Policies
If you are visiting our Service from the United Kingdom, European Union, or other non-U.S. location, please review our General Terms and Conditions. If you are visiting our Service from the United States, please review our U.S. Terms and Conditions.
1. These Terms
Welcome to the www.telegraph.co.uk website. These are the terms and conditions (Terms) which govern your use of (1) the www.telegraph.co.uk website and any of the 'Telegraph' branded microsites, and (2) any of the apps available for use on a Mobile Device (Site).
For the purpose of these Terms “Mobile Device” includes a Smartphone or other mobile or handheld device (such as a tablet) with an open operating system capable of exchanging data via 3G, 4G, 5G or wirelessly over a computer network (for example Apple OS iPhones, iPads, Kindle, Kindle Fire, Android OS phones tablets and Symbian OS phones and tablet devices).
These Terms apply regardless of whatever user device you are using (including desktop, laptop or mobile web browser, digital television, mobile phones, automobile-based personal computers, handheld digital devices, and any other Mobile Device or technology whether now known or developed in the future).
You will be deemed to have agreed to be bound by these Terms when you use, access or browse the Site, register your details with us, purchase a subscription package, subscribe for email or online services, or send us an email.
For the purposes of these Terms: "Content" includes all or part of any text, graphics, layout, logos, images, audio material, films or other moving images, product details and/or software published or otherwise available on the Site from time to time (including, anything made available for download); “including” and its derivations mean “including, without limitation”; "material" includes all or part of any text, graphics, layout, logos, images, audio material, films or other moving images; and "Trade Marks" means the trade marks, logos and service marks (whether or not registered) displayed on the Site.
2. Changes to these Terms
We may change these Terms from time to time. Please check these Terms regularly as any changes are effective immediately upon posting to the Site. Your continued use of the Site after posting will be deemed acceptance of the changes.
3. About us and our business
The Site is operated by or on behalf of Telegraph Media Group Holdings Limited (company registration number 14551860) ("TMG", "we" or "our"). You can contact us by telephone on the Telegraph General Switchboard at +44 (0) 207 391 2000.
4. Subscription and Registration
Access to our email services and to some areas of the Site is restricted to users who have either registered their details with us, or have purchased the relevant subscription package. You must not use a false name or email or provide any false information nor impersonate another person when purchasing a subscription, registering for use of the Site and our email services. If you have a password for registration or subscription, you shall not share or disclose it to any third party, nor allow any third party to use your password to gain access to the areas and services for registered users or subscribers. We may refuse or remove or suspend your registration or subscription at any time.
5. Intellectual Property
We are the owner or the licensee of all intellectual property rights in the Site the Content and the Trade Marks. Subject to these Terms, we grant you a limited, temporary, revocable, and non-exclusive licence to access, browse and use the Site (including the Content and Trade Marks) in accordance with paragraph 6 below. You shall abide by all additional copyright notices, information, or restrictions contained in any Content accessed through the Site.
6. Access and use of the Site
We use the unbranded version of the YouTube embedded video player (YouTube Player) to display some of our YouTube video content on www.telegraph.co.uk. The YouTube Player is made available to you by YouTube and your use is subject to YouTube’s Terms of Service available here: Terms of Service (youtube.com). YouTube may collect usage data when you interact or engage with the YouTube Player on www.telegraph.co.uk and the collection of such data is governed by Google’s privacy policy available here: Privacy Policy – Privacy & Terms – Google.
You may use the Site for personal non-commercial use only. You may only download and print extracts of the Content for your own personal non-commercial use.
Non-commercial use does not include the use of Content without prior written consent from us in connection with: (1) the development of any software program, including, but not limited to, training a machine learning or artificial intelligence (AI) system; (2) providing archived or cached data sets containing Content to another person or entity.
You may not:
(1) download or print any Content or extracts in a systematic or regular manner or otherwise so as to create a database in electronic or paper form comprising all or part of the Content from the Site; nor
(2) reproduce, republish, modify, archive, distribute, store, archive or commercially exploit the Content without our prior written consent; nor
(3) modify or adapt or create derivative works of the Content; nor
(4) utilise links to this website received as part of a paid-for media monitoring service; nor
(5) systematically forward links to this website within a business or outside a business for business purposes; nor
(6) copy or extract data from this website by means of robots, spiders, crawlers or other automatic devices or by any manual process used to systematically extract or copy web content.
Any such use of this website or the content is prohibited without an appropriate licence. Please contact NLA Media Access (www.nlamediaaccess.com) or us at syndication@telegraph.co.uk.
If you wish to syndicate or licence any Content from this website, please email us at syndication@telegraph.co.uk.
At all times when you are accessing, browsing or using or registering for use of the Site, you must do so lawfully and legitimately and without infringing or restricting anyone else’s rights or use and enjoyment of the Site. In particular, you must not use the Site in a manner or upload any material or link to any material which is false, fraudulent, inaccurate or misleading, obscene, offensive, defamatory, abusive or in breach of any third party rights (including intellectual property right).
At any time without notice and in our absolute discretion, we may permanently or temporarily terminate, suspend or deny your access to the Site. At any time without notice and in our absolute discretion, we may remove or edit any Content on the Site.
To the fullest extent permitted by law, in both cases none of TMG, its directors, employees or other representatives have any liability to you whatsoever for any loss or damage arising from such removal or editing or any restriction or hindrance to your use of the Site, email services or password.
This Site was operated by or on behalf of Telegraph Media Group Limited (company registration number 00451593) prior to 29th September 2024.
These Terms and Conditions are effective from 29 September 2024.
Effective Date: 29 September 2024.
Introduction Please read these Terms carefully before using our websites and any online services, software or apps provided by Telegraph Media Group Holdings Limited or its affiliates and branded microsites (collectively, “Telegraph”, “we”, or “us” or “our”) that post a link to these Terms (the “Service”). By visiting or otherwise using the Service in any manner, you agree to the then posted Terms and any applicable Additional Terms (defined below), to be bound by them, and that you have read and understood them. These Terms apply to visitors and users of the Service in the United States. You also acknowledge, agree and consent to our data practices as described in our Privacy Policy
THESE TERMS AND CONDITIONS CONTAIN A BINDING ARBITRATION PROVISION, CLASS ACTION WAIVER, AND JURY WAIVER THAT AFFECTS YOUR RIGHTS. THE ARBITRATION PROVISION REQUIRES THAT ALL DISPUTES BE RESOLVED IN INDIVIDUAL ARBITRATIONS OR SMALL CLAIMS COURT PROCEEDINGS. IN ARBITRATION, THERE IS NO JUDGE OR JURY AND THERE IS LESS DISCOVERY AND APPELLATE REVIEW THAN IN COURT.
Further, these terms are legally binding, limit Telegraph’s liability to you and require you to indemnify us. If you do not wish to be bound by these Terms and any Additional Terms, do not use the Service and uninstall our downloads and applications.
Additional Terms In some instances, additional or different terms, posted on the Service, apply to your use of certain parts of the Service (individually and collectively “Additional Terms”). To the extent there is a conflict between these Terms and any Additional Terms, the Additional Terms will control unless the Additional Terms expressly state otherwise. The Telegraph Community Guidelines are an example of an Additional Term.
Updates to these Terms and Additional Terms We may prospectively change these Terms and Additional Terms by posting new or changed terms on the Service as more fully explained here.
Quick Links We have summarized some (but not all) of the main topics of these Terms below. The complete provisions, and not the headings or summaries govern.Grants and Limitations of Rights
We only grant you a limited revocable license to use the Service subject to rules and limitations. More
You grant us a broad license to the content you submit and to your profile. You retain ownership of and responsibility for your content. We have the right to manage our Service to keep its content appropriate. More
Your use of our Service is subject to various restrictions designed to protect the Service and users. More
Limitations on Your Remedies As permitted by applicable law,
We also disclaim most warranties and provide the Service “As Is”. More
Our liability is greatly limited. More
Your equitable or injunctive relief rights are limited. More
Dispute Resolution
As permitted by law, you agree to arbitrate disputes and waive jury trial and class actions. More
Availability of Service
We may change or discontinue our Service, or your right to access it, in whole or in part.
Our Service is intended for access from and use in the U.S.. For EU/UK visitors, please visit telegraph.co.uk. More
1. OWNERSHIP AND YOUR RIGHTS TO USE THE SERVICE AND CONTENT.
A. Ownership. The Service and all of its content (“Content”), including all copyrights, patents, trademarks, service marks, trade names and all other intellectual property rights therein (“Intellectual Property”), are owned or controlled by Telegraph, our licensors, and certain other third parties. All right, title, and interest in and to the Content and Intellectual Property available via the Service is the property of Telegraph, our licensors or certain other third parties, and is protected by U.S. and international copyright, trademark, trade dress, patent and/or other Intellectual Property and unfair competition rights and laws to the fullest extent possible. Telegraph owns the copyright in the selection, compilation, assembly, arrangement, and enhancement of the Content on the Service.
B. Your Rights to Use the Service and Content.
(i) Your right to use the Service and Content is subject to your strict compliance with these Terms and the Additional Terms. Your right to access and use the Service and the Intellectual Property shall automatically terminate upon any violations. These rights are non-exclusive, limited, and revocable by us at any time in our sole discretion without advance notice or liability. As your right to access and use the Service and the content is personal to you, you may not assign nor transfer your right; any attempt to do so is void. You may, for your personal, non-commercial, lawful use only (collectively, the following are the “Telegraph Licensed Elements”):
Display, view, use, and play the Content on a computer, mobile or other internet enabled or permitted device (“Device”) and/or print one copy of the Content (excluding source and object code in raw form or otherwise) as it is displayed to you;
Stream the Content using any of the widgets and/or other digital streaming internet video players, if any, provided on the Service;
Subject to any applicable Additional Terms, if the Service includes a “Send to Friend,” social media sharing or similar tool that allows you to initiate and send to one or more of your contacts a communication that includes content, or to post our content to third-party services or your own site or online service, and the tool is operational, use the tool to do so; provided, however, that you do not do so in any manner that violates applicable law or third-party rights or reflects negativity on us, and only send to recipients you have permission to contact;
If the Service includes a “Download” link next to a piece of content (including, without limitation, an image, an icon, a wallpaper, a music track, a video, a trailer, an RSS feed), you may only download a single copy of such content to a single Device;
Download, install and use one copy of any software, including apps, that we make available on or through the Service (“Software”) on your Device in machine-executable object code form only and make one additional copy for back-up purposes; provided, however, that you understand and agree that (i) by allowing you to download the Software, Telegraph does not transfer title to the Software to you (i.e., you own the medium on which the Software is recorded, but the Software's owner (which may be Telegraph and/or its third-party Software licensor) will retain full and complete title to such Software); (ii) you may not copy, modify, adapt, translate into any language, distribute, or create derivative works based on the Software, except as expressly authorized in these Terms or applicable Additional Terms, without the prior written consent of Telegraph; (iii) you may not assign, rent, lease, or lend the Software to any person or entity and any attempt by you to sublicense, transfer, or assign the Software will be void and of no effect; and (iv) you may not decompile, disassemble, reverse engineer, or attempt to reconstruct, identify, or discover any source code, underlying ideas, underlying user interface techniques, or algorithms of the Software by any means whatsoever, except to the extent the foregoing restriction is prohibited by applicable law;
If made available to you, obtain a registered personal account (and/or related username and password) on the Service and interact with the Service in connection therewith;
Link to the Service from a website or other online service, so long as: (a) the links only incorporate text, and do not use any Telegraph names, logos, or images, (b) the links and the content on your website do not suggest any affiliation with Telegraph or cause any other confusion, and (c) the links and the content on your website do not portray Telegraph or its products or services in a false, misleading, derogatory, or otherwise offensive manner, and do not contain content that is unlawful, offensive, obscene, lewd, lascivious, filthy, violent, threatening, harassing, or abusive, or that violate any right of any third-party or are otherwise objectionable to Telegraph. Telegraph reserves the right to suspend or prohibit linking to the Service for any reason, in its sole discretion, without advance notice or any liability of any kind to you or any third-party; and
Use any other functionality expressly provided by Telegraph on or through the Service for use by users, subject to these Terms (including, without limitation, functionality to create and/or post User-Generated Content (as defined below)) and any applicable Additional Terms.
C. Additional Terms for Usage Subscriptions. Purchases of usage subscriptions (e.g., credits, points, and/or virtual currency) or any virtual items made available on the Service are nonrefundable, have no monetary value (i.e., are not a cash account or equivalent), and are purchases of only a limited, non-exclusive, revocable, non-assignable, personal, and non-transferable license to use those items only, even if such came with a durational term (e.g., a monthly subscription). Any attempt to transfer, assign or otherwise sell or trade such subscription, regardless of manner or method, is null and void. Suspension or termination thereof results in the forfeit of the suspended or terminated subscription or items, except as may be noted in the applicable Additional Terms. As permitted by law, we are not responsible for repairing or reissuing any credit or refund or any other sum, as a result of our modification of any usage subscriptions or virtual item, or for loss or damage due to error, or any other reason.
D. Rights of Others. In using the Service, you must respect the Intellectual Property and rights of others and Telegraph. Your unauthorized use of Content may violate the rights of others and applicable laws, and may result in your civil and criminal liability. If you believe that your work has been infringed via the Service, see Section 5.
E. Reservation of all Rights Not Granted as to Content and Service. These Terms and any applicable Additional Terms include only narrow, limited grants of rights to use and access the Service and content. No other right or license may be construed, under any legal theory, by implication, estoppel, industry custom, or otherwise. ALL RIGHTS NOT EXPRESSLY GRANTED TO YOU ARE RESERVED BY TELEGRAPH AND ITS LICENSORS AND OTHER THIRD PARTIES. Any unauthorized use of any Content or the Service for any purpose is prohibited.
F. Third-Party Services. We are not responsible for third parties or their content, advertisement(s), apps or sites (“Third-Party Services”). For instance, portions of the Service may be integrated into or linked to third-party sites, platforms and apps that we do not control. Similarly, we may make third-party ads and other Third-party Services, which we also may not control, available to you on or via our Service. This may include the ability to register or sign in to our Services using Meta or other third-party tools, Services, and to provide video content on our Service. We use the unbranded version of the YouTube embedded video player (YouTube Player) to display some of our YouTube video content on www.telegraph.co.uk. The YouTube Player is made available to you by YouTube and your use is subject to YouTube’s Terms of Service available here: Terms of Service (youtube.com). YouTube may collect usage data when you interact or engage with the YouTube Player on www.telegraph.co.uk and the collection of such data is governed by Google’s privacy policy available here: Privacy Policy – Privacy & Terms – Google. Use caution when dealing with third parties and consult their terms of use and privacy policies. We take no responsibility for Third-Party Services. If you are accessing or using the Service through Apple, Android, or any other platform, these are Third-Party Services. If you access our Apps via Apple, click here for Additional Terms and conditions that are applicable to you and are incorporated into the Terms by this reference.
TERMS APPLICABLE FOR APPLE IOS.
(i) To the extent that you are accessing the Service through an Apple mobile application, you acknowledge that these Terms are entered into between you and Telegraph and, that Apple, Inc. (“Apple”) is not a party to these Terms other than as third-party beneficiary as contemplated below.
(ii) The license granted to you by Telegraph under the Terms is subject to the permitted Usage Rules set forth in the App Store Terms of Use (see: http://www.apple.com/legal/itunes/us/terms.html) and any third-party terms of agreement applicable to the Service.
(iii) You acknowledge that Telegraph, and not Apple, is responsible for providing the Service and Content thereof.
(iv) You acknowledge that Apple has no obligation whatsoever to furnish any maintenance or any support services to you with respect to the Service.
(v) To the maximum extent not prohibited by applicable law, Apple will have no other warranty obligation whatsoever with respect to the Service.
(vi) Notwithstanding anything to the contrary herein, and subject to the terms and conditions of the Terms, you acknowledge that, solely as between Apple and Telegraph, Telegraph, and not Apple is responsible for addressing any claims you may have relating to the Service, or your possession and/or use thereof, including, but not limited, to: (i) product liability claims; (ii) any claim that the Service fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection or similar legislation.(vii) Further, you agree that if the Service, or your possession and use of the Service, infringes on a third-party’s Intellectual Property rights, you will not hold Apple responsible for the investigation, defense, settlement and discharge of any such Intellectual Property infringement claims.
(viii) You acknowledge and agree that Apple, and Apple’s subsidiaries, are third-party beneficiaries of the Terms, and that, upon your acceptance of the terms and conditions of the Terms, Apple will have the right (and will be deemed to have accepted the right) to enforce the Terms against you as a third-party beneficiary thereof.
(ix) When using the Service, you agree to comply with any and all third-party terms that are applicable to any platform, website, technology or service that interacts with the Service.(x) Your use of real time route guidance on the Service (if any) is at your sole risk. Location data may not be accurate.Return to navigation
2. CONTENT YOU SUBMIT AND COMMUNITY GUIDELINES
A. User-Generated Content.
(i) General. Telegraph may now, or in the future, offer users of the Service the opportunity to create, build, post, upload, display, publish, distribute, transmit, broadcast, or otherwise make available on or submit through the Service, or on or in response to our pages or posts on any third-party platforms or in connection with any of our promotions by any media or manner, or otherwise submit to us (e.g., on our Facebook or other social media pages, in response to our tweets, through a sweepstakes or contest, or by otherwise sending it to us) (collectively, “submit”) messages, text, illustrations, files, images, graphics, photos, comments, responses, sounds, music, videos, information, content, ratings, reviews, data, questions, suggestions, personally identifiable information, or other information or materials and the ideas contained therein (collectively, but excluding Telegraph Licensed Elements included therein, “User-Generated Content” or “UGC”). You may submit UGC through your profile, forums, blogs, message boards, social networking environments, content creation and posting tools, gameplay, social communities, contact us tools, email, and other communications functionality. Except to the extent of the rights and license you grant in these Terms and, subject to any applicable Additional Terms, you retain whatever legally cognizable right, title, and interest that you have in your UGC.
(ii) Non-Confidentiality of Your User-Generated Content. Except as otherwise described in the Service’s posted Privacy Policy, or any applicable Additional Terms, you agree that (a) your UGC will be treated as non-confidential and non-proprietary by us – regardless of whether you mark them “confidential,” “proprietary,” or the like – and will not be returned, and (b) to the maximum extent not prohibited by applicable law, Telegraph does not assume any obligation of any kind to you or any third-party with respect to your UGC. Upon request, you will provide documentation necessary to authenticate rights to such content and verify your compliance with these Terms or any applicable Additional Terms. You acknowledge that the Internet and mobile communications may be insecure and subject to breaches of security; according, you acknowledge and agree that your UGC is submitted at your own risk. In your communications with Telegraph, please keep in mind that we do not seek any unsolicited ideas or materials for products or services, or even suggested improvements to products or services, including, without limitation, ideas, concepts, inventions, or designs for music, websites, apps, books, scripts, screenplays, motion pictures, television shows, theatrical productions, software or otherwise (collectively, “Unsolicited Ideas and Materials”). Any Unsolicited Ideas and Materials you submit are deemed UGC and licensed to us as set forth below. In addition, Telegraph retains all of the rights held by members of the general public with regard to your Unsolicited Ideas and Materials. Telegraph’s receipt of your Unsolicited Ideas and Materials is not an admission by Telegraph of their novelty, priority, or originality, and it does not impair Telegraph’s right to contest existing or future Intellectual Property rights relating to your Unsolicited Ideas and Materials.
(iii) License to Telegraph of Your UGC. Except as otherwise described in any applicable Additional Terms (such as a promotion’s official rules), which specifically govern the submission of your UGC, or in our Privacy Policy, you hereby grant Telegraph, the non-exclusive, unrestricted, unconditional, unlimited, worldwide, irrevocable, perpetual, and cost-free right and license to use, copy, record, distribute, reproduce, disclose, sell, re-sell, sublicense (through multiple levels), display, publicly perform, transmit, publish, broadcast, translate, make derivative works of, and otherwise use and exploit in any manner whatsoever, all or any portion of your UGC (and derivative works thereof), for any purpose whatsoever in all formats, on or through any means or medium now known or hereafter developed, and with any technology or devices now known or hereafter developed, and to advertise, market, and promote the same. Without limitation, the granted rights include the right to:
(a) configure, host, index, cache, archive, store, digitize, compress, optimize, modify, reformat, edit, adapt, publish in searchable format, and remove such UGC and combine same with other materials, and
(b) use any ideas, concepts, know-how, or techniques contained in any UGC for any purposes whatsoever, including developing, producing, and marketing products and/or services. You understand that in exercising such rights metadata, notices and content may be removed or altered, including copyright management information, and you consent thereto and represent and warrant you have all necessary authority to do so. In order to further effect the rights and license that you grant to Telegraph to your UGC, you also, as permitted by applicable law, hereby grant to Telegraph, and agree to grant to Telegraph, the unconditional, perpetual, irrevocable right to use and exploit your name, persona, and likeness in connection with any UGC, without any obligation or remuneration to you. Except as prohibited by law, you hereby waive, and you agree to waive, any moral rights (including attribution and integrity) that you may have in any UGC, even if it is altered or changed in a manner not agreeable to you. To the extent not waivable, you irrevocably agree not to exercise such rights (if any) in a manner that interferes with any exercise of the granted rights. You understand that you will not receive any fees, sums, consideration, or remuneration for any of the rights granted in this Section
2. A(iii).(iv) Telegraph’s Exclusive Right to Manage Our Service. Telegraph may, but will not have any obligation to, review, monitor, display, post, store, maintain, accept, or otherwise make use of, any of your UGC, and Telegraph may, in its sole discretion, reject, delete, move, re-format, remove or refuse to post or otherwise make use of UGC without notice or any liability to you or any third-party in connection with our operation of UGC venues in an appropriate manner, such as to enhance accessibility of UGC, address copyright infringement and protect Users from harmful UGC. Without limitation, we may, but do not commit to, address content that comes to our attention that we believe is offensive, obscene, lewd, lascivious, filthy, violent, harassing, threatening, abusive, illegal or otherwise objectionable or inappropriate, or to enforce the rights of third parties or these Terms or any applicable Additional Terms. Such UGC submitted by you or others need not be maintained on the Service by us for any period of time, and you will not have the right, once submitted, to access, archive, maintain, change, remove, or otherwise use such UGC on the Service or elsewhere, except that California minors have certain rights to have certain content about them that they have themselves posted on the Service prospectively removed from public display as provided for in the Privacy Policy
(v) Representations and Warranties Related to Your UGC. Each time you submit any UGC, you represent and warrant that you are at least the age of majority in the jurisdiction in which you reside and are the parent or legal guardian, or have all proper consents from the parent or legal guardian, of any minor who is depicted in or contributed to any UGC you submit, and that, as to that UGC, (a) you are the sole author and owner of the Intellectual Property and other rights to the UGC, or you have a lawful right to submit the UGC and grant Telegraph the rights to it that you are granting by these Terms and any applicable Additional Terms, all without any Telegraph obligation to obtain consent of any third-party and without creating any obligation or liability of Telegraph; (b) the UGC is accurate; (c) the UGC does not and, as to Telegraph’s permitted uses and exploitation set forth in these Terms, will not infringe any Intellectual Property or other right of any third-party; and (d) the UGC will not violate these Terms or any applicable Additional Terms, or cause injury or harm to any person.
(vi) Enforcement. Telegraph has no obligation to monitor or enforce your Intellectual Property rights to your UGC, but you grant us the right to protect and enforce our rights to your UGC, including initiating actions in your name and on your behalf (at Telegraph’s cost and expense, to which you hereby consent and irrevocably appoint Telegraph as your attorney-in-fact, with the power of substitution and delegation, which appointment is coupled with an interest).
B. Telegraph Community Guidelines. As a user of the Service, the Telegraph Community Guidelines (“Guidelines”) are here to help you understand the conduct that is expected of members of the Service’s online communities (“Communities”). These Guidelines are Additional Terms. (i) Nature of Guidelines. Your participation in the Communities is subject to all of the Terms, including the Guidelines.If you submit UGC that Telegraph reasonably believes violates the Guidelines, then we may take any legally available action that we deem appropriate, in our sole discretion. However, we are not obligated to take any action not required by applicable law. We may require, at any time, proof of the permissions referred to above in a form acceptable to us. Failure to provide such proof may lead to, among other things, the UGC in question being removed from the Service.(ii) Your Interactions With Other Users; Disputes. You are solely responsible for your interaction with other users of the Service, whether online or offline. We are not responsible or liable for the conduct or content of any user. We reserve the right, but have no obligation, to monitor or become involved in disputes between you and other users. Exercise common sense and your best judgment in your interactions with others (e.g., when you submit any personal or other information) and in all of your other online activities.C. Appropriate Content and Alerting Us of Violations. We expect UGC to be appropriate for a general audience, but do not undertake to monitor it, and you consent to potentially encountering content you find offensive or inappropriate. We may include venue and content rules as Additional Terms. If you discover any content that violates these Terms or any applicable Additional Terms, such as the Telegraph Community Guidelines, then you may report it here. For alleged infringements of Intellectual Property rights, see Section 5. EU and EEA-based users can submit notices of illegal content found within our comment sections, in accordance with the Digital Services Act, by visiting this page.
3. SERVICE AND CONTENT USE RESTRICTIONS.
A. Service Use Restrictions.
You agree that you will not: (i) use the Service for any political or commercial purpose (including, without limitation, for purposes of advertising, soliciting funds, collecting product prices, and selling products); (ii) use any meta tags or any other “hidden text” utilizing any Intellectual Property; (iii) engage in any activities through or in connection with the Service that seek to attempt to or do harm any individuals or entities or are unlawful, offensive, obscene, lewd, lascivious, filthy, violent, threatening, harassing, or abusive, or that violate any right of any third-party, or are otherwise objectionable to Telegraph; (iv) decompile, disassemble, reverse engineer, or attempt to reconstruct, identify, or discover any source code, underlying ideas, underlying user interface techniques, or algorithms of the Service by any means whatsoever or modify any Service source or object code or any Software or other products, services, or processes accessible through any portion of the Service; (v) engage in any activity that interferes with a user’s access to the Service or the proper operation of the Service, or otherwise causes harm to the Service, Telegraph, or other users of the Service; (vi) interfere with or circumvent any security feature (including any digital rights management mechanism, device or other content protection or access control measure) of the Service or any feature that restricts or enforces limitations on use of or access to the Service, the Content, or the UGC; (vii) harvest or otherwise collect or store any information (including personally identifiable information about other users of the Service, including email addresses, without the express consent of such users); (viii) attempt to gain unauthorized access to the Service, other computer systems or networks connected to the Service, through password mining or any other means; or (ix) otherwise violate these Terms or any applicable Additional Terms.
B. Content Use Restrictions.
You also agree that, in using the Service, you: (i) will not monitor, gather, copy, or distribute the Content (except as may be a result of standard search engine activity or use of a standard browser) on the Service by using any robot, rover, “bot”, spider, scraper, crawler, spyware, engine, device, software, extraction tool, or any other automatic device, utility, or manual process of any kind; (ii) will not frame or utilize framing techniques to enclose any such content (including any images, text, or page layout); (iii) will keep intact all Trademark, copyright, and other Intellectual Property and other notices contained in such content; (iv) will not use such content in a manner that suggests an unauthorized association with any of our or our licensors’ products, services, or brands; (v) will not make any modifications to such content (other than to the extent of your specifically permitted use of the Telegraph Licensed Elements, if applicable); (vi) will not copy, modify, reproduce, archive, sell, lease, rent, exchange, create derivative works from, publish by hard copy or electronic means, publicly perform, display, disseminate, distribute, broadcast, retransmit, circulate or transfer to any third-party or on any third-party application or website, or otherwise use or exploit such content in any way for any purpose except as specifically permitted by these Terms or any applicable Additional Terms or with the prior written consent of an officer of Telegraph or, in the case of content from a licensor, the owner of the content; and (vii) will not insert any code or product to manipulate such content in any way that adversely affects any user experience or the Service.C. Availability of Service and Content. Telegraph, in its sole discretion without advance notice or liability, may immediately suspend or terminate the availability of the Service and/or Content (and any elements and features of them), in whole or in part, for any reason, in Telegraph’s sole discretion, and without advance notice or liability.
4. CREATING AN ACCOUNT.
A. If you register with us or create an account, you are solely responsible and liable for the security and confidentiality of your access credentials and for restricting access to your Device and for all activity under your account. Usernames and passwords must be personal and unique that do not violate the rights of any person or entity, and not offensive. We may reject the use of any password, username, or email address for any reason in our sole discretion. You are solely responsible for your registration information and for updating and maintaining it. You will immediately notify us here of any unauthorized use of your account, password, or username, or any other breach of security, but will remain responsible for any unauthorized use thereafter. You will not sell, transfer, or assign your account or any account rights.B. Accounts may only be set up by an authorized representative of the individual that is the subject of the account and who is of the age of majority. We do not review accounts for authenticity, and are not responsible for any unauthorized accounts that may appear on the Service. For any dispute as to account creation or authenticity, we shall have the sole right, but are not obligated, to resolve such dispute as we determine appropriate, without notice.
5. PROCEDURE FOR ALLEGING COPYRIGHT INFRINGEMENT.
If you are a copyright owner and believe infringing use of your content is on our Service, or you are a User that has received notice that you have posted allegedly copyright infringing content on our Service, click here.A. DMCA Notice. Telegraph asks our users to respect the intellectual property rights of others. It is our policy to respond appropriately to clear notices of alleged copyright infringement, as set forth more fully below. In Telegraph’s sole discretion, Telegraph may remove content that may be infringing on another person’s intellectual property rights with or without notice to the potential infringer. In accordance with the U.S. Digital Millennium Copyright Act (“DMCA”) and other applicable law, Telegraph has adopted a policy of terminating, in appropriate circumstances, users who are deemed to be repeat infringers. B. If we remove or disable access in response to a DMCA Copyright Infringement Notice, we will make a good faith attempt to contact the owner or administrator of the affected content so that they may make a counter-notification. If you own a copyright in a work (or represent such a copyright owner) and believe that your (or such owner’s) copyright in that work has been infringed by an improper posting or distribution of it via the Service, then you may send us a written notice that includes all of the following:
(i) a legend or subject line that says: “DMCA Copyright Infringement Notice”;
(ii) a description of the copyrighted work that you claim has been infringed or, if multiple copyrighted works are covered by a single notification, a representative list of such works;
(iii) a description of where the material that you claim is infringing or is the subject of infringing activity is located that is reasonably sufficient to permit us to locate the material (please include the full URL of the page(s) on the Service on which the material appears);
(iv) your full name, address, telephone number, and email address;
(v) a statement by you that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law;
(vi) a statement by you, made under penalty of perjury, that all the information in your notice is accurate, and that you are the copyright owner (or, if you are not the copyright owner, then your statement must indicate that you are authorized to act on the behalf of the owner of an exclusive right that is allegedly infringed); and
(vii) your electronic or physical signature.
Telegraph will only respond to DMCA Notices that it receives by email or mail at the addresses below:
By Email: grouplegal@telegraph.co.uk
By Mail: Telegraph Media Group 1015 15th Street NW, Suite 600Washington, DC 20005
For more information contact us by email.It is often difficult to determine if your copyright has been infringed. Telegraph may elect to not respond to DMCA Notices that do not substantially comply with all of the foregoing requirements, and Telegraph may elect to remove allegedly infringing material that comes to its attention via notices that do not substantially comply with the DMCA.
Please note that the DMCA provides that any person who knowingly materially misrepresents that material or activity is infringing may be subject to liability.We may send the information that you provide in your notice to the person who provided the allegedly infringing work. That person may elect to send us a DMCA Counter-Notification.Without limiting Telegraph’s other rights, Telegraph may, in appropriate circumstances, terminate a repeat infringer’s access to the Service and any other website owned or operated by Telegraph. C. Counter-Notification. If access on the Service to a work that you submitted to Telegraph is disabled or the work is removed as a result of a DMCA Copyright Infringement Notice, and if you believe that the disabled access or removal is the result of mistake or misidentification, then you may send us a DMCA Counter-Notification to the addresses above.
Your DMCA Counter-Notification should contain the following information:
(i) a legend or subject line that says: “DMCA Counter-Notification”;
(ii) a description of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled (please include the full URL of the page(s) on the Service from which the material was removed or access to it disabled);
(iii) a statement under penalty of perjury that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled;
(iv) your full name, address, telephone number, email address, and the username of your Account;
(v) a statement that you consent to the jurisdiction of the Federal District Court for the judicial district in which your address is located (or, if the address is located outside the U.S.A., to the jurisdiction of the United States District Court for the Central District of California), and that you will accept service of process from the person who provided DMCA notification to us or an agent of such person; and
(vi) your electronic or physical signature.
Please note that the DMCA provides that any person who knowingly materially misrepresents that material or activity was removed or disabled by mistake or misidentification may be subject to liability.
If we receive a DMCA Counter-Notification, then we may replace the material that we removed (or stop disabling access to it) in not less than ten (10) and not more than fourteen (14) business days following receipt of the DMCA Counter-Notification. However, we will not do this if we first receive notice at the addresses above that the party who sent us the DMCA Copyright Infringement Notice has filed a lawsuit asking a court for an order restraining the person who provided the material from engaging in infringing activity relating to the material on the Service.
You should also be aware that we may forward the Counter-Notification to the party who sent us the DMCA Copyright Infringement Notice.
6. NOTICES, QUESTIONS AND CUSTOMER SERVICE.
You agree that we may give you notices or otherwise respond to you by mail or to your email (if we have it on file) or in any other manner reasonably elected by us. All legal notices to us must be sent to: T
elegraph Media Group Holdings Limited, 111 Buckingham Palace Road, London, SW1W 0DT, United Kingdom.
If you have a question regarding the Service, you may contact Telegraph Customer Support by sending an email here. You acknowledge that we have no obligation to provide you with customer support of any kind and that customer service personnel cannot change or waive Terms or applicable Additional Terms.
7. PRODUCT SPECIFICATIONS; PRICING; TYPOGRAPHICAL ERRORS.
We strive to accurately describe our products or services offered on the Service; however, we do not warrant that such specifications, pricing, or other content on the Service is complete, accurate, reliable, current, or error-free. As permitted by applicable law, Telegraph shall have the right to refuse or cancel any orders in its sole discretion. Your orders are offers to purchase subject to our acceptance, which we may reject or cancel subject to refund. If we charged your credit or other account prior to rejection or cancellation, we will reissue credit to your account. Additional Terms may apply. If a product you purchased or accepted from Telegraph is not as described, as permitted by applicable law, your sole remedy is to return it, to cancel the purchase and receive a credit for the purchase price.
8. ARBITRATION AND DISPUTE TERMS.
A. Forum Selection/Jurisdiction. Jurisdiction and venue for any controversy, allegation, or claim arising out of or relating to the Service, the Content, your UGC, these Terms, or any applicable Additional Terms, (collectively, “Dispute”) shall be in New York, New York. Each party submits to personal jurisdiction and venue in New York, New York for any and all purposes.B. Pre-Arbitration Notification. Telegraph and you agree that it would be advantageous to discuss and hopefully resolve any Disputes before formal proceedings are initiated; provided, however, that Telegraph need not do so in circumstances where its claims of Intellectual Property rights are concerned (“IP Disputes,” with all other disputes referred to as “General Disputes”). The party making a claim – whether you or Telegraph – shall send a letter to the other side briefly summarizing the claim and the request for relief. If Telegraph is making a claim, the letter shall be sent, via email, to the email address listed in your Telegraph account, if applicable. If no such information exists or if such information is not current, then we have no notification or delay obligations under this Section 8.
B. If you are making a claim, the letter shall be sent to Telegraph Media Group Holdings Limited, 111 Buckingham Palace Road, London, SW1W 0DT, United Kingdom (Attn: General Counsel).
If the Dispute is not resolved within sixty (60) days after notification, the claimant may proceed to initiate proceedings as set forth in this Section 8. Either you or Telegraph, however, may seek provisional remedies (such as preliminary injunctive relief, subject to Section 8.D) before the expiration of this sixty (60)-day period.
C. Arbitration of Claims.
Unless you give us notice of opt-out within five (5) business days of your first use of the Service, addressed to: Telegraph Media Group Holdings Limited, 111 Buckingham Palace Road, London, SW1W 0DT, United Kingdom (Attn: General Counsel), all actions or proceedings arising in connection with, touching upon or relating to any Dispute, or the scope of the provisions of this Section, shall be submitted to JAMS (www.jamsadr.com) for final and binding arbitration under its Comprehensive Arbitration Rules and Procedures if the matter in dispute is over $250,000 or under its Streamlined Arbitration Rules and Procedures if the matter in dispute is $250,000 or less, to be held in New York, New York, before a single arbitrator in accordance with the New York Civil Practice Law & Rules §§ 7501 et seq.
If the matter in dispute is between Telegraph and a consumer, the matter shall be submitted to JAMS in accordance with its Policy on Consumer Arbitration Pursuant to Pre-Dispute Clauses Minimum Standards of Procedural Fairness. The arbitrator shall be selected by mutual agreement of the parties or, if the parties cannot agree, then by striking from a list of arbitrators supplied by JAMS. We may have the right to pay the JAMS fees if required for arbitration to be enforceable. If you are a consumer you have the right to an in-person hearing. The arbitration shall be a confidential proceeding, closed to the general public; provided, however, that a party may disclose information relating to the arbitration proceedings to its and its affiliates’ lawyers, insurance providers, auditors and other professional advisers. The fact that there is a dispute between the parties that is the subject of arbitration shall be confidential to the same extent. The parties may engage in the discovery or exchange of non-privileged information relevant to the dispute. The arbitrator shall issue a written opinion stating the essential findings and conclusions upon which the arbitrator’s award is based. Neither party shall be entitled or permitted to commence or maintain any action in a court of law with respect to any matter in dispute until such matter shall have been submitted to arbitration as herein provided and then only for the enforcement of the arbitrator’s award; provided, however, that prior to the appointment of the arbitrator or for remedies beyond the jurisdiction of an arbitrator, at any time, either party may seek pendente lite relief (subject to the provisions of these Terms waiving or limiting that relief) in a court of competent jurisdiction in New York, New York or, if sought by Telegraph, such other court that may have jurisdiction over you, without thereby waiving its right to arbitration of the dispute or controversy under this Section; provided further, however, that the losing party shall have fifteen (15) business days after the issuance of the arbitrator’s decision to fully comply with such decision, after which the prevailing party may enforce such decision by a petition to the New York County Supreme Court or, in the case of you, such other court having jurisdiction over you, which may be made ex parte, for confirmation and enforcement of the award.
D. Additional Procedures for Multiple Case Filings. (i) Multiple Case Filings. You and we agree that these “Additional Procedures for Multiple Case Filings” in this Section 14 shall also apply if you or we are subject to twenty-five (25) or more individual arbitration demands of a substantially similar nature with the assistance of the same law firm, group of law firms, or organizations (“Multiple Case Filing”). For the avoidance of doubt, this includes where you choose to participate in a Multiple Case Filing against us; for example, where your counsel asserts your Dispute against us in a Multiple Case Filing. Please be aware that if you do so, the resolution of your Dispute might be delayed and ultimately proceed in court. You and we agree that as part of these procedures, the parties’ counsel shall meet and confer in good faith in an effort to resolve the Disputes, streamline procedures, address the exchange of information, modify the number of Disputes to be adjudicated, and conserve the parties’ and the arbitrator’s resources. The limitations period(s) applicable to each arbitration demand within a Multiple Case Filing, including any applicable statutes of limitations and the requirement to file within one (1) year, shall remain tolled from the time a party makes a pre-arbitration demand to the time when that party files the arbitration demand with the arbitration provider.
(ii) STAGE ONE: If at least twenty-five (25) disputes are submitted as part of the Multiple Case Filing, you and we shall select sixteen (16) Disputes (eight (8) per side) to proceed as cases in individual arbitrations (“Bellwether Arbitrations”) as part of this initial staged process. The number of Disputes to be selected to proceed in Stage One can be increased by agreement of counsel for the parties (and if there are fewer than 50 disputes, all shall proceed individually in Stage One). While the Bellwether Arbitrations are adjudicated, no other demand for arbitration that is part of the Multiple Case Filing may be processed, administrated, or adjudicated, and no filing or other administrative costs for such a demand for arbitration shall be due from either party to the arbitration provider. If, contrary to this provision, a party prematurely files non-Bellwether Arbitrations with the arbitration provider, the parties agree that the arbitration provider shall hold those demands in abeyance. Following resolution of the Bellwether Arbitrations, the parties shall participate in a global mediation of all the remaining demands from the Multiple Case Filings, with a mediator jointly selected by counsel of the parties in an effort to resolve the remaining Disputes that are a part of the Multiple Case Filing.
(iii) STAGE TWO: If the remaining Disputes from the Multiple Case Filings have not been resolved at the conclusion of Stage One, you and we shall select fifty (50) Disputes (twenty-five (25) per side) to proceed as cases in individual arbitrations as Bellwether Arbitrations as part of Stage Two. The number of Disputes to be selected to proceed as part of Stage Two can be increased by agreement of counsel for the parties (and if there are fewer than 50 Disputes, all shall proceed individually in Stage Two). The remaining Disputes shall not be filed or deemed filed in arbitration nor shall any arbitration fees be assessed or collected in connection with those claims. After this second set of staged proceedings, the parties shall engage in a global mediation session of all remaining Disputes from the Multiple Case Filing with a retired mediator jointly selected by counsel in an effort to resolve the remaining Disputes (as informed by the adjudications of cases in Stages One and Two). Upon the completion of the mediation set forth in Stage Two, each remaining Dispute (if any) that is not settled or not withdrawn shall be opted out of arbitration and may proceed in a court of competent jurisdiction consistent with the remainder of these Terms. Notwithstanding the foregoing, counsel for the parties may mutually agree in writing to proceed with the adjudication of some or all of the remaining disputes in individual arbitrations consistent with the process set forth in Stage Two (except Disputes shall be randomly selected and mediation shall be elective by agreement of counsel) or through another mutually agreeable process. A court of competent jurisdiction shall have the authority to enforce the Additional Procedures for Multiple Case Filings, including the power to enjoin the filing or prosecution of arbitrations and the assessment or collection of arbitration fees. The Additional Procedures for Multiple Case Filings provision and each of its requirements are essential parts of this Arbitration Agreement. If, after exhaustion of all appeals, either an arbitrator or a court of competent jurisdiction decides that the Additional Procedures for Multiple Case Filings apply to your dispute and are not enforceable, then your dispute shall not proceed in arbitration and shall only proceed in a court of competent jurisdiction consistent with the remainder of the Terms.(iv) Timing of Bellwether Arbitrations. The parties shall work in good faith with the arbitrator to complete each Bellwether Arbitration (in each respective stage, i.e., Stage One, Stage Two, and, if agreed, subsequent stages) within one hundred and twenty (120) calendar days of its initial pre-hearing conference. The parties agree that the Bellwether Arbitration process is designed to achieve an overall faster, more efficient, and less costly mechanism for resolving Multiple Case Filings, including the claims of individuals who are not selected for a Bellwether Arbitration.E. Limitation on Injunctive Relief.
AS PERMITTED BY APPLICABLE LAW, IF YOU CLAIM THAT YOU HAVE INCURRED ANY LOSS, DAMAGES, OR INJURIES IN CONNECTION WITH YOUR USE OF THE SERVICE, THEN THE LOSSES, DAMAGES, AND INJURIES WILL NOT BE DEEMED IRREPARABLE OR SUFFICIENT TO ENTITLE YOU TO AN INJUNCTION OR TO OTHER EQUITABLE RELIEF OF ANY KIND. THIS MEANS (WITHOUT LIMITATION) THAT, IN CONNECTION WITH YOUR CLAIM, YOU AGREE THAT YOU WILL NOT SEEK, AND THAT YOU WILL NOT BE PERMITTED TO OBTAIN, ANY COURT OR OTHER ACTION THAT MAY INTERFERE WITH OR PREVENT THE DEVELOPMENT OR EXPLOITATION OF ANY WEBSITE, APPLICATION, CONTENT, UGC, PRODUCT, SERVICE, OR INTELLECTUAL PROPERTY OWNED, LICENSED, USED, OR CONTROLLED BY ANY TELEGRAPH PARTY (DEFINED BELOW) (INCLUDING YOUR LICENSED UGC) OR A LICENSOR OF ANY TELEGRAPH PARTY. F. Governing Law.
These Terms and any applicable Additional Terms, General Disputes and IP Disputes, and any other claim brought by you against Telegraph or by Telegraph against you pursuant to this Section, or otherwise related to the Service, Content, Telegraph Licensed Elements, UGC or other Telegraph products or services, will be governed by, construed, and resolved in accordance with, the laws of the State of New York, U.S.A., without regard to its conflicts of law provisions that might apply the laws of another jurisdiction. This Section shall be governed solely by the Federal Arbitration Act, 9 U.S.C. §1, et seq., and not by the law of any state, and is enforceable pursuant to its terms on a self-executing basis. You and Telegraph agree that we intend that this Section satisfies the “writing” requirement of the Federal Arbitration Act. This Section 8 can only be amended by mutual agreement. Either party may seek enforcement of this Section 8 in any court of competent jurisdiction. The arbitrator shall determine any and all challenges to the arbitrability of a claim. G. Class Action Waiver. As permitted by applicable law, both you and Telegraph waive the right to bring any Dispute as a class, consolidated, representative, collective, or private attorney general action, or to participate in a class, consolidated, representative, collective, or private attorney general action regarding any Dispute brought by anyone else. Notwithstanding any provision in the JAMS Comprehensive Arbitration Rules and Procedures to the contrary, the arbitrator shall not have the authority or any jurisdiction to hear the arbitration as a class, consolidated, representative, or private attorney general action or to consolidate, join, or otherwise combine the Disputes of different persons into one proceeding. Notwithstanding the arbitration provision set forth above, if the provision regarding waiver of class, collective, representative, and private attorney general claims of this Section is found to be void or otherwise unenforceable, any such class, collective, representative, or private attorney general claims must be heard and determined through an appropriate court proceeding, and not in arbitration.H. Jury Waiver.
AS PERMITTED BY APPLICABLE LAW, THE PARTIES HEREBY WAIVE THEIR RIGHT TO JURY TRIAL WITH RESPECT TO ALL CLAIMS AND ISSUES ARISING UNDER, IN CONNECTION WITH, TOUCHING UPON OR RELATING TO THESE TERMS, THE BREACH THEREOF AND/OR THE SCOPE OF THE PROVISIONS OF THIS SECTION, WHETHER SOUNDING IN CONTRACT OR TORT, AND INCLUDING ANY CLAIM FOR FRAUDULENT INDUCEMENT THEREOF. I. Small Claims Matters. Notwithstanding the foregoing, either of us may bring qualifying claim of General Dispute (but not IP Disputes) in small claims court, subject to Section 8.J. The provisions of this Section shall supersede any inconsistent provisions of any prior agreement between the parties. This Section shall remain in full force and effect notwithstanding any termination of your use of the Service or these Terms.
9. DISCLAIMER OF REPRESENTATIONS AND WARRANTIES.A. AS PERMITTED BY APPLICABLE LAW, YOUR ACCESS TO AND USE OF THE SERVICE IS AT YOUR SOLE RISK AND THE SERVICE IS PROVIDED ON AN “AS IS”, “AS AVAILABLE”, AND “WITH ALL FAULTS” BASIS.
To the fullest extent permissible by applicable law, Telegraph and their direct and indirect parents, subsidiaries, affiliates, and each of their respective employees, directors, members, managers, shareholders, agents, vendors, licensors, licensees, contractors, customers, successors, and assigns (collectively, “Telegraph Parties”) hereby disclaim and make no representations, warranties, endorsements, or promises, express or implied, in connection with, or otherwise directly or indirectly related to, without limitation, the Service, Content, Telegraph Licensed Elements, UGC or other Telegraph products or services, except as set forth in subsection C, below.
B. EXCEPT FOR ANY SPECIFIC WARRANTIES PROVIDED HEREIN, OR IN APPLICABLE ADDITIONAL TERMS, OR AS OTHERWISE REQUIRED BY APPLICABLE LAW, TELEGRAPH PARTIES HEREBY FURTHER DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING THE WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT OR MISAPPROPRIATION OF INTELLECTUAL PROPERTY RIGHTS OF THIRD PARTIES, TITLE, CUSTOM, TRADE, QUIET ENJOYMENT, SYSTEM INTEGRATION AND FREEDOM FROM COMPUTER VIRUS. C. NOTWITHSTANDING THE FOREGOING, THIS SECTION DOES NOT EXPAND OR LIMIT (I) ANY EXPRESS, WRITTEN PRODUCT WARRANTY OR RELATED DISCLAIMERS THAT ARE PROVIDED BY TELEGRAPH PARTIES OR THEIR SUPPLIERS WITH REGARD TO A PHYSICAL PRODUCT SOLD BY TELEGRAPH PARTIES TO YOU, OR ANY WARRANTY ON A PHYSICAL PRODUCT TO THE EXTENT REQUIRED BY APPLICABLE LAW; (II) TELEGRAPH PARTIES’ LIABILITY FOR PERSONAL INJURY TO YOU CAUSED BY TELEGRAPH PARTIES TO THE EXTENT NOT WAIVABLE OR CANNOT BE LIMITED UNDER APPLICABLE LAW; OR (III) ANY CAUSE OF ACTION YOU MAY HAVE AGAINST TELEGRAPH PARTIES THAT IS NOT WAIVABLE OR CANNOT BE LIMITED UNDER APPLICABLE LAW.10. LIMITATIONS OF OUR LIABILITY.A. AS PERMITTED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES WILL ANY TELEGRAPH PARTIES BE RESPONSIBLE OR LIABLE FOR ANY LOSS OR DAMAGES OF ANY KIND, including personal injury or death or for any direct, indirect, economic, exemplary, special, punitive, incidental, or consequential losses or damages of any kind, including without limitation loss of profits, in connection with, or otherwise directly or indirectly related to, without limitation, the Service, Content, Telegraph Licensed Elements, UGC or other Telegraph products or services, except, to the extent not waivable under applicable law, for direct damages for personal injury caused by a physical product manufactured, sold or provided by Telegraph.B. The foregoing limitations of liability will apply even if any of the events or circumstances were foreseeable and even if Telegraph Parties were advised of or should have known of the possibility of such losses or damages, regardless of whether you bring an action based in contract, negligence, strict liability, or tort (including whether caused, in whole or in part, by negligence, acts of god, telecommunications failure, or destruction of the Service).
C. AS PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL TELEGRAPH PARTIES’ TOTAL LIABILITY TO YOU, FOR ALL POSSIBLE DAMAGES, LOSSES, AND CAUSES OF ACTION IN CONNECTION WITH YOUR ACCESS TO AND USE OF THE SERVICE AND YOUR RIGHTS UNDER THESE TERMS, EXCEED AN AMOUNT EQUAL TO THE AMOUNT YOU HAVE PAID TELEGRAPH IN CONNECTION WITH THE TRANSACTION(S) THAT UNDERLIE THE CLAIM(S). D. NOTWITHSTANDING THE FOREGOING, THIS SECTION DOES NOT EXPAND OR LIMIT (I) ANY EXPRESS, WRITTEN PRODUCT WARRANTY OR RELATED DISCLAIMERS THAT ARE PROVIDED BY TELEGRAPH PARTIES OR THEIR SUPPLIERS WITH REGARD TO A PHYSICAL PRODUCT SOLD BY TELEGRAPH PARTIES TO YOU, OR ANY WARRANTY ON A PHYSICAL PRODUCT TO THE EXTENT REQUIRED BY APPLICABLE LAW; (II) TELEGRAPH PARTIES’ LIABILITY FOR PERSONAL INJURY TO YOU CAUSED BY TELEGRAPH PARTIES TO THE EXTENT NOT WAIVABLE OR CANNOT BE LIMITED UNDER APPLICABLE LAW; OR (III) ANY CAUSE OF ACTION YOU MAY HAVE AGAINST TELEGRAPH PARTIES THAT IS NOT WAIVABLE OR CANNOT BE LIMITED UNDER APPLICABLE LAW.11. UPDATES TO TERMS.It is your responsibility to review the posted Terms and any applicable Additional Terms each time you use the Service (at least prior to each transaction or submission).
EACH TIME YOU SIGN IN TO OR OTHERWISE USE THE SERVICE YOU ARE ENTERING INTO A NEW AGREEMENT WITH US ON THE THEN APPLICABLE TERMS AND CONDITIONS AND YOU AGREE THAT WE MAY NOTIFY YOU OF NEW TERMS BY POSTING THEM ON THE SERVICE (OR IN ANY OTHER REASONABLE MANNER OF NOTICE WHICH WE ELECT), AND THAT YOUR USE OF THE SERVICE AFTER SUCH NOTICE CONSTITUTES YOUR GOING FORWARD AGREEMENT TO THE NEW TERMS FOR YOUR NEW USE AND TRANSACTIONS.
Any new Terms or Additional Terms will be effective as to new use and transactions as of the time that we post them, or such later date as may be specified in them or in other notice to you. In the event any notice to you of new, revised, or additional terms is determined by a tribunal to be insufficient, the prior agreement shall continue until sufficient notice to establish a new agreement occurs. You can reject any new, revised or additional terms by discontinuing use of the Service.12.
GENERAL PROVISIONS.
A. Telegraph’s Consent or Approval. As to any provision in these Terms or any applicable Additional Terms that grants Telegraph a right of consent or approval, or permits Telegraph to exercise a right in its “sole discretion,” Telegraph may exercise that right in its sole and absolute discretion. No Telegraph consent or approval may be deemed to have been granted by Telegraph without being in writing and signed by an officer of Telegraph.
B. Consent to Electronic Contacting and Receiving Electronic Records. When you use our Service, including signing up to receive email or text messages, you consent to receive electronic records from us and consent to us contacting you electronically. We will try to promptly respond to all inquiries, but we are not obligated to do so. You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. You agree that any time you electronically transact, agree or consent via the Service it is intended to be an electronic signature which binds you as if you had signed on paper. You agree that your use of the Service, other than to read the Terms (or Additional Terms) and Privacy Policy, constitutes agreement to the Terms, and any applicable Additional Terms, then posted without further action by you. In order to withdraw your consent, update your contact information, or obtain paper copies of electronic records, you must contact us as outlined in Section 6, and stop using the Service. If you withdraw your consent, you will be removed from any email or text message program. If there is a cost to provide you with paper copies of electronic records, we will disclose that to you prior to sending you electronic records. Your consent to receive electronic records applies to your use of the Service, including any email or text message programs. Your devices must be able to review websites and electronic documents, receive email, or receive text messages to receive electronic records, depending on whether you are using the Service, or subscribing to email or text messages.
C. Indemnity. As permitted by applicable law, you agree to, and you hereby, defend (if requested by Telegraph), indemnify, and hold Telegraph Parties harmless from and against any and all claims, damages, losses, costs, investigations, liabilities, judgments, fines, penalties, settlements, interest, and expenses (including attorneys’ fees) that directly or indirectly arise from or are related to any claim, suit, action, demand, or proceeding made or brought against any Telegraph Party, or on account of the investigation, defense, or settlement thereof, arising out of or in connection with: (i) your UGC; (ii) your use of the Service and your activities in connection with the Service; (iii) your breach or alleged breach of these Terms or any applicable Additional Terms; (iv) your violation or alleged violation of any laws, rules, regulations, codes, statutes, ordinances, or orders of any governmental or quasi-governmental authorities in connection with your use of the Service or your activities in connection with the Service; (v) information or material transmitted through your Device, even if not submitted by you, that infringes, violates, or misappropriates any copyright, trademark, trade secret, trade dress, patent, publicity, privacy, or other right of any person or entity; (vi) any misrepresentation made by you; and (vii) Telegraph Parties’ use of the information that you submit to us (including your UGC) subject to our Privacy Policy (all of the foregoing, “Claims and Losses”). You will cooperate as fully required by Telegraph Parties, in the defense of any Claim and Losses. Notwithstanding the foregoing, Telegraph Parties retain the exclusive right to settle, compromise, and pay any and all Claims and Losses. Telegraph Parties reserve the right to assume the exclusive defense and control of any Claims and Losses. You will not settle any Claims and Losses without, in each instance, the prior written consent of an officer of a Telegraph Party. This section is not intended to limit any causes of action against us that you may have but are not waivable under applicable law.
D. Operation of Service; Availability of Products and Services; International Issues. Telegraph controls and operates the Service for users and visitors in the U.S.A., and makes no representation that the Service is appropriate or available for use beyond the U.S.A. If you use the Service from other locations, you are doing so on your own initiative and responsible for compliance with applicable local laws regarding your online conduct and acceptable content, if and to the extent local laws apply. For UK/EU visitors, please visit our General Terms and Conditions.
E. Export Controls. You are responsible for complying with all applicable trade regulations and laws both foreign and domestic. Except as authorized by U.S. law, you agree and warrant not to export or re-export the software to any county, or to any person, entity, or end-user subject to U.S. export controls or sanctions.
F. Severability; Interpretation. If any provision of these Terms, or any applicable Additional Terms, is for any reason deemed invalid, unlawful, void, or unenforceable by a court or arbitrator of competent jurisdiction, then that provision will be deemed severable from these Terms or the applicable Additional Terms, and the invalidity of the provision will not affect the validity or enforceability of the remainder of these Terms or the applicable Additional Terms. To the extent permitted by applicable law, you agree to waive and will waive, any applicable statutory and common law that may permit a contract to be construed against its drafter.
G. Investigations; Cooperation with Law Enforcement; Termination; Survival. As permitted by applicable law, Telegraph reserves the right, without limitation, to: (i) investigate any suspected breaches of its Service security or its information technology or other systems or networks, (ii) investigate any suspected breaches of these Terms and any applicable Additional Terms, (iii) use any information obtained by Telegraph in accordance with its U.S. Privacy Policy in connection with reviewing law enforcement databases or complying with applicable laws and use and/or disclose any information obtained by Telegraph to comply with law enforcement requests or legal requirements in accordance our U.S. Privacy Policy, (iv) involve and cooperate with law enforcement authorities in investigating any of the foregoing matters, (v) prosecute violators of these Terms and any applicable Additional Terms, and (vi) discontinue the Service, in whole or in part, or, suspend or terminate your access to it, in whole or in part, including any user accounts or registrations, at any time, without notice, for any reason and without any obligation to you or any third-party. Any suspension or termination will not affect your obligations to Telegraph under these Terms or any applicable Additional Terms. Upon suspension or termination of your access to the Service, or upon notice from Telegraph, all rights granted to you under these Terms or any applicable Additional Terms will cease immediately, and you agree that you will immediately discontinue use of the Service. The provisions of these Terms and any applicable Additional Terms, which by their nature should survive your suspension or termination will survive, including the rights and licenses you grant to Telegraph in these Terms, as well as the indemnities, releases, disclaimers, and limitations on liability and the provisions regarding jurisdiction, choice of law, no class action, and mandatory arbitration.H. Assignment. Telegraph may assign its rights and obligations under these Terms and any applicable Additional Terms, in whole or in part, to any party at any time without any notice.
These Terms and any applicable Additional Terms may not be assigned by you, and you may not delegate your duties under them, without the prior written consent of an officer of Telegraph. Prior to 29 September 2024, the Services governed by these Terms were provided by or on behalf of Telegraph Media Group Limited (company registration number 00451593).I. Complete Agreement; No Waiver. These Terms, and any applicable Additional Terms, reflect our complete agreement regarding the Service and supersede any prior agreements, representations, warranties, assurances or discussion related to the Service.
Except as expressly set forth in these Terms or any applicable Additional Terms, (i) no failure or delay by you or Telegraph in exercising any of rights, powers, or remedies under will operate as a waiver of that or any other right, power, or remedy, and (ii) no waiver or modification of any term of these Terms or any applicable Additional Terms will be effective unless in writing and signed by the party against whom the waiver or modification is sought to be enforced. J. California Consumer Rights and Notices. California residents can obtain information on our privacy practices, including how we comply with the California Online Privacy Protection Act and the California Shine the Light Act in our U.S. Privacy Policy.
In accordance with California Business and Professions Code Section 17538 et al., Telegraph’s return and refund policy is available here., the legal name under which Telegraph conducts business is Telegraph Media Group Holdings Limited, and Telegraph’s business address is Telegraph Media Group Holdings Limited, 111 Buckingham Palace Road, London, SW1W 0DT, United Kingdom (Attn: General Counsel). Within five (5) days of Telegraph’s receipt of your request, California residents may receive verification of this information by email by emailing us here.Residents of California are entitled to the following specific consumer rights information: you may contact the Complaint Assistance Unit of the Division of Consumer Services of the Department of Consumer Affairs by mail at: 1625 North Market Blvd., Suite N 112, Sacramento, California, 95834, or by telephone at (916) 445-1254. Hearing-impaired users can reach the Complaint Assistance Unit at TDD (800) 326-2297 or TDD (916) 322-1700.
Their website is located at: http://www.dca.ca.gov.California Transparency in Supply Chains Act 2010: Please see our Modern Slavery Statement.Any California residents under the age of eighteen (18) who have registered to use the Service, and who have posted content or information on the Service, can request that such information be removed from the Service by contacting us at the email or address set forth in Section 6 making such a request, stating that they personally posted such content or information and detailing where the content or information is posted.
We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished the post and archived copies of it may be stored by search engines and others that we do not control.California residents should visit our Privacy Policy to learn more about their California privacy rights.
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Your privacy is important to us. If you are visiting our Service from the United Kingdom, European Union, or other non-U.S. location, please review our General Privacy Policy. If you are visiting our Service from the United States, please review our U.S. Privacy Policy.UK and General Privacy and Cookie Policy
About us
The Telegraph Media Group is comprised of Telegraph Media Group Holdings Limited, Press Acquisitions Limited, and each of their respective subsidiaries. You can find our contact information here. The Chelsea Magazine Company Ltd (“CMC”) is also part of Telegraph Media Group of companies, and you can visit their dedicated privacy policy here
Telegraph Media Group is also responsible for our website www.telegraph.co.uk, and whether you browse as a guest or register with us we will collect different types of information about you: for example, for website functionality; to provide improved or personalised services to you; to help decide what kind of advertising you will see on the site; and, in accordance with your chosen preferences, to market goods or services to you. Please also see our website terms and conditions.
We are not responsible for the content or privacy practices of external sites, third party Apps or your chosen internet browser. However, we do seek to explain how we work with third parties, including search engines and ad servers such as Google. You can see Google’s Privacy Policy here.
We also offer a number of services to our readers and other customers, trading under different brands. You can see Our Brands and their respective Service Providers at the end of this Privacy Policy.
When we collect your information we may share it across our Telegraph Media Group companies. This Privacy and Cookie Policy explains how we use any of your personal information we might collect and how you can limit our use of it.
1. What information do we gather?
The information that we gather falls broadly into two types (please see further below for how we collect it and what we use it for):
1.1 Information that relates directly to you (e.g. your name, your email address and contact details, communication preferences and customer history).
1.2 Information that does not directly identify you (e.g. how you might browse our website), specifically:
(1) Your IP address through the placement of cookies; and
(2) Location data, which might be gained through your postal address (where you have provided this to us), IP address or GPS data (see Section 3 (4), below).
(3) Information from your browser such as screen size, browser type, device type and pages viewed
Please note that not all cookies are either personally identifiable information or even unique identifiers; but some can be, while others can influence what you see on our website and others (see Sections 6 and 7 on cookies and their management, below).
2. How we use your information
2.1 When we seek your permission. Often we will be using your information in accordance with your specific consent or instructions: for example, because you have requested or consented to receiving certain information, or entered into a contract with us (or one of Our Brands) for goods and services: see Section 2.2 below.
At other times we will use your information on one of the other lawful bases described below in this section.
2.2 Contract.
(1) When you enter into a contract for goods or services with us (including competitions, offers, subscriptions or your online Telegraph account), or where you wish to register an interest in doing so, we will use your personal data to enter into and fulfil our contractual relationship with you.
(2) Fulfilling our contract with you means being able to manage and administer our services, and maintain our standards of tailored service levels, customer care and consumer compliance. This might include fulfilling orders or returns, processing payments or refunds, and providing aftercare, as well as improving your customer experience online and otherwise, including by monitoring service levels and responding to feedback. This may include sharing your details (such as name and address) with our payment providers to enable them to verify credit details related to payments and validate payment authenticity. Our providers may retain payment details to enable efficient renewal and re-subscription processes for our products and services.
2.3 Legitimate interests.
Other uses of your information are made for ordinary and transparent purposes which we think are necessary for our legitimate interests as a provider of news, content, and other services (including when working with Our Brands). We use your information on this basis to do the following:
(1) Recognise and remember you when you visit our website and better understand how you use our website and others by using cookies to follow your use. We explain what cookies are in Section 6 and how you can manage them in Section 7, below;
(2) Recognise and remember you when you use a Telegraph application (“Telegraph App”), to analyse how you use it and to serve you with advertisements based on your interests. Section 3.1 (4) explains how we gather this information;
(3) Serve you advertisements on selected, third-party websites that make their advertising space available to us. We call this “Audience Extension” and we do this either by means of using retargeting cookies and similar technologies (we explain what cookies are in Section 6 and how you can manage them in Section 7, below) or by matching other unique identifiers, subject to appropriate safeguards and preferences for the purposes of serving you targeted advertisements and for running website analytics.
One such example is when we use Facebook’s Custom Audience feature (although other sites may offer similar services). Custom Audiences enable us to display personalised advertising to our customers whilst they are on Facebook, or your information may be used to create lookalikes of similar audiences for targeting. This information is matched on a pseudonymised basis without leaving our servers. Facebook does not receive any new information from us about you except as necessary to fulfil our instructions to serve relevant advertising as our data processor, and if you are not an existing Facebook customer then Facebook will not see any of your personally identifiable data (please see this link for further information). You can opt out of your data being used in this way by contacting data.protection@telegraph.co.uk. You can manage your Facebook advertising preferences by visiting facebook.com/adpreferences/data;
Serve you advertisements on our own website that are tailored to you or a group similar to you, where we make advertising space available to carefully selected third parties. This is subject to appropriate safeguards and your preferences around us serving you targeted advertising.
(4) Identify your interests. We might then put your information in aggregated form into groupings (known as “segments”) by a particular audience, which means we can serve you advertisements and offers that will interest you within the website, including by reference to data we receive from third parties. These advertisements and offers can be for our own products and for those of third parties. Please see Sections 6 and 7 for more information about cookies and how we serve you more targeted messaging;
(5) Keep you updated on any services you have subscribed to, or any products you have purchased, and/or about similar services unless you have told us otherwise (including where we are working alongside other Service Providers to provide these services, such as travel or insurance, as detailed in the Our Brands section);
(6) Contact you to let you know about any of our products, services or promotions (which may in some cases be provided by third parties), including by email, mail, telephone, app push notification or SMS text message, always having regard to data protection legislation and your preferences. Please see Section 4 to understand more about how you provide and can manage your preferences.
(7) Contact you directly or via social media in relation to any competitions and/or prize draws you have entered.
(8) Contact you, or have one of our trusted third party research partners contact you, for market research purposes, for example to ask you to participate in a survey. You can notify us if you no longer want us to contact you in this way. If you do choose to participate in a survey or where you choose to join Telegraph’s Contributors panel to participate in surveys, we will only use any data you provide under the survey in an anonymised and aggregated format. We may work with and share certain information with our trusted third party research partners, such as information about your subscription, so that they can engage you in research projects that are most relevant to you. Where we do, we will ensure that we enter into appropriate protections under contract to protect your information. You can notify us at any time if you do not wish this data to be shared in this way. You can see the Telegraph Contributors Panel privacy policy here
(9) Make sure materials on the website or in apps are presented in the most effective way for you and your computer or mobile device;
(10) Collect and log numeric internet addresses to improve the website and to monitor website usage; and
(11) Assess and understand our readers’, customers, site users' and account holders' feedback and identify usage hotspots;
(12) To analyse browsing information and cookie data using machine learning, for example to determine which subscription offers might be of most interest to you or which content or articles you would most like to see.
2.4 Some limited uses of your data are required to comply with legal obligations, such as fraud detection and taxation. For example, we may receive and use certain data from third party payment providers (such as PayPal and GooglePay) when you purchase a subscription from us, to ensure we are compliant with local tax regulations;
2.5 Our core activities as a media and publishing organisation, on paper or online, are classed as special purposes (which includes journalism and the arts). Please be aware that we are subject to a series of exemptions from data protection law when processing personal data for these purposes, and such purposes are not relevant to this Privacy Policy unless expressly stated.
2.6 We occasionally work with partners to compare their customer database to ours. This is called “data matching” and it allows our partners (such as other brands) to see if they can reach their audiences on our platforms. This will usually be carried out at an aggregated group audience level rather than on an individual level basis, although your information may be used to generate these insights. These insights may show, for example, if there is an overlap between our audiences and our partner’s audience and other information to help understand whether an advertising campaign would be effective.
We may also work with partners to build ‘lookalike’ audiences that are similar to our partners’ existing audiences, for targeting. An example of this may be a restaurant brand that wants to advertise to “food and drink enthusiasts” or “restaurant goers”, and so wishing to select an audience who we have identified as having interests in these ares. We would do this by segmenting our audiences into groups based on what they seem to like and similar behaviours. The restaurant is then able to identify a relevant audience, which means we can show you advertising that is relevant to you.
3. How do we gather information?
3.1 Information (as set out in Section 1) is gathered in the following ways:
(1) indirectly (e.g. from third party data providers or by using website technology that tracks and administers your visits through your browser, or similar technology when you use a Telegraph application (“App”) on a mobile device, or when you log on and/or share stories through social media;
(2) directly (e.g. when you buy a subscription, sign up to create a telegraph.co.uk profile, download a mobile device application or you otherwise provide your information when you interact with us, for example by telephone, email, or live chat);
(3) through your device (e.g. mobile, PC or tablet) where you have enabled location services for the applicable App or browser. This may be used for location targeted services or advertising in accordance with your preferences, which may be adjusted either on your device or via server, App or website preferences;
(4) through location technology for mobile web services. The service we use is based on machine learning algorithms which analyse data from different connection types. These include fixed http and https connections, location consent requests on https sites and from mobiles Apps using https connections. More information is available here. You can opt-out of this service here;
(5) through social media sign-on. We offer a quick registration option using your existing social media accounts via an App or the website. If you log in to our sites using a social media account, you are granting permission to that social media company to share your user details with us, and to collect information about you and how you use our site (which process we do not control and will be subject to the terms and conditions of your social media account). This will include that social media company tracking or identifying when you share one of our stories through their site. When you use social sign-on, we will gather the information you have already used in the process of registering for that social media site (in accordance with your preferences provided to that site and/or to us at the point that you use our social sign-on) and your social media account will be linked to your Telegraph account, including in our providing social media messaging to you (See Section 5.2, below on de-linking accounts);
(6) when you subscribe to The Telegraph, we may also use a card updater service to automatically update your credit or debit card details. This service is facilitated by your credit or debit card issuer, whom you should contact for further information;
(7) in the past we may have obtained certain additional details through a telephone number appending service where we have had contact details for you but did not have your phone number or needed to update your phone number (but would not use phone numbers that are gathered this way where those numbers are registered with the Telephone Preference Service). We no longer append data in this way; and
(8) we may also overlay additional demographic and lifestyle data from CACI (www.caci.co.uk) to help us understand what else you might be interested in for direct marketing and insight purposes. These segmentations are built using a variety of sources, including publicly available data (such as the electoral register and the UK Census) information you provide us or derived from surveys and questionnaires. You can opt out of having your personal information profiled in this way by contacting us. See Section 5, below.
(9) through cross-device graphing algorithms to associate devices that might be related to each other, such as devices used by the same person or in the same household. We may collect and use this analytics data together with your personal information, to stitch session data from unauthenticated (anonymous) user visits with authenticated (logged in) user visits in order to build a broader profile of our individual users so that we can serve you better.
(10) we may obtain personal data based on the content you view via our Apps. Your recently viewed articles are also cached in the local storage on your device. This can be deleted by you via the settings of the App. You can choose to receive notifications from us on your device via the App, and manage these notifications in the settings of the App;
(11) when you use the App, we may ask for your permission to be able to access certain functions of your mobile handset, depending on your device. This may include us asking for your permission: (i) if you choose to store content to use offline, permission to save that content on your mobile; (ii) to access your details on your mobile, so we can locate your account on your mobile; (ii) to access your photographs/camera if you choose to submit photographs to the Telegraph.
(12) if you register or sign into our websites or Apps by using your Google login details, you give Google your permission to share personal data that is publicly available in your Google profile (e.g. your name, email address). Your email address will be linked to your Telegraph subscription or registration to allow you to access your profile and subscribed content.
(13) If you register or purchase a subscription via Apple, you give Apple permission to share personal data with us (e.g. your name and email address) You can choose for Apple not to share this data and create a random email address. This email address will be linked to your Telegraph subscription or registration to allow you to access your profile and subscribed content.
(14) When you open the comments section of an article on our website for the first time, an account is generated for you within our third party commenting platform (“Viafoura”). The account includes your first name, last name and your email address. When you leave a comment, Viafoura collects and stores your current IP address and the content of the comment. If you decide to delete a comment from public view, Viafoura will retain the comment, but it won’t be visible on The Telegraph website.
We may quote your name and comment in our journalism, for instance in an article or a newsletter or on the homepage. Our editors may choose your post to be pinned or featured at the top of the comments section of the article. We may email you to ask for permission to put you in touch with a journalist who is interested in your experience or opinion, based on your comment(s). We collect and process data from the comments section for reporting and analysis purposes, to enhance and optimise our products and services.
Please be mindful of the information you choose to disclose in your comments, as it will be visible to other users. See our Community guidelines here.
4. How do you decide how you want to hear from us? 4.1 In accordance with data protection legislation and your preferences, we may contact you including by email, phone, post, Telegraph App notifications and SMS text. 4.2 We provide the means for you to grant and withhold your permission for us to contact you. We do this by using opt-in and opt-out boxes or unsubscribe options, which determine your permission for us to contact you about our wider range of goods and services, including those provided by Our Brands (the range of Telegraph-branded offers, products and services listed below this policy). In relation to postal marketing communications, where we have collected your postal address (for example when you take out a subscription) we may use your address to send you postal marketing. If you no longer wish to receive postal marketing you can notify us in accordance with section 5, below. 4.3 Sometimes, we need your information to be able to contact you to provide the service you wish to use (e.g. a subscription or Telegraph Fantasy Football). In those cases, by signing up to the service you are agreeing that we will have to send you service communications to run the service itself, and we will not offer you the chance to opt-out from receiving those messages until you decide you no longer wish to use the services. 4.4 As well as the communications we send you, we also offer you the opportunity to choose whether to hear from specific companies and organisations that we work in association with, including (but not limited to) the Service Providers for Our Brands. We will always name those companies and organisations, and you will have to opt in to hearing from them via a tick box (or because you choose to engage with them directly). 4.5 If you have signed up to receive marketing from us by SMS, to stop this, please reply STOP to the last message you received.
5. Accessing and updating your personal information 5.1 You can update your details and marketing preferences by accessing your account pages on the website, by emailing data.protection@telegraph.co.uk or by writing to us at The Telegraph - Data Protection, Firstsource, Riverside Road, Pride Park, Derby, DE24 8HY 5.2 You can de-link your social media account from your Telegraph account by emailing data.protection@telegraph.co.uk. De-linking your account will not change your marketing preferences unless you specifically request it and we are not responsible for how third party social media sites use information they collect about you, including via your own social media account or through your having linked it to your Telegraph account. 5.3 You have the right to access the personal information held about you from us, or from any other organisation that controls your personal information. To understand how to obtain a copy of the personal information that we hold, please see Section 13 below.
6. Cookies and similar technologies 6.1 A cookie is a small piece of information that is placed on your computer when you visit certain websites. When we refer to “cookies” we include other technologies with similar purposes, such as tags and identifiers. Find out more about the use of cookies on cookiecentral.com/. 6.2 When you first visit our sites using a new browser, or if you visit in private browsing mode, we will provide you with a cookies permission banner seeking your consent to use of cookies as required by law. From this banner you will be able to access our cookies management tool. By clicking OK or clicking through to any part of the site, we will start to manage your visit using cookies. 6.3 We use the following types of cookie, as will your browser: 6.5 We may use selected data management providers for our own purposes such as and/or similar to those described in 6.4, above. 6.6 We have no access to third party cookies and third party organisations have no access to ours. The third party organisations that place cookies, including your browser (such as Google), Ozone, data management providers and the third party companies who pay for advertising and analytics services using this information, will have their own privacy policies.
7. Managing your cookies preferences 7.1 Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates. We also provide our own cookie management tool for you to make more specific choices about how cookies are used for your visits to our site. 7.2 We also use third party cookies, as will your browser. These are cookies that may be read by third parties (for example if you have used social sign-on and have the option to like or comment using your social media account). If you would prefer to just restrict third party cookies, here is our cookie management tool:Alternatively, visit youronlinechoices.com or click on the AdChoices logo that you will see in the corner of advertisements that carry behavioural targeting cookies. 7.3 We use various third parties to provide us with information to help us learn about how users use our website. To find out more about how we use these third party services click on their names, below, to view their websites and privacy policies:
7.4 If you would like to disable 'third party'; cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to the third party's website and getting them to generate a one-time 'no thanks' cookie that will stop any further cookies being written to your device. Here is a link to the third party advertising platform we use, which has instructions on how to do this:adssettings.google.com/authenticatedPlease note that even after disabling this, you may still see “non-personalised” advertisements that may appear materially the same as the “personalised” ones. This is simply a function of what advertisers and partners we are working with, and does not mean your preferences have not been applied.Please note also that the likes of Google, with whom we work to serve advertising, will still use cookies for necessary administrative purposes after you have amended your personalised advertising settings. These purposes include frequency capping (namely to stop users being served the same advertisements repeated), aggregated reporting of engagement (on a non-personal basis) and to combat fraud and abuse (for example, to prevent bogus click-throughs by web hosts to inflate the value of their platform). 7.5 We also use a data management platform. We use the data this platform records, including data gathered through cross-device tracking, to better understand our users’ interests, so that we can provide better and relevant Telegraph Media Group and advertiser services based on this information. 7.6 When you share stories using social media, for example Facebook, the social media company will drop cookies and identifiers to track this. 7.7 You can also visit the trade body representing these advertising companies for more information on how to opt out of these cookies: youronlinechoices.com
8. Ad Blockers 8.1 We use JavaScript to detect ad blockers. We use the script in the source code of our website. It confirms advertisements are correctly displayed on your device by simulating the display of the advertisement. 8.2 By detecting ad blockers, we do not store any information on your device and we do not process any of your personal data. 8.3 We may display a message to advise you that we have detected that you are using and ad blocker 8.4 We reserve the right to restrict your access to some or all of our website while you have an ad blocker turned on.
9. Protecting your information 9.1 The password you provide when registering with the website is encrypted to ensure protection against unauthorised access to your personal information. 9.2 We invest in high-quality security and do our utmost to protect user privacy. No data transmission over the Internet can be entirely secure, and therefore we cannot guarantee the security of your personal information and/or use of the website. Any information that you send is at your own risk and may be read by others. However once we have received your personal information we use strict procedures to protect the security of your personal information.
10. Disclosing your information 10.1 Selling our businesses. We may share your personal information with potential buyers, their advisers and connected third parties in connection with the potential sale or transfer of our business or assets or of any part of our business or assets (including any of Our Brands). If we sell, transfer or restructure any part of our business that holds your personal information, we may share or transfer that information to the buyer or new entity: for example, so that they can continue to provide continuity of service to you. We will use reasonable efforts to try and ensure that the buyer or new entity continues to use your personal data in the same way or a similar way to that outlined under our privacy policy. We will always try and notify you of such a change of control or ownership, such as by way of public announcement and updates to this privacy policy or any new privacy policy. 10.2 Your internet browser or other accounts. Depending on which browser you use to visit our site, and in accordance with your browser cookie preferences (see above), your browser (such as Google) may collect information about you and your visit for its own services, including those services such as segmented or personalised advertising that it provides to us and other sites. If you use social media sign-on (such as with Facebook), you will be enabling sharing of information between us and that site in the manner set out in Section 3.1 (5) above and any notices provided to you. You can de-link your social sign-in as set out in Section 5.2. 10.3 Our partners. Except as set out in Section 10.1 or 10.2 above, we never sell personal information, or pass it to third parties outside of the Telegraph Media Group for their own marketing purposes, without your permission. We sometimes provide your personal information to third parties who are our subcontractors or providers of various products and services on our behalf e.g. the providers of the branded services listed below (Our Brands and their Service Providers) and intermediaries, in order to fulfil those orders and providers of key services such as our customer care partners, First Source. Your personal information will always be subject to appropriate protections under contract. Where you are engaging with Our Brands for products and services, you will sometimes contract with our Service Providers and may choose to provide them with personal information or permissions directly. 10.4 Legal requirements. We may disclose your personal information if we are required to do so by law, or if in good faith we believe such action is necessary to comply with the law a legal obligation. 10.5 Verification of circulation figures. We may disclose subscribers’ personal information including: name, address, email address and telephone number and payment details (though no bank or credit card account details) to the Audit Bureau of Circulation (ABC) for the sole purpose of verifying our newspaper circulation figures. ABC’s Privacy Policy can be found here. 10.6 Data processors. In common with most organisations, some of our functions using your personal information are outsourced to contractors (for example, Sourcepoint who manage our cookies consents or our other software providers). Any processing of personal information by these contractors will only be for these carefully defined purposes, and will be adequately and lawfully protected under contract, including requirements of confidentiality and data security.
11. Where we store your personal information 11.1 The personal information that we collect from you will sometimes be sent and stored outside of the UK or the European Economic Area ("EEA") in order to carry out the activities listed in “Use of Your Information”. Except where this is on your specific instructions, this will always be subject to adequate safeguards as to the protection and security of your personal data. This means that we will only transfer your personal data outside of the UK or EEA: (a) to countries that have been found to provide an adequate level of protection for personal data. This may include certain US organisations that have certified participation in the EU-US Data Privacy Framework including the UK Extension; or (b) where we have used specific approved contracts that use approved clauses (such as Standard Contractual Clauses or the International Data Transfer Agreement) for the protection of personal data and where we have carried out assessments of the safeguards provided by those countries. These contracts give your personal data the same level of protection as the UK and EEA. Further details on these safeguards are available on enquiry from data.protection@telegraph.co.uk. 11.2 We will only keep your personal information for as long as we need it for a lawful purpose: whether because of the products and services we have provided to you, for example as a subscriber or registered user (and to allow for reasonable retention of records afterwards to reflect legal requirements or limitation periods),or because we believe you still wish to hear from us. This is again separate from our role as a media organisation and the information we are lawfully able keep in the public interest because it is relevant to our journalism and publishing activities.
12. Changes to this Policy 12.1 If we change our Policy, we will post the changes on this page. Please check the website regularly for any changes to this Policy. However, from 25 May 2018 any significant changes will be provided to you directly where possible. 12.2 The previous Privacy Policy was dated 3rd August 2023.
13. If you don't feel we're adhering to this Policy, what should you do? 13.1 You have the following rights: (1) To obtain access to, and copies of, the personal data that we hold about you, or require that it is transmitted to another data controller; (2) To request that we restrict our data processing activities or cease processing your personal data in certain ways, for example because you do not consider it lawful; (3) To require us not to send you marketing communications; (4) To withdraw your consent, where we are relying on it to process your personal data; (5) To object to how we process your personal data, in particular where we are relying on our legitimate interests; and (6) To ask us to erase the personal data we hold about you, for example because it is causing you distress or you believe it to be no longer relevant, or to correct the information if it is incorrect.
If you would like to exercise any of your rights as stated above, you can do so by emailing data.protection@telegraph.co.uk. Please note that the above rights are not absolute, and we will be entitled to refuse requests where exceptions apply (including where we are processing it in our capacity as a media organisation). You can find out more about your rights at www.ico.org.uk.
Automated decision making You also have the right to object to automated decision-making, including by means of profiling. Although we use various algorithms and automated criteria to help us serve advertising in the manner set out in this Policy, this results in segmented advertising (by category of user) rather than specific decisions being made about you. This can in any event be controlled through your cookie and ad preferences.If we change how we use this technology in the future, we will let you know if it affects you via this Policy (and significant changes or effects we will notify directly).
14. If you don't feel we're adhering to this Policy, what should you do?
14.1 If you believe that we have not adhered to this Policy, please notify us by email at data.protection@telegraph.co.uk and we will try to solve the problem promptly. If you are not satisfied with our response, or have any other queries, you can also contact the Information Commissioner at www.ico.org.uk or 0303 123 1113.This policy is effective from 29 September 2024.
Our Brands Telegraph brands and their suppliers change from time to time. The following list was updated on 11th March 2024. N.B. Telegraph Travel also uses the services of smaller organisations and individual hotels. These are clearly specified in our marketing communications.
NEW US PRIVACY POLICY
Effective Date: 29th September 2024
Your privacy is important to us. Telegraph Media Group Holdings Limited, Press Acquisitions Limited, and each of their respective subsidiaries (collectively, “Telegraph Media Group”, “we”, or “us” or “our”) created this Privacy Policy to inform you about how we collect, use, disclose, share, and protect Personally Identifiable Information (or “PII”, defined below) and otherwise comply with applicable U.S. consumer privacy laws. We encourage you to read this Privacy Policy in its entirety before using https://www.telegraph.co.uk/ or any other online service (e.g., website or mobile app) that posts a link to this Privacy Policy, opening our e-mails or otherwise submitting PII to us (collective the “Service”).
This Privacy Policy applies to visitors of our Service (defined below) in the United States. If you are visiting the Service from another country, please refer to our General Privacy Policy.
By visiting or otherwise using the Service, you agree to the Service’s U.S. Terms and Conditions and consent to Telegraph Media Group’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy and any additional privacy statements that may be posted on an applicable part of the Service or otherwise provided at collection. If you do not agree or consent, please discontinue use of the Service and uninstall Service downloads and applications.
Your U.S. State Privacy Rights
California, Colorado (effective July 1, 2023), and Nevada residents have certain privacy rights detailed here. To the extent that there is a conflict between this Privacy Policy and the state privacy notices, the state privacy notices will control.
About Ads and Tracking
Learn about certain choices you have regarding Tracking Technologies, including certain sharing of activities for interest-based advertising, including Location-Based Advertising and Cross-Device Matching.
TABLE OF CONTENTS
A. Information About You That You Provide
B. Information Collected Automatically
C. Information Telegraph Media Group Collects From Other Sources
2. How We Use The Information We Obtain
3. Information We Share With Third Parties
4. Sweepstakes, Contests, and Promotions
5. Information You Disclose Publicly or to Others
6. Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics
7. Data Security and Monitoring
10. Accessing and Changing Information
11. Choices: Tracking and Communications Options
A. Tracking Technologies Generally
B. Analytics and Advertising Tracking Technologies
12. U.S. State Privacy Notices
i. PI Collection, Disclosure, and Retention – By Category of PI
ii. PI Use and Disclosure – By Processing Purpose
B. Your Consumer Rights and How to Exercise Them
i. Right to Limit Sensitive PI Processing (California Consumers)
ii. Right to Know/Access (California and Colorado)
iii. Do Not Sell / Share / Target
iv. Right to Delete (California and Colorado)
v. Correct Your PI (California and Colorado)
vi. Automated Decision Making/Profiling (California and Colorado)
vii. How to Exercise Your Consumer Privacy Rights
C. Non-Discrimination/non-retaliation
D. Notice of Financial Incentive Programs
E. Our Rights and the Rights of Others
i. Additional Notice for California Residents
13. Changes to This Privacy Policy
14. Contact Telegraph Media Group
SCOPE
This Privacy Policy governs our practices with regards to PII collected when you access or use the Service. This Privacy Policy will provide you with information as to how Telegraph Media Group collects, uses, and shares information about you, including the choices Telegraph Media Group offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to Telegraph Media Group’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.
1. INFORMATION WE COLLECT
A. Information About You That You Provide
Telegraph Media Group, and/or its Service Providers (defined below), may collect information you provide directly to Telegraph Media Group and/or its Service Providers via the Service. For example, Telegraph Media Group collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here.
Information Telegraph Media Group, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number (“Personally Identifiable Information” or “PII”); and (2) demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases (“Demographic Information”). Except to the extent required by applicable law, Demographic Information is “non-Personally Identifiable Information” or “non-PII” (i.e., data that is not Personally Identifiable Information under this Privacy Policy). In addition, Personally Identifiable Information, including, without limitation, Telegraph Media Group-Collected PII (defined below), once “deidentified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements) including through anonymization, pseudonymization, and/or hashing, is also non-Personally Identifiable Information and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that deidentified data is not capable of re-identification. We will not reidentify or attempt to reidentify data that we maintain as deidentified or knowingly enable any third party to do so. To the extent any non-Personally Identifiable Information, or PII collected outside of the Service, is combined by or on behalf of Telegraph Media Group with Personally Identifiable Information Telegraph Media Group itself collects directly from you on the Service (“Telegraph Media Group-Collected PII”), Telegraph Media Group will treat the combined data as Telegraph Media Group-Collected PII under this Privacy Policy. The definition of “personal information” under certain state laws differs from the definition of PII used in this Privacy Policy. California and Nevada residents can learn more about their privacy rights here.
B. Information Collected Automatically
Telegraph Media Group, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include information regarding how you might browse our website, specifically, IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Telegraph Media Group with Telegraph Media Group-Collected PII, Telegraph Media Group does not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or Telegraph Media Group-Collected PII. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
The methods that may be used on the Service to collect Usage Information include:
Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device recognition technologies, in-app tracking methods, device and activity monitoring and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
Cookies
A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Service may associate some or all these types of cookies with your devices.
Web Beacons (“Tracking Pixels”)
Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
Embedded Scripts
An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Telegraph Media Group’s web server, or from a third party with which Telegraph Media Group works and is active only while you are connected to the Service and deleted or deactivated thereafter.
Location-identifying Technologies
GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content, including third party ads, based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked by us and third parties.
Device Recognition Technologies.
Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
In-App Tracking Methods
There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs,” or may use “SDKs,” to associate app user activity to a particular app and to track user activity across apps and/or devices. SDKs are blocks of code that may be installed in our mobile application by third party companies with which we work. SDKs help us understand how you interact with our mobile application and collect certain information about the device and network you use to access our application, such as the advertising identifier associated with your device and information about how you interact with our application.
Some information about your use of the Service and certain other online services may be collected using Tracking Technologies across time and services and used by Telegraph Media Group and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services. See Section 11 regarding certain choices regarding these activities.
Telegraph Media Group is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
C. Information Telegraph Media Group Collects From Other Sources
Telegraph Media Group may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Telegraph Media Group-Collected PII. Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of Telegraph Media Group with Telegraph Media Group-Collected PII, this Privacy Policy is not intended to limit Telegraph Media Group’s activities regarding such third-party-sourced, or non-Service-sourced, information (including Personally Identifiable Information), and such data will only be treated as Telegraph Media Group-Collected PII to the extend it is combined with Telegraph Media Group-collected PII. Telegraph Media Group is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.
2. HOW WE USE THE INFORMATION WE OBTAIN
Telegraph Media Group may use information about you, including Telegraph Media Group-Collected PII and other Personally Identifiable Information, for any purposes not inconsistent with Telegraph Media Group’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:
Allow you to participate in the features we offer on the Service;
Facilitate, manage, personalize, and improve your online experience;
Process your registration, manage your account, and provide customer care and consumer compliance (e.g., fulfilling orders or returns, processing payments or refunds, and providing aftercare, as well as improving your customer experience);
Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
Telegraph Media Group Affiliates’ marketing and other purposes;
Improve the Service and for any other business purposes;
Tailor our content, advertisements, and offers;
Fulfill other purposes disclosed at the time you provide Personally Identifiable Information or otherwise where we are legally permitted or are required to do so;
Determine your location and manage digital content rights (e.g., territory restrictions); and
Prevent and address fraud, breach of policies or terms, and threats or harm.
3. INFORMATION WE SHARE WITH THIRD PARTIES
Except as restricted by applicable law, this Privacy Policy, or any other representation Telegraph Media Group makes to you, Telegraph Media Group may share non-Personally Identifiable Information, and Personally Identifiable Information that is not deemed Telegraph Media Group-Collected PII hereunder (provided that Telegraph Media Group is aware of no restrictions of Telegraph Media Group’s use, if any), with third parties or Telegraph Media Group companies and their affiliates (“Telegraph Media Group Affiliates”) for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your Personally Identifiable Information, including Telegraph Media Group-Collected PII, to non-Personally Identifiable Information, including without limitation through hashing it or substituting a unique identifier for the Personally Identifiable Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. Telegraph Media Group’s sharing of Telegraph Media Group-Collected PII is, however, subject to the following:
Marketing: Subject to your communications choices explained in Section 11.D, and the rights of California residents explained in Section 12, we may use your Personally Identifiable Information to send you marketing communications. Telegraph Media Group will not share your Telegraph Media Group-Collected PII with third parties or Telegraph Media Group Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below) without your consent (which may be by means of third-party interaction described in the next bullet point). We sometimes provide your PI to third parties who are our Vendors of various products and services on our behalf to fulfill those orders.
Your Disclosure or Consent: As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your Telegraph Media Group-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not Telegraph Media Group.
Telegraph Media Group may also share any information about you (including, without limitation, Telegraph Media Group-Collected PII) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:
Telegraph Media Group’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to, your information, including, without limitation, Personally Identifiable Information, Demographic Information, and Usage Information, in connection with their work on Telegraph Media Group’s behalf, provided however, Telegraph Media Group does not authorize its Service Providers to use Telegraph Media Group-Collected PII provided by Telegraph Media Group to the Service Providers to send you direct marketing messages other than related to Telegraph Media Group and Telegraph Media Group Affiliates absent your consent. For more information on choices Service Providers may offer you visit Section 11.
Third parties and their advisers if we are approached by a potential buyer in connection with the potential sale of our business or of any part of it.
Your internet browser or other accounts. Depending on which browser you use to visit our site, and in accordance with your browser cookie preferences (see above), your browser (such as Google) may collect information about you and your visit for its own services, including those services such as segmented or personalized advertising that it provides to us and other sites.
Data processors. In common with most organizations, some of our functions using your personal information are outsourced to contractors. Any processing of personal information by these contractors will only be for these carefully defined purposes, and will be adequately and lawfully protected under contract, including requirements of confidentiality and data security.
To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
If Telegraph Media Group believes your actions are inconsistent with Telegraph Media Group’s terms and conditions, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Telegraph Media Group, the Service or its users, or any third party.
In addition, Telegraph Media Group may share your Telegraph Media Group-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Telegraph Media Group assets, or transfer of all or a portion of Telegraph Media Group’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS
Telegraph Media Group may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personally Identifiable Information. If you voluntarily choose to enter a Promotion, your information, including Personally Identifiable Information, may be disclosed to Telegraph Media Group, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.
5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS
The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personally Identifiable Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Telegraph Media Group. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personally Identifiable Information included in UGC is not subject to Telegraph Media Group’s usage or sharing limitations, or other obligations, regarding Telegraph Media Group-Collected PII or other Personally Identifiable Information under this Privacy Policy or otherwise and may be used and shared by Telegraph Media Group and third parties to the fullest extent not prohibited by applicable law. Telegraph Media Group encourages you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service’s Terms and Conditions click here. California minors should see Section 9 regarding potential removal of certain UGC they have posted on the Service.
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Telegraph Media Group relies on you to only send to people that have given you permission to do so. The recipient’s Personally Identifiable Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Telegraph Media Group for any other marketing purpose unless Telegraph Media Group obtains consent from that person. Your contact information and message may be included in the communication.
6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS
The Service may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)) or other services (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personally Identifiable Information from you.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Telegraph Media Group’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5 or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with Telegraph Media Group or other Telegraph Media Group Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Telegraph Media Group and Telegraph Media Group Affiliates. Also, both Telegraph Media Group and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
Telegraph Media group may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”). We may use Microsoft and Google for advertising Services. See Section 11 for more information on your choices regarding certain personalized advertising.
Telegraph Media Group may use Google Analytics, Adobe Analytics or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help Telegraph Media Group analyze Service users and how they use the Service. Information generated by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage. See Section 11 for more information on your choices regarding these services.
Telegraph Media Group is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.
7. DATA SECURITY AND MONITORING
Telegraph Media Group takes reasonable measures to protect Telegraph Media Group-Collected PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Telegraph Media Group does not guarantee the security of your information collected through the Service.
To help protect you and others, Telegraph Media Group and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including Telegraph Media Group-Collected PII and other Personally Identifiable Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the Terms and Conditions and this Privacy Policy; investigate violations of or enforce these documents; improve the Services and your Services experiences, and to protect the rights and property of Telegraph Media Group Company Affiliates, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.
8. INTERNATIONAL TRANSFER
This policy is targeted towards users located in the U.S. and the information Telegraph Media Group and its Service Providers collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, in the U.S. as set forth in this Privacy Policy. If you are a user located in the U.K. or EU, please refer to the General Privacy Policy.
9. CHILDREN'S PRIVACY
The Service is intended for a general audience and not directed to children less than 13 years of age. For further information on how Telegraph Media Group treats Children’s Personal Information (defined below) in connection with any children’s or mixed-use portions of the Service (if any), please see the Children’s Privacy Policy posted thereon, which will be deemed incorporated herein for purposes of that part of the Service.
Telegraph Media Group does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Telegraph Media Group here, detailing where the content or information is posted and attesting that you posted it. Telegraph Media Group will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that Telegraph Media Group does not control.
10. ACCESSING AND CHANGING INFORMATION
Telegraph Media Group may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Telegraph Media Group-Collected PII, and potentially certain other information about you (e.g., profile and account information). Telegraph Media Group will make good faith efforts to make requested changes in Telegraph Media Group’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all your information or public postings from Telegraph Media Group’s databases (California minors see Section 9 and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
11. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS
A. Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to HTML5 cookies or other Tracking Technologies. Visitors in the U.S. may also manage cookies on our Service through our consent management platform
Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Telegraph Media Group currently does not alter Telegraph Media Group’s practices when Telegraph Media Group receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Telegraph Media Group is not responsible for the completeness or accuracy of this third-party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Telegraph Media Group is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Services, but such tools rely on third parties and third-party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective. For instance, here is where you can find cookie controls for popular browsers:
We do not represent that these third-party tools, programs or statements are complete or accurate. You will need to do this on each browser that you use to access our Services and clearing cookies on your browser(s) may disable your preference settings. Also, our Services may not function properly or as intended if you block all or even certain cookies. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.
B. Analytics and Advertising Tracking Technologies
You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.”
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us, and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you can opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Telegraph Media Group supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Telegraph Media Group directly engages to serve you Interest-based Advertising will do so as well, though Telegraph Media Group cannot guaranty their compliance.
We may also use Microsoft Advertising Services. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit here. We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit here.
In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the other online services. For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads. If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
Telegraph Media Group is not responsible for effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
C. Mobile Apps
With respect to Telegraph Media Group’s mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., tracking across apps and websites owned by other online services, location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. For example, to limit receiving Interest-based Advertising on your mobile device, for iOS 14, go to “Settings,” select “Privacy,” select “Tracking,” and then toggle off “Allow Apps to Request to Track.” For earlier versions of iOS dating back to iOS 6, go to “Settings,” select “Privacy,” select “Advertising,” and toggle on “Limit Ad Tracking.” For Android, go to “Settings,” select “Privacy,” select “Ads,” and then toggle on “Opt out of Ads Personalization.” Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist. To learn more about how you can control certain location permissions, such as GPS, wi-fi, and network data, using your mobile device’s operating system settings, please visit the following links depending on which device you use:
Android: https://support.google.com/android/answer/3467281
iOS: - https://support.apple.com/en-us/HT207056
D. Communications
You can opt out of receiving certain promotional communications (emails or text messaging) from Telegraph Media Group at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from Telegraph Media Group to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Telegraph Media Group may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Telegraph Media Group’s ongoing business relations. Except in connection with Corporate Transactions, to prospectively opt-out of our sharing of your Company-Collected PII with third parties, other than with Telegraph Media Group Affiliates, for their own direct marketing purposes, email us here
E. Cross-Device Data
To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the prior section regarding the DAA’s Interest-based Advertising choices.
12. U.S. STATE PRIVACY NOTICES
This U.S. State Privacy Notice (“Notice”) applies to “Consumers” as defined under the California Consumer Privacy Act, including as amended by the California Privacy Rights Act, Colorado Privacy Act (effective July 1, 2023), and all laws implementing, supplementing or amending the foregoing, including regulations promulgated thereunder (together, the “CCPA”), and Chapter 603A of the Nevada Revised Statutes (collectively, “U.S. Privacy Laws”). Capitalized terms used but not defined in this Notice shall have the meanings given to them under the CCPA.
This Notice is designed to meet our obligations under U.S. Privacy Laws and supplements the U.S. Privacy Policy of Telegraph Media Group Holdings Limited. In the event of a conflict between any other Telegraph Media Group policy, notice, or statement and this Notice, this Notice will prevail as to Consumers unless stated otherwise.
Applicability:
Section A of this Notice provides notice of our data practices, including our collection, use, disclosure, and sale of Consumers’ Personal Information or Personal Data (collectively, “PI”), as that respective term is defined under US Privacy Laws.
Sections B-D of this Notice provide information regarding Consumer rights and how you may exercise them. Nevada “consumers” have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, the other Consumer rights only apply to California Consumers.
Section E of this Notice provides additional information for California residents.
For California residents the term “Consumer” is not limited to data subjects acting as individuals regarding household goods and services and includes data subjects in a business-to-business context.
Non-Applicability: This Notice does not apply to our job applicants, current employees, former employees, or independent contractors (“Personnel”), however, California Personnel may obtain a separate privacy notice that applies to them by contacting our human resources department by email here. This Notice also does not apply to PI that we may process as a Service Provider/Processor on behalf of another Business/Controller.
A. Notice of Data Practices
The description of our data practices in this Notice covers the twelve (12) months prior to the Effective Date and will be updated at least annually. Our data practices may differ between updates. However, if the practices are materially different from this Notice, we will provide supplemental pre-collection notice of the current practices, which may include references to other privacy policies, notices, or statements. Otherwise, this Notice serves as our notice at collection.
We may Collect your PI directly from you (e.g., when you register for an account); your devices; our affiliates; service providers; public sources of data; credit reporting agencies; or other businesses or individuals. As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We will not reidentify or attempt to reidentify data that we maintain as deidentified or knowingly enable any third party to do so.
Generally, we Process your PI to provide you services and as otherwise related to the operation of our business, including for one or more of the following Business Purposes: Performing Services; Managing Interactions and Transactions; Security; Debugging; Advertising & Marketing; Quality Assurance; Processing Interactions and Transactions; Security and Fraud Prevention; and Research and Development. We may also use PI for other Business Purposes in a context that is not a Sale or Share under U.S. Privacy Laws, such as disclosing it to our Service Providers, Contractors, or Processors that perform services for us (“Vendors”), to the Consumer or to other parties at the Consumer’s direction or through the Consumer’s action; for the additional purposes explained at the time of collection (such as in the applicable privacy policy or notice); as required or permitted by applicable law; to the government or private parties to comply with the law, legal process, to protect or enforce legal rights or obligations, or prevent harm; and to assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business (“Corporate Transaction”) (“Additional Business Purposes”). Subject to restrictions and obligations under U.S. Privacy Laws, our Vendors may also use your PI for Business Purposes and Additional Business Purposes, and may engage their own vendors to enable them to perform services for us.
We may also use and disclose your PI under this Notice for Commercial Purposes, which may be considered a “Sale” or “Share” under applicable U.S. Privacy Laws, such as when Third-Party Digital Businesses (defined below) Collect your PI via third-party cookies, and when we Process PI for certain advertising purposes.
We provide more detail on our data practices in the two charts that follow.
PI Collection, Disclosure, and Retention – By Category of PI
We collect, disclose, and retain PI as follows:
There may be additional information we Collect that meets the definition of PI under applicable U.S. Privacy Laws but is not reflected by a category above, in which case we will treat it as required, but will not include it when we describe our practices by PI category.
DATA RETENTION
As required by California law, we note our general PI retention rules by category of PI in the chart above. However, because there are numerous types of PI in each category, and various uses for each PI type, actual retention periods vary. We will retain specific PI pieces based on how long we have a lawful purpose for the retention. For instance, we may maintain business records for so long as relevant to our business, and may have a legal obligation to hold PI for so long as potentially relevant to prospective or actual litigation or government investigation. We apply the same criteria for determining if we have a legitimate purpose for retaining your PI that you ask us to delete. If you make a deletion request, we will conduct a review of your PI to confirm if legitimate ongoing retention purposes exist, will limit the retention to such purposes for so long as the purpose continues, and will respond to you with information on any retention purposes on which we rely for not deleting your PI. For more information on deletion requests see the Right to Delete section.
ii. PI Use and Disclosure – By Processing Purpose
We use and disclose PI for the processing purposes described below:
B. Your Consumer Rights and How to Exercise Them
As described more below, subject to meeting the requirements for a Verifiable Consumer Request (defined below), Telegraph Media Group provides Consumers the privacy rights described in this section. For residents of states without Consumer privacy rights, we will consider requests but will apply our absolute discretion with respect to, if, and how we process such requests. Visitors in the U.S. may also manage cookies on our Service through our consent management platform.
To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, use our Consumer Rights Request Portal, or e-mail us at data.protection@telegraph.co.uk, and respond to any follow-up inquiries we make. Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.). More details on the request and verification process are in Section 3. The Consumer rights we accommodate are as follows:
i. Right to Limit Sensitive PI Processing (California Consumers)
We only Process Sensitive PI for purposes that are exempt from Consumer choice under U.S. Privacy Laws.
ii. Right to Know/Access (California and Colorado)
Residents of California are entitled to access PI, up to twice in a 12-month period, collected and maintained about the Consumer on or after January 1, 2022, including beyond the 12-month period preceding our receipt of the request, unless doing so proves impossible or would involve a disproportionate effort.
(1) Categories
California residents have a right to submit a request for any of the following:
The categories of PI we have Collected about you.
The categories of sources from which we Collected your PI.
The Business Purposes or Commercial Purposes for our Collecting, Selling, or Sharing your PI.
The categories of Third Parties to whom we have disclosed your PI.
A list of the categories of PI disclosed for a Business Purpose and, for each, the categories of recipients, or that no disclosure occurred.
A list of the categories of PI Sold or Share about you and, for each, the categories of recipients, or that no Sale or Share occurred.
(2) Specific Pieces
You may request to confirm if we are Processing your PI and, if we are, to obtain a transportable copy, subject to applicable request limits, of your PI that we have collected and are maintaining. For your specific pieces of PI, as required by applicable U.S. Privacy Laws, we will apply the heightened verification standards as described below. We have no obligation to re-identify information or to keep PI longer than we need it or are required to by applicable law to comply with access requests.
iii. Do Not Sell / Share / Target
Under U.S. Privacy Laws there are broad and differing concepts of “Selling” PI for which an opt-out is required. California has an opt-out from “Sharing” for Cross-Context Behavioral Advertising (use of PI from different businesses or services to target advertisements). Colorado has an opt-out from targeted advertising. Nevada “consumers” have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes. You may contact us here to be verified and learn more about your opt-out rights under that law. We may Sell or Share your PI and/or use your PI for Targeted Advertising, as these terms apply under U.S. Privacy Laws. However, we provide Consumers an opt-out of Sale/Sharing/Targeting regardless of state of residency.
Third-Party digital businesses (“Third-Party Digital Businesses”) may associate cookies and other tracking technologies that Collect PI about you on our services, or otherwise Collect and Process PI that we make available about you, including digital activity information. We understand that giving access to PI on our services, or otherwise, to Third-Party Digital Businesses could be deemed a Sale and/or Share and thus we will treat such PI (e.g., cookie ID, IP address, and other online IDs and internet or other electronic activity information) collected by Third-Party Digital Businesses, where not limited to acting as our Service Provider (or Contractor or Processor), as a Sale and/or Share and subject to a Do Not Sell/Share/Target opt-out request. We will not Sell your PI, Share your PI for Cross-Context Behavioral Advertising, or Process your PI for Targeted Advertising if you make a Do Not Sell/Share/Target opt-out request.
Opt-out preference signals (also known as global privacy control or GPC): Some of the U.S. Privacy Laws require businesses to process GPC signals, which is referred to in California as opt-out preference signals (“OOPS”), which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the Sale or Sharing of personal information. To use an OOPS/GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the OOPS/GPC. We have configured the settings of our consent management platform to receive and process GPC signals on our website. We process OOPS/GPC with respect to Sales and Sharing that may occur in the context of Collection of cookie PI by tracking technologies online by Third-Party Digital Businesses, discussed above, and apply it to the specific browser on which you enable OOPS/GPC. We currently do not, due to technical limitations, process OOPS/GPC for opt-outs of Sales and Sharing in other contexts (e.g., non-cookie PI). We do not: (1) charge a fee for use of our service if you have enabled OOPS/GPC; or (2) change your experience with any product or service offered by Telegraph Media Group if you use OOPS/GPC; (3) apart from notifying you that you opted out, display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the OOPS/GPC.
Opt-out for non-cookie PI: If you want to limit our Processing of your non-cookie PI (e.g., your email address) for Targeted Advertising, or opt-out of the Sale/Sharing of such data, make an opt-out request here.
Opt-out for cookie PI: If you want to limit our Processing of your cookie-related PI for Targeted Advertising, or opt-out of the Sale/Sharing of such PI, you need to exercise a separate opt-out request on our cookie management tool or by clicking on the “Do Not Sell or Share My Personal Information” link on the banner of the website and app. This is because we have to use different technologies to apply your opt-out of cookie PI and to non-cookie PI. Our cookie management tool enables you to exercise such an opt-out request and enable certain cookie preferences on your device. A similar tool is available for our app, which you can access via the Do Not Sell/Share/Target option in the settings menu. You must exercise your preferences on each of our websites and apps you visit, from each browser you use, and on each device that you use. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to enable them again via our cookie management tool. Please also refer to Section 11 for other ways to exercise preferences regarding Third-Party Digital Businesses. Beware that if you use ad blocking software, our cookie banner may not appear when you visit our services and you may have to use the link above to access the tool.
We do not knowingly Sell or Share the PI of Consumers under 16, unless we receive affirmative authorization (“opt-in”) from either the Consumer who is between 13 and 16 years old, or the parent or guardian of a Consumer who is less than 13 years old. If you think we may have unknowingly collected PI of a Consumer under 16 years old, please Contact Us.
We may disclose your PI for the following purposes, which are not a Sale or Share: (i) if you direct us to disclose PI; (ii) to comply with a Consumer rights request you submit to us; (iii) disclosures amongst the entities that constitute Telegraph Media Group as defined above, or as part of a Corporate Transaction; and (iv) as otherwise required or permitted by applicable law.
iv. Right to Delete (California and Colorado)
Except to the extent we have a basis for retention under applicable law, you may request that we delete your PI. Our retention rights include, without limitation:
to complete transactions and services you have requested;
for security purposes;
for legitimate internal Business Purposes (e.g., maintaining business records);
to comply with law and to cooperate with law enforcement; and
to exercise or defend legal claims.
Please also be aware that making a deletion request does not ensure complete or comprehensive removal or deletion of PI or content you may have posted.
Note also that, depending on where you reside (e.g., California), we may not be required to delete your PI that we did not Collect directly from you.
v. Correct Your PI (California and Colorado)
Consumers may bring inaccuracies they find in their PI that we maintain to our attention, and we will act upon such a complaint as required by applicable law. You can also make changes to your online account in the account settings section of the account. That will not, however, change your information that exists in other places.
vi. Automated Decision Making/Profiling (California and Colorado)
We do not engage in Automated Decision Making or Profiling.
vii. How to Exercise Your Consumer Privacy Rights
To submit a request to exercise your Consumer privacy rights, or to submit a request as an authorized agent, use our Consumer Rights Request Portal, or e-mail us here, and respond to any follow-up inquiries we make. Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.).
a. Your Request Must be a Verifiable Consumer Request
As permitted or required by applicable U.S. Privacy Laws, any request you submit to us must be an authenticated or Verifiable Consumer Request, meaning when you make a request, we may ask you to provide verifying information, such as your name, e-mail, phone number and/or account information. We will review the information provided and may request additional information (e.g., transaction history) via e-mail or other means to ensure we are interacting with the correct individual. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), Right to Delete, or Right to Correction request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. We do not verify opt-outs of Sell/Share/Target or Limitation of Sensitive PI requests unless we suspect fraud.
We verify each request as follows:
Right to Know (Categories) (available for California residents only): We verify your Request to Know Categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. If we cannot do so, we will refer you to this Notice for a general description of our data practices.
Right to Know (Specific Pieces): We verify your Request To Know Specific Pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you and may require a signed declaration under penalty of perjury that you are the Consumer whose PI is the subject of the request. If you fail to provide requested information, we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know Categories Request if you are a California resident.
Do Not Sell/Share/Target & Limit SPI: No specific verification required unless we suspect fraud.
Right to Delete: We verify your Request to Delete to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized deletion. If we cannot verify you sufficiently to honor a deletion request, you can still make a Do Not Sell/Share/Target and/or Limit SPI request.
Correction: We verify your Request to Correct PI to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the Consumer posed by unauthorized correction.
To protect Consumers, if we are unable to verify you sufficiently we will be unable to honor your request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
b. Agent Requests
You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority to submit requests on your behalf, and of you. You can learn how to do this, emailing us here. In order to, submit an agent request, the agent must provide us with written permission signed by the Consumer or a lawful power of attorney, when you submit the request or in response to our confirmation email if you did not submit it with the request. In certain instances, we may require the Consumer to verify their own identity directly with us or directly confirm with the Consumer that they provided the agent with permission. In certain circumstances, we may require additional information or documentation. Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable U.S. Privacy Laws.
c. Appeals (Colorado)
Residents of Colorado, may appeal Telegraph Media Group’s decision regarding a request by replying to our Response.
viii. Our Responses
Some PI that we maintain is insufficiently specific for us to be able to associate it with a verified Consumer (e.g., clickstream data tied only to a pseudonymous browser ID). We do not include that PI in response to those requests if we cannot associate it with a verified Consumer. If we deny a request, in whole or in part, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we Process to respond to your Consumer request(s). In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
Consistent with applicable U.S. Privacy Laws and our interest in the security of your PI, we will not deliver to you more sensitive PI such as your account password or payment information in response to a Consumer privacy rights request; however, you may be able to access some of this information yourself through your account if you have an active account with us.
C. Non-Discrimination/non-retaliation
We will not discriminate or retaliate against you in a manner prohibited by applicable U.S. Privacy Laws for your exercise of your Consumer privacy rights. If you wish to delete some or all of your PI, and wish to remain in a Notice of Financial Incentive Program (as explained below), you are able to do so. We may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable PI.
D. Notice of Financial Incentive Programs
We may offer discounts or other rewards (“Incentives”) from time-to-time to Consumers that register to view articles (“Registrants”) on our Service. We collect certain pieces of PI from Registrants, such as name, phone number, e-mail address, IP address, or location which are used to administer the Incentives to Registrants and reasonably necessary to provide the Incentives. You may opt-in to Incentives by registering to access a limited number of free articles a month (subject to our standard terms and conditions, or other loyalty and Incentive programs we may offer from time-to-time (“Program(s)”). Each Program is subject to our standard terms and conditions and may have additional terms (“Program Terms”), available on the specific Program page or at Program sign-up. The Incentives will be described in the Program page, or at Program sign-up. As the value of the Incentive may change from time to time, please review the current applicable Program Terms. We measure the value of your PI collected in the Program as value of the advertising revenue generated per article view by a U.S. Registrant. We value the Program as the additional revenue generated per article view. We deem the value of the PI to be reasonably related to the value of the Incentive, and by subscribing to these Programs you indicate you agree. If you do not agree to the Program Terms and do not agree that the value of your PI collected is reasonably related to the value of the Incentive, do not subscribe to the Programs. If you subsequently wish to withdraw from the Programs, the method for doing so will be explained in the Program terms or you may contact us by email at data.protection@telegraph.co.uk, and you may withdraw at any time. We do not limit Program participation to consumers that do not exercise their CCPA rights. However, if you submit a deletion request, and inform us that you wish to remain in the program, we will retain the PI necessary to administer the Program. If you do not want us to retain your information to administer the Program, then we will also terminate your participation in the Program.
E. Our Rights and the Rights of Others
Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your rights under U.S. Privacy Laws. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.
i. Additional Notice for California Residents
In addition to the CCPA, certain Californians are entitled to certain other notices, as follows:
This Notice provides information on our online practices and your California rights specific to our online services. Without limitation, Californians that visit our online services and seek to acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:
(1) California Minors
Although our services are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our services, and posted content on the service, can request removal by contacting us, detailing where the content is posted and attesting you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines we do not control.
(2) Shine the Light
We may share “personal information,” as defined by California’s “Shine the Light” law, with third parties for such third parties own direct marketing purposes. California residents may opt-out of this sharing by contacting us at data.protection@telegraph.co.uk. You must put the statement “Shine the Light Request” in the body of your correspondence. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. This right is different than, and in addition to, CCPA rights, and must be requested separately. However, a Do Not Sell/Share/Target opt-out is broader and will limit our sharing with third parties for their own direct marketing purposes without the need for making a separate Shine the Light request. We will not accept Shine the Light requests by telephone or by fax, and are not responsible for requests not labeled or sent properly, or that are incomplete.
F. Contact Us
If you have any questions, comments, or concerns about our U.S. privacy practices, please contact as outlined in Section 14. Please note that e-mail communications will not necessarily be secure; accordingly, you should not include sensitive information in your e-mail correspondence with us.
13. CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not treat your previously collected Telegraph Media Group-Collected PII, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. If you have a subscription to the Service, material changes to the Privacy Policy will only become effective with respect to the aspect of that subscription Service at the end of the then current term unless you otherwise consent to the new Privacy Policy. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
14. CONTACT TELEGRAPH MEDIA GROUP
If you have any questions about this Privacy Policy, please contact Telegraph Media Group by email here. If you have any conditions requiring special accommodation, please let us know.
© Telegraph Media Group 29th September 2024. All Rights Reserved.
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(2) Service cookies that help us to make our website work as efficiently as possible; remember your registration and login details; remember your settings preferences; to detect what device you are using and adapt how we present our services according to the screen size of that device; and meter the number of pages you view for the purpose of administering subscriptions to The Telegraph.
(3) Third party advertising and analytics cookies, which are placed by or on behalf of independent advertisers who are advertising on our site. These cookies may be placed within the advertisement and elsewhere on our site by us or by your browser. They can allow the advertiser or your browser to tailor advertising to you when you visit other websites. They are used for statistical analysis by allowing the advertiser to count how many people have seen their advertisement or have seen it more than once, to make sure you are not repeatedly served with the same advertising messages.
(4) We also place third party cookies to enable the serving of our own advertisements, (for example, for our subscriptions offers), on our own website or other websites. These advertisements will be based on your browsing behaviour on our website and will be tailored to your interests. The information we gather from your visit is limited to page URLs. For instance, if you are particularly interested in Food and Drink articles, the subscription offer advertisements served to you when you visit your Facebook account will feature our Food and Drink content.
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The Telegraph Media Group is a trusted and respected media brand, committed to providing journalism of the highest quality and integrity. As such we have obligations to our readers, viewers and the wider public, but also to our advertisers, suppliers and partners.
Our brand and our values are our most vital assets. Their maintenance depends on our commitment to the core journalistic values of accuracy, fairness and fearless reporting in the public interest.
Our ability to provide high quality journalism depends on commercial success. In a fast-changing media world, we must innovate to achieve that success, while at all times ensuring we preserve editorial independence, which is paramount to the integrity of all our products.
These guiding principles outline standards of good practice which are to be observed and maintained by all employees, contractors and freelancers who provide services to the Company.
They will form an ongoing part of training for all staff.
Telegraph staff must be familiar with and observe all relevant industry Codes.
The Editors' Code of Practice administered by the Independent Press Standards Organisation (IPSO) stipulates that the press must take care not to publish inaccurate, misleading or distorted information.
The Advertising Code administered by the Committee of Advertising Practice (CAP Code) and enforced by the Advertising Standards Authority, lays down rules for advertisers, agencies and media owners to follow. Under the Code advertising must be responsible, and not mislead, harm or offend its audience. Particular rules cover advertising to children and specific sectors such as alcohol, gambling, motoring, health and financial products.
The Content and Native Disclosure Guidelines issued by the Internet Advertising Bureau UK (IAB) set out principles of best practice to promote continued growth in innovative areas of advertising.
It is entirely appropriate, and indeed essential, that editorial staff understand and contribute to the commercial success of the Telegraph. However, editorial independence must always be maintained. Commercial staff should not influence editorial’s story judgments in connection with any advertiser’s or potential advertiser’s interest. The final decision on all editorial content is the Editor’s.
Any commercially paid content beyond traditional advertisements must be clearly and appropriately marked as per protocols.
It is perfectly proper for journalists to write content that is paid for commercially, provided that it is clearly marked as such. In undertaking such tasks, journalists should do nothing to compromise their ability to write for our audience objectively, fairly and honestly.
If a company has provided any significant free products or services to assist with editorial this must be appropriately noted.
Uses of social media to promote a company’s product or services must be clearly marked as commercial content and must comply with the CAP Code and TMG protocols.
TMG staff who have personal social media accounts should also follow the CAP Code if promoting a commercial campaign.
All payments to staff and contributors for the creation of commercial content must be approved by their line manager in advance in writing. Commercially funded positions in editorial are permitted but hires must be made by editorial and such staff must work to editorial contracts and in line with editorial standards.
All commercial campaigns involving editorial should adhere to these guidelines, Codes and accompanying protocols. They must have senior editorial executive signoff before they are agreed.
Complex, exceptional or controversial issues will be escalated to a weekly editorialcommercial meeting for signoff. Matters that cannot be resolved there will be escalated to the Editor, the commercial director and the chief financial officer.
The Editor’s decision on the use of editorial placements in relation to a campaign shall be final.
If you are ever in doubt about any matter concerning business conduct, please seek advice from any senior member of your executive team.
• IPSO Editors' Code of Practice
This Statement has been prepared on a consolidated basis on behalf of both The Telegraph Media Group Limited (“TMG”) and The Chelsea Magazine Company (“CMC”), a subsidiary of TMG (together, the “Telegraph Media Group”). The Telegraph Media Group is committed to acting ethically and with integrity in all our business dealings and relationships and this statement sets out the actions the Telegraph Media Group has taken to endeavour to ensure that our corporate activities and supply chains are free from modern slavery and human trafficking during the financial year ended 31 December 2023 (“Year”).
TMG is a limited company registered in England and Wales whose registered office is at 111 Buckingham Palace Road, London, SW1W 0DT, with registered number 14551860. CMC is a limited company registered in England and Wales whose registered office is at 111 Buckingham Palace Road, London, SW1W 0DT, with registered number 06081165.
TMG is a multi-platform media organisation and the publisher of The Daily Telegraph, The Sunday Telegraph, The Telegraph Magazine, www.telegraph.co.uk, and the Telegraph app.
CMC is a print magazine and digital publisher of lifestyle and sporting content with a wide range of brands as listed on www.chelseamagazines.com.
The Telegraph Media Group is based in the UK and has a large global audience. The Telegraph Media Group engages a variety of suppliers for different services. Our operations and supply chain relate mainly to the following services: printing and distribution, building and office services, events services, media services, recruitment, technology, training, marketing and advertising, customer services and retail.
We strive to maintain high standards of conduct and ethical behaviour from our employees and our suppliers:
Policies:
We have a Modern Slavery policy which we have embedded in our Staff Handbook. This makes it clear what behaviour is expected of our employees in respect of modern slavery.
Whistleblowing:
Our whistleblowing policy encourages our employees, customers, business partners and suppliers, to report any concerns, including any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
Business Code of Conduct:
All our Suppliers are required to confirm that they comply with our “Supplier Business Code of Conduct” before they do business with us. This sets out requirements that Suppliers provide safe working conditions, treat workers with dignity and respect and act ethically and within the law in their use of labour. We undertake a higher level of due diligence, if there is a higher risk of modern slavery.
Enhanced Monitoring:
At present there have been no suppliers who have been identified during the due diligence process as high risk suppliers. Should any suppliers be identified as having a higher potential for modern slavery then this supplier would be monitored and investigated more closely by our procurement and compliance teams. Where applicable, modern slavery provisions are included in contracts.
Employee assurance:
We require all staff (whether permanent, fixed term, temporary or freelance) to demonstrate that they possess appropriate right-to-work documentation.
We provide our staff with training on our modern slavery obligations and emphasise the importance of our Supplier Business Code of Conduct. New joiners are assigned a modern slavery training module to complete as part of their probation. The training module and modern slavery policy are available year-round to existing staff. We take our modern slavery obligations very seriously and will continue to monitor compliance on an on-going basis and look for new ways to enhance the training on offer.
This statement has been approved by the Telegraph Media Group’s Board of Directors, who will review and update it annually.
Anna Jones Chief Executive on behalf of the Board of Directors
26th June 2024
Introduction
Press Acquisitions Limited is the head of a UK ‘sub-group’ (“the Group”) as defined in paragraph 11 (2) of Schedule 19 of the Finances Act 2016. This strategy is published on behalf of the Group in compliance with the duty under paragraph 19 of the schedule and in accordance with paragraph 20 thereof.
Telegraph Media Group Holdings Limited is a subsidiary of Press Acquisitions Limited and trades as The Telegraph, an award-winning, multimedia news brand that has been synonymous with quality, authority and credibility for more than 160 years. The core business is the publication of high-quality journalism in print and online of the following newspaper titles: The Daily Telegraph, The Sunday Telegraph and The Telegraph (a weekly world edition), plus the website www.telegraph.co.uk. Telegraph Media Group Holdings Limited acquired the trading business from Telegraph Media Group Limited in a group reorganisation on 29 September 2024.
Approach to risk management and governance
The Group is committed to executing and managing its tax responsibilities with the highest integrity and complying with all applicable tax laws. The Group has appropriate governance, policies and processes in place to ensure its tax obligations are met from an operational and risk management perspective.
Its internal policies and processes facilitate the structured identification, assessment and management of tax risk. Responsibility for the day-to-day management of UK tax risk resides with the Chief Financial Officer, supported by the Head of Tax. The Senior Accounting Officer is an independent director who overseas risk management and governance with support from advisers where appropriate.
Attitude towards tax planning
The Group manages its tax affairs to support the business, adopting an approach that preserves the commercial purpose of intended transactions whilst evaluating the use of appropriate tax strategies, including accessing tax incentives and reliefs. Key tax decisions are made by tax professionals with the appropriate level of knowledge and expertise.
The level of risk in relation to UK taxation that the Group is prepared to accept
The Group’s approach on tax policy is to maintain a low-risk tax profile both in the UK and in other tax jurisdictions.
Where applicable laws and regulations are subject to interpretation, giving rise to inevitable complexity and uncertainty, we seek appropriate assurance regarding the position taken from reputable third party advisers. The Board of Directors has oversight over how tax risks are managed as well as ensuring there are appropriate controls.
Approach to dealing with tax authorities
The Group engages with HMRC on a real-time basis in a spirit of co-operative compliance. The Group works closely with HMRC, maintaining continual dialogue in an open, honest and transparent manner, acting fairly, responsibly and with integrity. We seek to resolve any errors or disputed matters through pro-active and transparent discussion and negotiation with HMRC.