In accordance with Data Protection and Privacy law
1. NewsWhip as a Controller
NewsWhip is a private business that provides real-time media monitoring and analysis services that predict the news stories and topics that matter. We are committed to the privacy of those that engage with us and this statement details our approach. While providing Personal Data to us in the course of business or whilst using our Services or websites including: newswhip.com; and spike.newswhip.com, we will manage your data in accordance with this privacy statement.
Personal Data processed by NewsWhip is in accordance with current Data Protection Regulation in Ireland and the GDPR.
If you are under 18 years, please read this statement with the assistance of a parent or guardian.
2. Key Definitions
- “Our”, “we”, “us” or “NewsWhip” refers to NewsWhip Media Limited and its subsidiaries and parent company trading as NewsWhip.
- “You”, “Your”, or “Subject” refers to the individual person whose Personal Data is the subject of the text.
- Personal Data refers to information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as; a name, an identification number, location data, an online identifier, or one of more factors specific to the physical, psychological, genetic, mental, economic, cultural or social identity of that natural person.
- Data Subject refers to the identified or identifiable natural person.
- Special (often referred to as sensitive) Category Data refers to racial or ethnic origin, political opinions, religious or philosophical beliefs, or trades union membership, or that includes genetic data, biometric data to reveal the identity of a person, or data concerning health, sex life or sexual orientation. Personal Data relating to criminal convictions is also considered sensitive.
- Controller refers to the natural or legal person or body which alone or jointly determines the purpose and means of the processing of Personal Data.
- Processor refers to the natural or legal person or body which processes Personal Data on behalf of the Controller under their instructions.
- Sometimes NewsWhip acts as the Controller and sometimes as the Processor when your data is being used. We explain in this statement whether we are acting as a Controller or a Processor in respect of any given processing activity.
3. Contact Us
Questions, comments or requests can be submitted to NewsWhip’s data protection representatives.
By Mail to: FAO: Legal Department, NewsWhip, Huckletree D2, 42 Pearse Street, Dublin 2,D02 YX88 Ireland.
By Email to: email@example.com
4. Purpose and lawful basis
NewsWhip processes your Personal Data for many reasons and we are obliged to inform you of the purposes for which we use your data and legal basis for processing. Our core business is the real-time media monitoring and analysis of social media engagement (“Services”). NewsWhip does not collect the Personal Data of social media contributors to create profiles of individual Data Subjects.
Our Services only process public social media data. We do not collect any private data about individuals as inputs for our Services. For example, we model how fast each story is spreading by gathering public data points on engagement with that story. We index and monitor content from public sources such as public social media pages, public tweets, public web pages, public forums, public YouTube accounts, and aggregate data on overall engagement with any posts, videos, or stories we discover. As an author of this data, you can control how this data is published through the privacy settings on your social media platform. Where we can detect that posts have been deleted or unpublished at source, we will also remove this data from our processing.
The purposes for processing your Personal Data may overlap, and some purposes for processing may have multiple legal basis. They are as follows:
|Category||Purpose||Examples of the type of data processed||Legal basis for processing*|
|*Note; Where this document refers to the legitimate interest of NewsWhip as a legal basis for processing, such legitimate interest refers to the business of the operation of a real-time media monitoring platform that analyses current and historic user engagement metrics on social media platforms.|
|*Personal Data that is the subject matter of the Services that we deliver|
|The Personal Data that is the subject of the real-time media monitoring Services that we deliver||To provide real-time media monitoring Services to our customers||Names, social media handles, data included in the content of posts, images and links to posts on third party platforms||Legitimate interest of NewsWhip*|
|Interaction with our customers|
|Entering into and managing a contract with our customers to supply a Service||To interact with the representatives of our customers to deliver the Services, provide customer service and support and to affect payment.||General Personal Details: name, contact details, employer, position, and role in the organisation||
|Credit Card processing||To manage credit card processing||Applicable credit card information||NewsWhip is a Processor of this data|
|Customer login data||To facilitate access/log in to Services||User name, e-mail address, customer organisation name, address and location, IP address||NewsWhip is a Processor of this data|
|Service Data||To deliver the Services||Information that is created, inputted, submitted, posted, transmitted, stored or displayed by you or your agents in the process of using our Services.||
|Log files/Analytics (“Usage Data”||To improve our Services. To assist us in understanding usage of our Services and (in some cases) to determine whether an email has been opened and acted upon.||IP address, browser, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data, feature usage, user name, user email address and other information that may be included in open textual fields.||
|Login through third party service||To allow login through a social media account sign-in service eg Facebook Connect.||Name, email address(es), current city, profile picture URL, or other personal information that the third party service makes available to us||
|The staff of NewsWhip (employee or contractor)|
|Data required for the employment of staff||Information provided while applying for a position||CV, references, background check, qualifications||
|Applicants for employment||To manage the employment/engagement of staff||Personal Data includes: name, address, contact details PPS number, bank account details, nationality||
|Marketing & promotional activities|
|Direct Marketing||Direct communication to customers/potential customers||Postal address, e-mail, text (You may opt out of any of the above upon request).||
|Website & Social Media||To promote the activities of and Services provided by NewsWhip||IP address, web tracking data, images of events||
|Enquiries||To engage with individuals who make an enquiry||Details provided on the enquiry including name, and contact details||
|Promotions, events and Subscriber testimony||To promote the activities and Services of NewsWhip||Name, contact details, testimony||
|Email Alerts||To provide relevant alert(s) where a subscriber to our Services adds you to the email alerts feature||Email address||
|General Legal/regulatory obligations|
|Revenue & Regulatory Authorities||To enable processes that are compliant with law and regulation||Identity, PPS number, payments, tax residency||
|Auditors & Compliance||To audit the activities of the business in line with regulation and best practice||All data||
5. Where you have provided consent
Where we are processing Personal Data based on your consent you may withdraw that consent at any time.
6. Who we share Personal Data with.
We take all reasonable measures to protect your personal information while it is in our possession, however, it may be transferred to others where there is a legitimate and lawful reason. This section lists the categories and types of organisations that we may transfer Personal Data to.
6.1 Delivery of our Services
We share the content of social media posts with our customers. We may also share the contact details of the staff of our customers with suppliers of service where such transfer is necessary for the delivery of the service being provided.
6.2 Staff of NewsWhip
Payroll bureau, IT providers, benefit providers, customers, professional advisors, Insurers in the event of a claim.
On social media.
6.4 Usage Data
We may share Usage Data with third parties, including our customers, partners and service providers, for various purposes, including to help us better understand our customers’ needs and improve our Services as well as for advertising and marketing purposes.
6.5 Legal / Regulatory Requirements
Revenue Commissioners, Audit & Compliance, Solicitors or advisors representing NewsWhip.
7. International transfer
NewsWhip controls the processing of data in the US and may transfer data between these locations on the basis of EU Standard Contractual Clauses.
When we provide Services to our international customers, we transfer data on the basis of an EU adequacy ruling or in the absence of an adequacy ruling on the basis of EU Standard Contractual Clauses.
In the event that a service provider to NewsWhip is international in nature, or sub processes with entities that are not within the EU, we will take steps to ensure that Personal Data is retained in the EU and that any further processing that may expose such data to international transfer is subject to the protections provided by a lawful basis of transfer.
8. Responsibility of customers and others who provide Personal Data to us
You warrant that personal information provided to us by you that relates to third parties (e.g. company representatives, associates or suppliers) has been obtained fairly and lawfully and that such information is accurate. You also warrant that third parties are aware of the purpose for which their Personal Data is being used and that their privacy rights have been upheld.
9. Information relating to children and vulnerable persons
The processing of Personal Data relating to children receives special attention under Data Protection Regulation and we shall treat this information with particular care. Children are defined as under 16’s in Ireland. Information processed on social media platforms has been obtained subject to the privacy policies and processes of the individual platforms and NewsWhip does not obtain the data of children for the NewsWhip service from any other sources. The processing of data relating to children shall receive additional consideration while planning an operational process.
10. Special (Sensitive) Data
NewsWhip recognises that it may from time to time process special categories, particularly in the context of employment and the delivery of our Services. The processing of this category of information shall typically require consent. We may also process Special Category Data where there is a legal/regulatory obligation.
11. Confidentiality & security
News Whip have implemented generally accepted standards of technology and operational security to protect Personal Data from alteration, unauthorised disclosure or destruction, and from use for unauthorised purposes. Furthermore, we have taken measures to ensure that contracts with all third parties that provide technical and processing Services include terms that specify appropriate technical and organisational security measures to prevent accidental, unauthorised or unlawful disclosure or processing of Personal Data.
12. Your Rights
Subjects have the right to:
- Be informed of information on whether we have Personal Data relating to a Subject, the categories of data and the purpose of processing.
- Where information is collected directly from the Subject, to be informed of the Controller and representative, the purpose and legal basis for processing, and details about the processing of your data.
- Be informed if a failure to provide the Personal Data will have any direct and material personal consequences.
- Access your Personal Data. Where the format is not reasonably understood, this shall be delivered in an intelligible format.
- Have inaccurate, incomplete or out-of-date Personal Data that we hold about you corrected, or deleted.
- Withdraw consent for your Personal Data to be processed – where it was obtained from you on the basis of consent.
- Make a submission on any automated decisions making processes or profiling of you.
- Transfer your data to another Controller.
- Have your Personal Data excluded from certain categories of processing.
- Lodge a complaint with the Data Protection Commissioner. Contact details for the DPC can be found at www.dataprotection.ie.
- There are some limitations to these rights.
- You can contact us to exercise these rights by e-mail at firstname.lastname@example.org. We will ask for additional information to verify your identity prior to acting upon such requests.
13. Removal from mailing lists
You may unsubscribe from our mailing lists at any time by using the ‘unsubscribe’ button on marketing communications, or by contacting us at email@example.com.
14. Reporting of Data Breaches
Where a data breach occurs that poses a risk to the Subject it shall be reported to the Data Protection Commission. Where such a breach occurs and poses a high risk to you we will also inform you. All breaches will be managed in accordance with Irish law and the GDPR.
15. Data Retention
We retain Personal Data that you submit to us only for as long as is necessary for the purposes for which it was obtained, or as required by law. We have detailed retention periods for which Personal Data shall be retained for particular purposes. NewsWhip reserves the right to delete Personal Data prior to the conclusion of the retention period or where such retention is not absolutely necessary.
|Storage of Personal Data|
|Purpose of processing||Duration||Criteria for the storage of Personal Data|
|Personal Data obtained in the course of the delivery of our analytical Services||3 months or less||From detection of deletion or unpublishing of the data from source.|
|Customer and sales transaction data||7 years||From end of relationship|
Generally for the duration of employment plus 7 years. Where categories of data have:
We will retain for these periods plus one year.
|Marketing data relating potential customers||12 months||From the last communication|
|Incidents or complaint reports||7 years||From date of the incident or complaint report|
|Documentation relating to revenue||Stored as mandated by law plus 12 months|
|Nothing in this section creates an obligation upon NewsWhip to retain Personal Data on behalf of a Data Subject.|
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This statement may be updated from time to time. The most up-to-date version is available on our website. We advise you to use a current version of this document when considering your rights.
Last updated: March 2023