Privacy Policy

Clear Sky Publishing is a privately owned media company serving geographical and specialist interest communities with a number of news brands and associated websites.

1. Who are we

Clear Sky Publishing is a privately owned media company serving geographical and specialist interest communities with a number of news brands and associated websites. Our portfolio of UK-based regional newspapers and magazines are located in the South West and our brands include the North Devon Gazette, the Torbay Weekly, the Mid Devon Weekly, the Moorlander and the Exeter Magazine.

This privacy notice is to let you know how brands within the Group promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

2. Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated in February 2022.

3. How the law protects you

We are only allowed to use your personal data if we have one or more of the following reasons to do so:

  • To fulfil a contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest (which means we have a business or commercial reason to use your information. We still have to assess whether your rights when relying on this reason), or
  • When you give us consent to. Here is a list of all the ways that we may use your personal information and the reason from the list above which we are relying on. If we are relying on a legitimate interest this is also detailed below:

What we use your personal information for

Our reasons

Our legitimate interests

• To manage our relationship with you or your business. 

• To develop new ways to meet our customers’ needs and to grow our business. 

• To develop and carry out marketing activities. 

• To study how our customers use products and services from us and other organisations. 

• To provide advice or guidance about our products and services. 

• Your consent. 

• Fulfilling contracts. 

• Our legitimate interests. 

• Our legal duty. 

• Keeping our records up to date, working out which of our products and services may interest you and telling you about them.  

• Monitoring and reporting campaign effectiveness and alternatives for you. 

• Developing products and services, and what we charge for them. 

• Defining types of customers for new products or services. 

• Seeking your consent when we need it to contact you. 

• To develop and manage our brands, products and services. 

• To test new products. 

• To manage how we work with other companies that provide services to us and our customers. 

• Fulfilling contracts. 

• Our legitimate interests. 

• Our legal duty. 

• Developing products and services, and what we charge for them. 

• Defining types of customers for new products or services. 

• Being efficient about how we fulfil our legal and contractual duties. 

• To make and manage customer payments. 

• To collect and recover money that is owed to us. 

• Fulfilling contracts. 

• Our legitimate interests. 

• Our legal duty. 

• Being efficient about how we fulfil our legal and contractual duties. 

• Complying with regulations that apply to us. 

• Developing products and services, and what we charge for them. 

• Defining types of customers for new products or services. 

 

• Fulfilling contracts. 

• Our legitimate interests. 

 

• Complying with regulations that apply to us.  

• Being efficient about how we fulfil our legal and contractual duties. 

• To serve you targeted advertising that we believe are more relevant to your interests.   

• Our legitimate interests. 

• Your consent. 

 

• Developing products and services, and what we charge for them. 

• Defining types of customers for new products or services. 

 

• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit. 

• Our legitimate interests. 

• Our legal duty. 

• Complying with regulations that apply to us.  

• Being efficient about how we fulfil our legal and contractual duties. 

• To exercise our rights set out in agreements or contracts. 

• Fulfilling contracts. 

• Our legitimate interests. 

 

• Complying with regulations that apply to us.  

• Being efficient about how we fulfil our legal and contractual duties. 

• To maintain statutory records. 

• Our legal duty 

• Our legitimate interests. 

• Complying with regulations that apply to us 

• Being efficient about how we fulfil our legal and contractual duties. 

4. Types of Personal Information

We use many different kinds of personal information:

Type of personal information  

Description  

Financial  

Your financial position when you open a business account with us via credit reference agencies.  

Contact  

Where you live and how to contact you.  

Transactional  

Details about payments including to and from your accounts with us.  

Contractual  

Details about the products or services we provide to you.  

Locational  

Data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internet.  

Behavioural  

Details about how you use our products and services.  

Technical  

Details on the devices and technology you use.  

Communications  

What we learn about you from letters, emails and conversations between us.  

Usage Data  

Other data about how you use our products and services.  

Consents  

Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you.  

5. Where we collect personal information from

We may collect personal information about you (or your business) from other companies within the Clear Sky Publishing group.  We may also receive data from third parties where you have consented for your details to be given to third parties.

5.1 Data you give to us:

  • When you sign up for our products and services
  • When you talk to us on the phone
  • When you use our websites and mobile device apps (including when you comment on them)
  • In emails and letters
  • In customer surveys
  • If you take part in our competitions or promotions (including awards)
  • If you are attending an exhibition

5.2 Data we collect:

We also collect data when you use our services. This can include the profile you create to identify yourself when you connect to our internet, mobile and telephone services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.

5.3 Data from third parties we work with:

  • Credit reference agencies
  • Social networks
  • Market researchers
  • Ticket agencies
  • Third parties you have given consent to pass your data to us New Paragraph

6. Who we share your personal information with

We may share your personal information with companies within the Clear Sky Publishing Group and these organisations:

  • Regulators and other authorities, including the Police
  • Credit reference agencies
  • Debt collection agencies
  • Fraud prevention agencies
  • Any party linked with you or your business’s product or service
  • Companies we have a joint venture or agreement to co-operate with
  • Companies you consent to share your data with.
  • Companies who we run competitions in conjunction with
  • Exhibitors at events
  • Event venues
  • If you are a shareholder, our Registrars
  • If you use direct debits, we will share your data with the Direct Debit scheme
  • If purchasing items from our shops, the supplier of such items We may need to share your personal information with other organisations to provide you with the product or service you have chosen.
    We may also share your personal information if the make-up of Clear Sky Publishing Group changes in the future:
  • We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
  • During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
  • If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

6.1 Credit Reference Agencies (Business account customers only)

For business customers we carry out credit and identity checks when you apply for an account. We may use Credit Reference Agencies (CRA’s) to help us with this.
We will share your personal information with CRA’s and they will give us information about you. The data we exchange can include:

  • Name, address and date of birth
  • Credit application
  • Details of any shared credit
  • Financial situation and history
  • Public information, from sources such as the electoral register and Companies House. We’ll use this data to:
  • Assess whether you or your business is able to afford to make repayments
  • Make sure what you’ve told us is true and correct
  • Help detect and prevent financial crime
  • Manage accounts with us
  • Trace and recover debts

6.2 Sending data outside of the EEA

We will only send your data outside of the European Economic Area (‘EEA’) to:

  • Follow your instructions.
  • Comply with a legal duty.
  • Work with our agents and advisers who we use to help run services. If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
  • Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
  • Put in place a contract with the recipient that means they must protect it to the same standards as the EEA.
  • Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.  We may need to collect personal information by law, or under the terms of a contract we have with you.
    If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services. It could mean that we cancel a product or service you have with us.

7. Marketing

We and our partners may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us and data we collect when you use our services, or from third parties we work with where you have consented to data being passed to us
We and our partners can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages by contacting us at any time or using the unsubscribe button on the marketing material
If you choose to stop receiving marketing material you may still receive certain things such as invoices from us which we need to send you for contractual or other legal purposes.

8. How long we keep your personal information

We will keep your personal information for as long as you are a customer of Clear Sky Publishing Group or you continue to use our services.
After you stop being a customer/user, we may keep your data for up to 6 years to enable us to respond to any questions or complaints and to show that we treated you fairly.
We may keep your data for longer than 6 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

9. What if you want us to stop using your personal information?

You have the right to opt-out or to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.  
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
You can also ask us to restrict the use of your personal information if:

  • It is not accurate.
  • It has been used unlawfully but you don’t want us to delete it.
  • It not relevant any more, but you want us to keep it for use in legal claims.
  • You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it. If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us.
    If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

10. What if you want us to stop using your child’s personal information?

If you notify us that we have received personal information from your child without your consent we will use reasonable efforts to remove any data we hold.

11. Access to your information and correction

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please see the subject access request procedure below.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate using the contact details above.

12. Cookies

To find out more about how we use cookies please see our cookie policy. You can also manage you cookies with the Manage Cookies tab at the foot of the website.

13. Other websites

If you decide to visit a website not owned by us by clicking through from our site you will be bound by that new site’s terms and conditions and privacy policy.

14. How to complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us at Chris.Coward@clearskypublishing.co.uk or Data Protection Officer, Unit 3, Old Station Road, Barnstaple, EX32 8PB.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

How to contact us
If you wish to contact us with regard to your data, our Data Protection Officer can be contacted by:
Email: Chris.Coward@clearskypublishing.co.uk
Post: Data Protection Officer Unit 3, Old Station Road, Barnstaple, EX32 8PB
Telephone: 01271 341638