Last updated [5 October 2018]
Research Bods Online Limited (“ResearchBods”) administer and operate the website www.matterscommunity.co.uk (the “Site”) and “Mail Matters”, “Mail Online Matters” and “Metro Matters” (the “Panels”) on behalf of Associated Newspapers Limited ("ANL" ''we", "us", and "our").
ANL will be the controllers of your information for the purposes of data protection legislation.
This privacy notice covers the collection of personal information from users of the Site and members of our Panels ("you" and "your") and use of that information by ANL and parties that ANL authorise, such as our suppliers and subcontractors.
1. What kinds of information do we collect:
The information collected about you depends on how you're using the Site and participating in the Panels, but we will only collect your personal information where necessary.
• Registration Data
To become a member of a Panel, you need to register on the Site. When you register you are asked to provide some basic information about yourself, such as your name, email address, your date of birth, postcode and phone number - which we call "Registration Data". You can update your Registration Data at any time. Please note, your account may be deleted your account if you've been inactive for a period of time, so please make sure that any Registration Data is accurate and kept up to date.
• Research Task Data
We also collect information that you submit when you voluntarily complete any of the research tasks (e.g. surveys, polls or forum discussions) we invite you to participate in, or feedback, comments or other information that you provide to us through the Site or otherwise, including any information, photos and/or videos which you may upload.
This may also include special category data such as your ethnicity and sexuality, which helps us to ensure that our Panel is representative of the UK population and to conduct research more effectively. Providing special category data is not compulsory, and you may withdraw your consent at any time by emailing us at firstname.lastname@example.org
• When you contact us
We collect information when you contact us or provide us with information through the Site or otherwise at any other point (for instance, when you contact us with an enquiry, request or feedback).
• Information from your device
• Third party suppliers
From third party suppliers who have confirmed to us that they are authorised to pass your information to us in accordance with your legal rights.
2. How we may use your information?
ANL may use your information to:
• administer and manage the Site and the Panels;
• verify your identity (e.g. when you register as a member of a Panel or return to the Site);
• invite you to participate in and communicate with you about research tasks (such as surveys, polls and forum discussion) on the Site and other research activities that may be relevant to you based on the information you have provided to us;
• send you communications about the Site and the Panels (including service messages to make you aware of new features or changes to the Site or Panels);
• collate and aggregate responses to research tasks by you and other members of the Panel;
• create statistical profiles of Panel membership based on the information provided by you and other members of the Panels;
• conduct market research, which may include statistical, technical and logistical analysis;
• verify that a Panel is representative of the UK population;
• process and deal with any complaints or enquiries made by or about you;
• monitor and develop the Site and the Panels to improve your experience;
• monitor compliance with and investigate any suspected breach of the Terms and Conditions or other applicable terms.
• to enter you into and administer any prize draws that you are eligible to take part in or, where invited to do so, have asked to be entered into. This is done to reward members for completing research tasks (e.g. surveys, polls and forum discussions).
3. Legal Basis for processing your data
Contract: We process some of your data as a necessary part of performing our contractual obligations to you (e.g. our Terms and Conditions)
Consent: Some processing activities will only be done where we have sought your prior consent. If we require your consent, we will provide you with full details of the information that we would like and the reason we need it. Once given, you have the right to withdraw your consent again at any point and we will be obliged to stop processing your data and delete it unless we can demonstrate that another legal basis applies. If you withdraw your consent to us processing sensitive personal data, we will stop sending you any research tasks which require this information but may continue to send you other research tasks and we may still use the anonymised, aggregated data which we have created using your information. We may continue to send you other research tasks and we may still use the anonymised, aggregated data which we have created using your information.
Legitimate Interests: We process some of your data because it is in our legitimate interests to do so. For example, we have a legitimate interest in undertaking market research and using the results of that research to gain insight. Where this is the case, we have considered the impact using your information may have on you, and limited our use to only what is strictly necessary. Where we are using this as our basis, we can provide you with an explanation of why the processing is in our interests and you are free to contest this decision if you wish.
Legal Obligations: Some processing activities are necessary for compliance with a legal obligation placed on us.
Type of data
Legal grounds for processing
Registration Data and Research Task Data you provide to us (other than special category data), which may include photos and/or videos you upload on the site.
Contract: when you agree to participate in each of our research tasks in exchange for a reward (which may include entry into a prize draw or a voucher), then there is a contract between us for you to complete those research tasks band for us to be able to use the resulting data and to provide you with a reward (which may include an entry into a prize draw or a voucher). We will process your data in connection with that contract.
Legitimate Interest: ANL has a legitimate interest in undertaking market research and using the results of that research to gain insight about its business, including its audience, brands, products and advertisements.
Special category data
Consent: when you submit special category data we will ask for your consent to use that information for the purposes as described in this Policy.
Registration Data, log-in history, history of engagement with our services, browser details, device internet protocol (IP) address and device type and data collected via cookies (see Cookies Policy).
Legitimate Interest: We have a legitimate interest in using this information to understand how people use our Site and engage with the Panel services, so that we can improve our services and undertake research more effectively.
Administer rewards such as prize draws or vouchers, and for winners of prize draws, publish their name and county on our Site or in the Panel newsletter
Registration Data and for prize draw winners, their name and county.
Contract: when you agree to participate in our research services in exchange for a reward (such as an entry into a prize draw or a voucher), a contract is formed between us and you – to complete those research tasks in exchange for us administering that reward.
Legal obligation: the Non-Broadcast Code of Advertising and Direct & Promotional Marketing (CAP Code) requires us to publish or make available the winner's name and county.
Queries and complaints handling
Registration Data, Research Task Data, log-in history, history of engagement with our services, browsing data, device IP address, device type and any other data your provide to us.
Legitimate Interest: We have a legitimate interest in our users engaging with the Site and services and improving the Site and services. Therefore we may use your personal information to manage any queries or complaints you may have
4. Emails from Mail Matters, Mail Online Matters and Metro Matters
• All Panel members will receive emails in connection with the Site and the Panels. This includes emails about: new features or changes on the Site; information about new surveys, polls or forum discussions on the Site; other research activities that may be relevant to you based on information you have provided to us; information about rewards, including prize draws in connection with research tasks on the Site.
• By registering to be a member of the Panel you acknowledge that you understand that these emails are necessary for us to provide our research services. You can unsubscribe from these emails at any time by clicking on the "unsubscribe” link at the bottom of any of the emails. Alternatively, you can email us at email@example.com from your registered email address and ask us to unsubscribe you.
5. How your information is shared
• Researchbods shares your personal information with ANL, as the owner of the Site and the Panel.
• ANL has access to those parts of the Site that are visible to other Panel members as well as open and closed online discussion forums on the Site, and may engage with you directly via such discussion forums and other areas of the Site.
• ANL may disclose aggregated and anonymised results of the research tasks to other members in the ANL group of companies and third parties (such as advertiser clients and media buying agencies).
• ANL may also pass information about you to other parties as follows:
o to third party processors authorised by us and acting on our behalf such as contractors, suppliers and/or agents including without limitation our customer care teams to administer and manage the site and the Panel now or in the future. These third parties are only allowed access to your information as needed to perform functions connected with the Site and the Panel, or to provide services to us. They're not allowed to use it for any other purpose.
Our current sub-processors are the following:
o as part of general statistical information about the Panel's membership base, traffic volumes and related matters. These details will not include information from which you could be personally identified;
o to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence, unlawful activity or suspected breach of the Terms and Conditions or where required by law or where we suspect harm or potential harm to others. We will cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders.
6. Publically available information
Please note that the Site contains public forums and pages which are displayed to other members of the Panel. When you engage with these areas of the Site, your user name and some profile information you voluntarily provide and your submissions will be publicly available. Please always think carefully about creating your user name (which will be the identity by which you are known on those areas) and before disclosing information to other users or otherwise making your information publicly available.
7. Details of transfers to third countries and safeguards
• Any organisation who has access to your information in the course of providing services on ANL or ResearchBod’s behalf will be governed by contractual restrictions and/or technical limitations to make sure they protect your information and comply with applicable data protection legislation.
• Where these organisations are based outside of the EEA in a jurisdiction that has not been deemed adequate by the EU, ANL or ResearchBods enter into EU approved model clauses with them to ensure appropriate safeguards are in place.
8. How can you exercise your rights under the GDPR
• Access: If you wish to exercise your right to access a free copy of your data, you can contact us at the contact details provided below at Section 13.
• Deletion: To ask us to delete your personal data, please contact us at the contact details provided below at Section 13. However, there may be circumstances where we are legally entitled to retain it.
• Rectification: If you wish to update or rectify your data, you can do this directly by accessing your account settings.
• Revoke consent: If you wish to object to the processing of your special category data you can email us at firstname.lastname@example.org. You can opt-out of email communications by clicking on the “unsubscribe” link in any marketing email or newsletter you receive from us.
• Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party please contacting us as at the contact details provided below at Section 13 stating the nature of and reasons for such objection.
• Complain: You also have the right to lodge a complaint about us with our supervisory authority, the Information Commissioner’s Office.
If you are contacting us to exercise any of your rights under the GDPR, you will have to provide valid proof of identification. We are required to respond to your request within 1 month.
9. Data retention and account deletion
We will keep your personal information for only as long as necessary, which is longer in some cases than in others. The length of this retention period depends on the purpose for which the information was obtained and its nature. For example:
• We may need to keep some personal information about you so that we can deal with any complaints you might make about the Site or the Panel or our services.
• If you ask us to stop sending you emails in connection with research tasks, the Site and the Panel, we need to retain enough information about you to enable us to ensure we stop including you in any communications.
• We may need to keep personal information so that we can defend possible future claims.
10. Closing your account
You may close your account at any time. If you do so, your Registration Data will be removed and you will be unable to access the Site and you will no longer receive emails from us.
We will delete your account as soon as reasonably practicable following receipt of the deletion request, and in any event within 5 business days.
If you delete your account, we may continue to process your data for contractual reasons e.g. If we need to provide you with a prize won before closing your account. Please note, if you have not earned a reward or incentive or rewards at the time you delete your account, you will forfeit any rights to try and earn or receive those incentives or rewards.
We reserve the right to suspend or terminate your membership at any time, at our sole and absolute discretion. This may be because, for example, we consider that you have breached the Terms and Conditions or any other applicable terms or if you have been inactive for a period of time.
We may close the Panel and your account when the research programme ends or is cancelled. In these circumstances, we will inform all Panel members by email of the Panel being closed, at which point your access to it will cease.
11. Business Changes
ANL may choose to run the Site or the Panel itself or to appoint a new supplier to run it in which case your information may be passed to that new supplier. Use of your personal information will remain subject to this privacy notice (as amended from time to time).
If ANL becomes involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisers involved. Such a transaction may involve ANL: (i) retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction. ANL will provide notice to you before any of your personal information becomes subject to a different privacy notice.
12. Updates to this Policy
We reserve the right to make changes to this Policy. Where changes are made, we will post the revised Policy here with an updated effective date. Please check regularly for any changes to this Policy.
13. How to contact us:
If you have any queries or comments about this Policy or to exercise any of your rights under the GDPR, please contact us by email at:
Alternatively, you can write to us at:
Legal Department – Data Protection & Privacy
Associated Newspapers Limited
2 Derry Street
London, W8 5TT
You can also contact our Data Protection Officer at:
Alternatively, you can write to them at:
F.A.O Data Protection Officer - Associated Newspapers Ltd
Platform, New Station Street,
Leeds, LS1 4JB