used on your personal computer). However, doing this will not always disable a web beacon or other tracking technologies in the email message due to specific email software capabilities. For more information about this, please refer to the information provided by your email software or service provider. Web beacons can also be rendered ineffective in certain circumstances by opting out of cookies or amending your cookie settings in your browser. Further details on web beacons, and how to manage them, can be found here:
Last updated: 14 June 2019