Privacy policy

1. What we do not do

• No third-party analytics. We do not use Google Analytics or anything equivalent.
• No data selling. We do not sell your data or pass it to third parties for their own marketing.

2. Data controller

The controller is Trocalia Digital S.L. (trading as Troc Media), Spanish tax ID (CIF) B70751490, registered office in Barcelona. For anything concerning your data, write to us at info@northwestmercury.co.uk.

3. What data we process, why, and on what basis

We process data in four distinct situations. For each we state the purpose, the legal basis and how long we keep it.

• a) When you visit the site. We measure our audience in aggregate, without cookies and without storing your IP address. Like any website, the server keeps technical access logs for a limited time, for security. Legal basis: our legitimate interest (Art. 6(1)(f) GDPR). Retention: as long as needed to produce statistics and keep the site secure.
• b) When you write to us through a form. We collect your name, email, website if you give one, and your message, for the sole purpose of replying. Legal basis: steps taken at your request prior to entering into a contract, and our legitimate interest in answering enquiries (Art. 6(1)(b) and 6(1)(f) GDPR). Retention: as long as needed to handle the enquiry and evidence our reply.
• c) When you buy a publication. If you start preparing a publication, we save the draft and your contact details so that you can complete it. When you buy, we process your contact and billing details. Payment and invoicing are handled by Stripe, which collects the payment data directly: we never see or store the card number. Legal basis: for the draft, steps taken at your request prior to entering into a contract and our legitimate interest (Art. 6(1)(b) and 6(1)(f) GDPR); for the purchase, performance of the contract (Art. 6(1)(b)) and, for tax matters, compliance with legal obligations (Art. 6(1)(c)). Retention: the draft, for as long as it is useful or until you ask us to delete it; tax records for the statutory periods (4 years for tax purposes and 6 under the Spanish Commercial Code).
• d) If you are a company we offer our services to. We process the company’s professional contact details (business name, email, website and town), obtained from publicly accessible sources such as its own website, in order to offer it our services. We write only to companies, organisations and professionals. We record interaction with our commercial messages in order to manage them. Legal basis: our legitimate interest (Art. 6(1)(f) GDPR). Retention: for as long as you do not object. You can object at any time using the unsubscribe link included in every message. If you unsubscribe, we keep your address solely so that we do not write to you again.

4. Cookies

If you only read the newspaper, we use no cookies. Only when you arrive from a link in our communications do we use first-party technical cookies, needed to show you the relevant page. We use no advertising or third-party cookies. You can delete them from your browser settings.

5. Who else processes this data

To operate we rely on the following providers, which process data on our behalf and on our instructions:

• Stripe: payments, invoicing and payment data.
• Hosting and email delivery providers.
• Artificial intelligence providers that help us write and translate content; they never receive reader data.

We may also disclose data to public authorities, courts and law enforcement where a legal rule requires it. Outside those cases, we do not share data with third parties.

6. International transfers

Our servers are in the European Union, but some providers (payments, email and artificial intelligence) may process data outside the European Economic Area. Where that happens, the transfer relies on the mechanisms under Chapter V GDPR, such as the standard contractual clauses approved by the European Commission or an adequacy decision.

7. Your rights

You may at any time exercise your rights of access, rectification, erasure, objection, restriction of processing and portability, and object to receiving commercial messages. Simply write to info@northwestmercury.co.uk saying which right you wish to exercise; we will reply within one month at the latest.

If you believe we have not handled your request properly, you have the right to lodge a complaint with the Spanish Data Protection Agency (C/ Jorge Juan 6, 28001 Madrid — www.aepd.es), which is the competent supervisory authority, or with the supervisory authority of the European Union country in which you live.

8. Minors

Neither reading the newspaper nor buying a publication is directed at minors, and we do not knowingly collect data from minors.

9. Changes to this policy

If we change how we process data we will update this page and its revision date. We suggest checking back from time to time.