We are the subscription management business of HH&S Group Ltd trading as SubSaver.
This is the main privacy notice for HH&S Group Ltd.
This Privacy Notice, which covers all of your personal information
whether collected online or offline, including by telephone or where
you write to us.
For all of our Sites, the publisher of the newspaper or magazine you subscribe to is the data controller of the personal information
that we gather about you. Regardless of which publisher
is the controller, you can always contact SubSaver with questions or concerns
about your privacy by emailing us at email@example.com
- Personal and contact details you have provided to us, such as
your name, email address or postal address, for example when you
register for a subscription;
- Information we buy or obtain from third parties, including
2. USE OF YOUR INFORMATION
We want to offer you products and services which you want to use. We
may use and permit others to use your personal data as set out below.
We may use information about you to provide and manage the products
and services you have subscribed to or purchased, to help us customise
our products or services for you, to personalise your visits to our
Sites, to help us to choose products and services we think will
interest you, for market research and to improve the usefulness of our
Sites, products and services.
We also use your personal data to contact you, including to notify
you about changes and updates to products or services, to evaluate the
performance of our products and services and to develop new products
We may use your information for the management of our business and
improving the operation of our business and that of our business
partners, to assess our internal processes and carry out financial
We may monitor, record and store records of calls, email, text
messages, social media messages and other
communications where permitted by law and we’ll do this where the law
requires it, or to comply with regulatory rules, to prevent or detect
crime, for evidential purposes, in the interests of protecting the
security of our communications systems and procedures and for quality
control and staff training purposes.
We may use your data to comply with legal and regulatory obligations.
We may make use of your personal information for direct marketing
activities, or supply this information to third parties for their
direct marketing activities, with your consent or as permitted by law.
By direct marketing activities, we mean the communication directly to
particular individuals (by e-mail, post or telephone) of any
advertising or marketing material.
Where we’re relying upon your consent to process personal data, you
can withdraw this at any time by contacting us at firstname.lastname@example.org.
We may disclose details about the use of our Sites to other
businesses e.g. to demonstrate patterns of use to advertisers and
others. The information we pass on will be anonymised. We compile
anonymous records of user trends which we may make use of ourselves or
pass to the publishers or our associated companies, including advertising networks.
3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
SubSaver shares information with the publisher of your newspaper or magazine and as needed with our third party service
providers and partners, as part of providing and administering our products and services or operating our
business or as set out below.
We will disclose your information and co-operate with appropriate
bodies and authorities in good faith where we are required to by
law, a court order, a regulatory authority, or otherwise, including
with the police, trading standards, regulatory authorities or other
The publisher of your newspaper or magazine may also share information to facilitate the sale of one or more
parts of their business, including if they are approached by a potential
buyer or the restructuring of one or more parts of their business and
with auditing organisations such as the Audit Bureau of Circulation
4. WHAT ARE THE LEGAL GROUNDS FOR OUR PROCESSING OF YOUR
PERSONAL INFORMATION (INCLUDING WHEN WE SHARE IT WITH OTHERS)?
We rely on the following legal bases to use your personal data:
A. Where it is needed to provide you with our products or
services, such as:
- Managing products and services you hold with us, or an enquiry
- Updating your records, tracing your whereabouts to contact you
your account and doing this for recovering debt (where appropriate)
- Sharing your personal information with third parties and services
providers when you apply for a product or service to help manage your
product or service
- All stages and activities relevant to managing any product or
service including enquiry, application, administration and management
B. Where it is in our legitimate interests to do so, such as:
- Managing your products and services, updating your records
- To perform and/or test the performance of, our products, services
and internal processes
- For some direct marketing communications, subject to appropriate
controls and safeguards
- To follow guidance and recommended best practice of government
- For management and audit of our business operations including
- To carry out monitoring and to keep records of our communications
with you and us
- For market research and analysis and developing statistics
- To provide insight and analysis to business
partners either as part of providing products or services, helping us
improve products or services, or to assess or to improve the operating
of our businesses
- Where we need to share your personal information with people or
organisations in order to run our business or comply with any legal
and/or regulatory obligations
- To comply with our legal obligations or where we reasonably
we are under a legal or regulatory obligation
C. With your consent or explicit consent
- For some direct marketing communications and digital advertising
5. HOW LONG DO WE KEEP YOUR DATA FOR?
In general, we keep your personal information for as long as we need
it for the purpose for which it was collected, plus a short additional
period in case of problems. How long we keep it therefore varies
according to the type of information it is and why we have it, and will
range from a few days or weeks to, in some cases, several years.
We have established a full data retention policy, and can provide
further information on request.
6. WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LAW?
The law gives you certain rights in respect of the information that
we hold about you. Below is a short overview of those rights. The
website of the Information Commissioner’s Office (http://www.ico.org.uk) has a wealth
of useful information in respect of your rights over your personal data.
If you wish to exercise your rights, you can write to us by
or by post to SubSaver, 301 Harbour Yard, Chelsea Harbour, London SW10 0XD, for
the attention of the legal department.
Your right to withdraw your consent
If we are processing your personal data on the basis of your
consent, you have the right to withdraw that consent at any time.
Your right to access the information we hold about you
With some exceptions designed to protect the rights of others, you
have the right to a copy of the personal data that we hold about you,
as well as information about what we do with it, who we share it with
and how long we will hold it for. We may make a reasonable charge
for additional copies of that data beyond the first copy, based on our
Your right to have inaccurate information about you
You have the right to have the information we hold about you
corrected if it is factually inaccurate.
Your right to object to what we do with your data, and
to have restrictions placed upon it
Where we process your personal data on the basis of our legitimate
interest, you have the right to object to that processing and to have
restrictions placed upon it while we consider your objection.
Your right to have your information erased in some
You have the right to require us to delete the information that we
hold about you if it is no longer necessary for the purpose we
collected it for, and there is no other legal basis on which we must,
or are allowed to, retain it.
Your right to stop receiving direct marketing from us
You have the right to require us to stop sending you direct
marketing material (for example, promotional emails). It can
sometimes take a few days to action these requests.
Your right to complain to the Information Commissioner’s
You have the right to lodge a complaint about our handling of your
personal data with the supervisory authority, which in the UK is the
Information Commissioner’s Office. But before you do so, please do
contact us first to give us a chance to put matters right, at email@example.com
You can contact the ICO on 0303 123 1113.
7. CHANGES TO THIS PRIVACY NOTICE
It’s likely that we’ll need to update this Privacy Notice from time
to time. Any changes to this Privacy Notice will be posted here
and such changes will become effective as soon as they are posted. Your
continued use of the relevant Site constitutes notice to you of all
8. CONTACT US
If you have any questions about this privacy notice, or if you wish
to exercise your rights you can contact us email at firstname.lastname@example.org.
Alternatively, you can write to SubSaver, 301 Harbour Yard, Chelsea Harbour, London SW10 0XD