Privacy Policy

1. Introduction

This is the privacy policy pertaining to the mobile applications (apps) and web platforms of Bauer Media Audio Ireland LP, acting by its general partner Bauer Audio Ireland Limited (hereinafter “Bauer”, “our”, “we”).

This policy explains Bauer’s approach to digital information collection, storage and use in connection with the GoLoud Apps, OTB sports app and Goloud Website and Player, The Personal Information that Bauer collects is used for providing and improving these services. Bauer will not use or share your information with anyone except as described in this Privacy Policy.

If you choose to use our Services, then you agree to the collection and use of information in relation to this policy.

Bauer will ensure that it keeps all personal data you provide to us in accordance with our obligations under the Data Protection Acts 1988 to 2018 and General Data Protection Regulation (GDPR) (EU 2016/679).

We may update this policy from time to time, so please review it regularly. If you have any questions about this policy or the information which we hold, please contact us at: PrivacyOfficer@BauerMedia.ie or write to us at Bauer Media, Marconi House, Digges Lane, Dublin 2.

This policy applies to Bauer’s services only and not to other websites, APPs, social media sites linked to or from Bauer digital services.

2. About Bauer

Bauer has a number of brands in Ireland, these include:

• Goloud
• OTB Sports
• Today FM
• Newstalk
• 98FM
• Spin 1038
• Spin Southwest
• AudioXI

Bauer also provides a number of digital services for example Websites, smartphone Apps, Alexa Skills, Newsletters etc.

3. The information we collect

Bauer will never collect any unnecessary personal data from you and will not process your information in any way, other than as specified in this notice.

The personal data that Bauer collects varies depending on the online activity you access, below lists the information Bauer may collect when you register for a newsletter, take a survey, enter a competition, register with our apps or sites, or if you make direct contact with one of our companies:

• - Name
• - Email
• - Contact Phone Number (where required for a competition entry or where you contact the station via SMS or Whatsapp)
• - Home Address (where required for a competition entry or to reply to direct contact)
• - Confirmation that you’re over 18 (where required for a competition entry)
• - IP Address (To allow us geo-fence audio streams, this data is not used beyond this purpose)
• - Information contained in a curriculum vitae (where sent directly to the station)

Bauer collects your personal data when you;

• - subscribe (opt-in) to a newsletter,
• - enter a competition
• - participate in an online survey
• - contact Bauer or one of its brands directly
• - register on Bauer sites or apps

Lawful Basis for Processing

We process your personal data based on the following lawful basis.

• - Station Newsletter Subscriptions are based on Consent.
• - Direct Marketing emails are based on either Consent or Legitimate interest, where we use legitimate interest we will have completed an legitimate interest assessment where we conduct a balance test between our legitimate interests and your privacy rights.

Automatic Data Collection

Bauer use cookies and capture IP addresses as part of the essential operation of their sites and media streams, this data is used to geo-fence content and media streams so we can adhere to our licencing agreement regarding the broadcasting of licenced material. We also use cookies to maintain preferences you have selected, manage load balancing and DDOS mitigation these cookies are used only for this purpose and do not track you beyond our digital assets.


Marketing/Advertising Cookies

With your consent we use marketing cookies to better target advertising and make it more relevant to you and your interests, we also use these cookies to frequency cap the number of times you will see an individual ad. Advertising cookies collect information regarding your use of both our website and other websites you may visit. This information allows advertising networks to target their audience.

Where consent is not provided you will still receive ads but they will not be targeted.

You can find more about Advertising cookies here https://policies.google.com/technologies/partner-sites

You can also have control over what third party cookies are used on your device by using tools like

http://www.youronlinechoices.com/ie/your-ad-choices

Or

http://optout.networkadvertising.org

Further details of the cookies we use can be found in our Cookie Policy.


Site/App Analytics

Bauer uses third party tools including facebook and Google to monitor the usage of its digital assets including apps and websites, this is an essential part of the running of any online service. It provides the information we require to manage our server capacity and the popularity of our content. For more information on privacy regarding these third parties please see:
Google Analytics (Website analytics)

Google Firebase (app analytics, app registration)

Facebook (ad tracking, App SDK)

Branch (Push notification links)

Social Media

You should be aware that you may be making available personally identifiable information about yourself when you submit material to our social media pages or to other interactive elements of our digital services.

4. How we use the personal data we collect:

Bauer takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

We do not employ automated decision making methods to any of your personal data under our control.

The purposes and reasons for processing your personal data are detailed below:


• - We collect your data to administer a service which you have subscribed to and given consent for your personal data to be processed, this includes Station Newsletter and/or promotional material and/or App content management.


• - We collect your data as part of a competition entry to allow us contact you regarding the competition, this data is processed based on consent.


• - We collect personal data to administer your personalised preferences such as news content or preferred music and services.


• - We collect your personal data that you provide us with when you contact us directly to respond to your specific inquiry or to administer the relevant site activity where we have a legitimate interest.


• - We automatically capture your IP addresses to geo-fence our content.


• - Comply with legal regulatory requirements and legitimate business purposes.

Marketing uses

How we use marketing information?

• - To help us to monitor, analyse and improve Bauer Services. This information helps us to understand which Bauer content, products and services are most interesting, enjoyable and useful to our users, and if they are shared via social networks. The information also helps us to identify when errors occur within the digital products and services within Bauer and test different versions of a page or feature to see which one works best. All of which helps us improve our digital products and services for our users.
• - We can create a more tailored experience by looking at the information we have about you. For example, we will do this by making programme recommendations or telling you about relevant Bauer events in your area.
• - To inform the way we commission future content at Bauer. We will use aggregated and anonymous user data to help our commissioning teams understand what type of content our users like.
• - To sell advertising on Bauer.
• - We will send you information about the digital products and services within Bauer or other marketing activities, but only where you have signed up to receive these from us. Similarly, sometimes, third party partners will want to send you information about products and services, but will only do so if you have agreed to receive them by ticking an opt-in box associated separately with a competition partner.
• - We will email you occasionally about the digital products and services within Bauer that you have signed up for (for example, to provide you with password reminders or to contact you about content you have submitted to us via our digital products and services) so that we are able to deliver these services to you. We may also invite you to participate in surveys from time to time to help us understand what you think about our programmes, products and services, and in turn make them better.

5. Your Rights

You have the right to access any personal information that Bauer processes about you and to request information about:

• - What personal data we hold about you
• - The purposes of the processing
• - The categories of personal data concerned
• - The recipients to whom the personal data has/will be disclosed
• - How long we intend to store your personal data for
• - If we did not collect the data directly from you, information about the source

If you wish to make a Subject Access Request please contact PrivacyOfficer@BauerMedia.ie

• You have the right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• You have the right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• You have the right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• You have the right of portability – you have the right to have the data we hold about you transferred to another organisation.
• You have the right to object – you have the right to object to certain types of processing such as direct marketing. (eg Newsletter Opt-out)
• You have the right to object to automated processing, including profiling

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

6. Information collected for journalistic purposes

Under Article 85 of the GDPR (EU 2016/679) material acquired and used for journalistic purposes is exempt from certain Articles of GDPR, these include Chapter II (principles) other than Article 5(1)(f), Chapter III (rights of the data subject) Chapter IV (controller and processor obligations), Chapter V (transfer of data), Chapter V1, Chapter VII and Chapter IX.

Please note that the requirement to process personal data in a manner that ensures appropriate security remains when processing for journalistic purposes.

7. Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this policy or where there is a legal requirement. Bauer uses third-parties to provide services regarding subscriptions, surveys, competitions and events; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice and are subject to the GDPR (EU 2016/679).

8. Our commitment to security

Bauer takes your privacy seriously, we employ appropriate technical and organisational security measures to prevent unauthorised access, alteration, disclosure or destruction of your information.

We use the following industry standard methods to protect your data:

• - SSL (HTTPS) Across all websites
• - Encryption
• - Enterprise firewalls

Unfortunately, the sending of information via the internet is not completely secure. Although we will do our utmost to protect your information, we cannot guarantee the security of your data sent to our digital services within Bauer ; any sending of information is therefore at your own risk.

9. Transfer Outside the EEA

Bauer utilise services (or parts of them) that may be hosted/stored outside the EEA which means that we may transfer any information which is submitted by you through one of our digital services to outside the European Economic Area ("EEA") for the below purposes:

• - Newsletter Subscription
• Data Processor is MailChimp, more info here https://mailchimp.com/legal/privacy/ MailChimp have a proven track record in providing email marketing services across the globe.
• - Competition Forms and Surveys
• Data Processor is Wufoo.com, more information here https://secure.wufoo.com/privacy/
• Wufoo are Certified with the EU-US Privacy Shield Framework.
• - Events Registration Forms
• Data Processor is Eventbrite, more information https://www.eventbrite.ie/support/articles/en_US/Troubleshooting/eventbrite-privacy-policy?lg=en_IE
• - Streaming Services
• Data Processor is Triton Digital, for more information https://www.tritondigital.com/eu-privacy-policy

Therefore, when you sign up to our newsletter or enter a competition or register to attend a station event or participate in a station survey, the personal information you submit may be stored on servers which are hosted outside the EEA. Where this is the case, we will ensure that those providers use an appropriate level of protection for your information and agree to abide by GDPR (EU 2016/679) by way of standard contractual clauses.

10. How Long We Keep Your Data

Bauer only ever retains personal information for as long as is necessary to provide a service you have consented to or to adhere to certain warranties or proof of delivery for competition winners.

Where you have subscribed to a Newsletter we will retain your data until you unsubscribe or the Newsletter is canceled. We include unsubscribe links on all newsletter emails.

Where you have registered for an event we’ll retain your personal data for 13 months after the event as a record of attendance.

Where you enter a station competition we’ll retain your data for 12 months after the successful competition of the prize or event in the case of tickets.

We have retention policies in place to meet these obligations.

11. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Bauer, or how your complaint has been handled, you have the right to lodge a complaint directly with the Data Protection Commissioner and Bauer.

The details for each of these contacts are:

• Data Protection Commissioner
• Canal House
• Station Road
• Portarlington
• R32 AP23
• Co. Laois
• Phone: 1890 252 231
• Fax: +353 57 868 4757

• Bauer Media Ireland
• Privacy Officer
• Marconi House
• Digges Lane
• Dublin 2
• Co Dublin
• D02TD60
• Phone: +353 1 8049000