Privacy Policy

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: legal@newswhip.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, channel handles, data included in the content of posts, videos, images and links to posts on third party platforms, aggregated engagement data 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
    • Entering into or performance of a contract
    • Consent
    • Legitimate interest of NewsWhip*
    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.
    • Entering into or performance of a contract
    • Consent
    • Legitimate interest of NewsWhip*
    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.
    • Entering into or performance of a contract
    • Consent
    • Legitimate interest of NewsWhip*
    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
    • Entering into or performance of a contract
    • Legitimate interest of NewsWhip*
    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
    • The performance of a contract.
    • There is a legal / regulatory obligation
    • Legitimate interest of NewsWhip*
    Applicants for employment To manage the employment/engagement of staff Personal Data includes: name, address, contact details PPS number, bank account details, nationality
    • Entering into or performance of a contract
    • There is a legal / regulatory obligation
    • Legitimate interest of NewsWhip*
    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).
    • Consent
    Website & Social Media To promote the activities of and Services provided by NewsWhip IP address, web tracking data, images of events
    • Legitimate interest of NewsWhip*
    • Consent (for images of Subjects)
    Enquiries To engage with individuals who make an enquiry Details provided on the enquiry including name, and contact details
    • Consent
    • Legitimate interest of NewsWhip*
    Promotions, events and Subscriber testimony To promote the activities and Services of NewsWhip Name, contact details, testimony
    • Consent
    Email Alerts To provide relevant alert(s) where a subscriber to our Services adds you to the email alerts feature Email address
    • Legitimate interest of NewsWhip*
    General Legal/regulatory obligations
    Revenue & Regulatory Authorities To enable processes that are compliant with law and regulation Identity, PPS number, payments, tax residency
    • There is a legal / regulatory obligation
    • Legitimate interest of NewsWhip*
    Auditors & Compliance To audit the activities of the business in line with regulation and best practice All data
    • There is a legal / regulatory obligation
    • Legitimate interest of NewsWhip*

     

    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/end-users. We may also share the contact details of the staff of our customers/end users with suppliers of service and or payment providers 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.

    6.3 Marketing

    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. Third Party Policies

    NewsWhip utilises YouTube API Services within its Services. Upon accessing the Services, You agree to be
    bound by YouTube’s Terms of Service, which can be found at https://www.youtube.com/t/terms and is
    incorporated into NewsWhip Terms and Conditions by this reference. Upon accessing the Services, You also acknowledge and agree to be bound by the Google Privacy Policy, which can be found at http://www.google.com/policies/privacy and is incorporated herein by this reference.

    11. 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.

    12. 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.

    13. Your Rights

    Subjects have the right to:

    1. Be informed of information on whether we have Personal Data relating to a Subject, the categories of data and the purpose of processing.
    2. 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.
    3. Be informed if a failure to provide the Personal Data will have any direct and material personal consequences.
    4. Access your Personal Data. Where the format is not reasonably understood, this shall be delivered in an intelligible format.
    5. Have inaccurate, incomplete or out-of-date Personal Data that we hold about you corrected, or deleted.
    6. Request that your Personal Data be deleted or for you to be forgotten.
    7. Withdraw consent for your Personal Data to be processed – where it was obtained from you on the basis of consent.
    8. Make a submission on any automated decisions making processes or profiling of you.
    9. Transfer your data to another Controller.
    10. Have your Personal Data excluded from certain categories of processing.
    11. Lodge a complaint with the Data Protection Commissioner. Contact details for the DPC can be found at www.dataprotection.ie.

    Please note:

    • There are some limitations to these rights.
    • You can contact us to exercise any of the above rights by e-mail at legal@newswhip.com. We will ask for additional information to verify your identity prior to acting upon such requests.

    14. 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 marketing@newswhip.com.

    15. 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.

    16. 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
    Employment data

    Generally for the duration of employment plus 7 years. Where categories of data have:

    • regulatory limitations to possible liability, or
    • mandatory retention periods,

    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.

    17. Cookies

    While using our web site we use cookies – small text files – which are placed on your hard drives to provide a more intuitive website experience. Cookies are a typical part of operating procedure for most websites and most browsers permit users to opt-out of receiving them if the user would prefer.

    You can opt out of the use of certain categories of cookies on the cookie notice tool that is always visible while you use the NewsWhip website. This may reduce some of the functionality of the site. You can view our Cookies policy here.

    Cookies can also be deleted by you from your browser at any time.

    18. Updates

    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: November 2023