Data controller: First Group Enterprises Limited, First Floor, 58 Southwark Bridge Road, London, SE1 0AS
ICO registered number: Z2416755, VAT number: GB865036224, Company number: 05705759
Our promise to you
At First Group Enterprises Ltd, we are committed to protecting the privacy of all customers and visitors to our websites. Our privacy policy covers areas that, as users and parents ourselves, we would like explained clearly.
First Group Enterprises Ltd is the owner of First News, First Wonder Box and First Careers. We are a family owned business and the sole owner of information collected on this site. We are also the data controller for information required to process orders.
The only personal data we collect from you is the information required to process your order and manage your subscription in the most effective way. This includes name, address and date of birth details of the children receiving our products. This information is required to ensure that we are providing relevant products that are age-appropriate.
We do not share your personal data with any third parties other than those involved in the administration of your subscription e.g. our mailing house or a customer service agent. All our contracted processors of personal information have signed a contract with us to provide at least the same processes to protect your personal data.
We will never knowingly contact any child directly, other than to deliver the product that has been ordered.
We will always process personal data securely and in accordance with the General Data Protection Regulation, 25 May 2018.
At the end of your subscription term, we will hold your data for a period of 3 years and transaction details for 6 years plus 1 in accordance with the HMRC regulations. This enables us to renew your subscription easily, should you choose to re-subscribe. It also enables us to remind you that your subscription has lapsed and to offer you preferential rates or alternative products. After this time we will delete the data we hold on you.
We will not market to you beyond 3 years after your subscription has lapsed and any communications we do send are to ensure you don’t miss out on promotions about new products that might interest you or the children in your lives.
Our Privacy Policy in detail
Subscription data
The information we collect
When taking orders, we process your data within the lawful basis of ‘contractual obligation’. This means we only take information from you which is required in order to process your subscription and give you (or the recipient) the best possible customer experience. We will ask you to submit the name and delivery address of the recipient (often a child under 16 years of age) and the name, address and contact details (phone number and email address) of the person placing the order (the purchaser). For First Wonder Box orders we also ask for the month and year of birth, plus the gender of the child. We take this information so that we can tailor boxes to the demographic of our customers later on in the subscription series and recommend other First Group Enterprise Ltd products, which may be of interest. We believe this will give our customers the best experience of our product.
Our lawful basis for processing your personal data.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we need to comply with a legal or regulatory obligation.
- Where we have your consent
Legitimate Interest means the interest of our business to enable us to give the best service possible to the recipients and purchasers of our products. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at data@firstnews.co.uk
As required under GDPR we have conducted a Legitimate Interest Assessment in relation to sending marketing material. We assessed the balance of your rights with ours and we believe that you will not be disadvantaged by receiving our communications and we can demonstrate under GDPR that we have a legitimate interest in using your data for marketing purposes. You always have a choice of opting out or unsubscribing or by contacting us at unsubscribe@firstnews.co.uk
How we use your data
The data we collect is used to process orders. We will never contact a child directly (other than the physical delivery of their product). All other correspondence will be conducted directly with the purchaser. We will store the contact details that were given to us at the time of purchase (unless these are later changed by you). This is to ensure a good service and effective communication. The purchaser may be contacted regarding delivery issues, changes to the service, changes in payment terms or any other service related issues.
If you have an active subscription with us we will send you a weekly email newsletter to let you know what we will be covering in the latest issue of First News. These emails give adults an opportunity to discuss topics with children and also address more difficult news stories (we are often asked to provide guidance to adults on difficult topics). Unless you have asked not to be contacted through a specific channel, we may also send you emails, letters through the post and phone you from time to time to let you know about other products from First Group Enterprises that may be of interested to you.
If you would like to unsubscribe from any of these communication channels, please send an email to unsubscribe@firstnews.co.uk We communicate by post, email, SMS and phone. Please let us know which channels you would prefer us not to use when contacting you with marketing messages. As long as you are an active customer, we will continue to send you important information about your subscription via the most appropriate channel.
You will be given a straight-forward way to opt-out of our marketing communications each time you are contacted.
We may share your personal data with a third-party auditing organisation (ABC) so they can verify aggregated statistics about circulation and usage of our products or review our policies, processes and procedures for compliance with relevant standards. You can view their privacy policy at www.abc.org.uk/privacy-policy
Storage of data
Data is stored securely with First Group Enterprises Ltd and our thoroughly vetted third parties. These third parties are essential to the processing of orders. Whilst First Group Enterprises Ltd is the controller of the data, our third party suppliers also strictly follow the GDPR legislation dated 25 May 2018. Data is not shared beyond our contracted third parties.
At the end of your subscription term, we will store your data for a period of 3 years. This enables us to renew your subscription easily, should you choose to re-subscribe. It also enables us to remind you that your subscription has lapsed, offer you preferential rates and to recommend other relevant First Group Enterprises Ltd products that we think may be of interest to you. We also store your transaction details for 6 years plus 1 in accordance with the HMRC regulations.
Once the 3-year period comes to an end, your individual data (except transactional data) will be deleted in a secure manner and you will receive no further direct contact from First Group Enterprises Ltd.
Your rights
You have some improved rights under the GDPR.
- Data Subject Access Request: You have the right to access the personal information we may hold about you. On receipt of such a request we will endeavour to respond to you as soon as possible, but at least within one calendar month. You must provide us with 2 forms of personal identity to ensure that we only disclose to you information which is relevant to you personally. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- Rectification: You have the right to request that we amend any personal information that may be incorrect or require updating.
- Erasure: You have the right to request that we delete any personal information pertaining to you. Any questions about these rights may be sent to data@firstnews.co.uk.
- The right to restrict processing. Individuals have a right to ‘block’ or suppress processing of personal data. If you decide to do this, we will continue to store the data, but not further process it until we have agreed a solution to the issue you have raised.
Competition Data
What data do we collect?
In order to enter competitions online, entrants must register via our website www.firstnews.co.uk. Registration data required includes name, age bracket, address, email address and phone number. We also ask for parent/carer’s details (name, address, email and phone number). A notification is sent by email to the parent (or carer) when a child requests to register on the website. The parent/carer is required to approve this in order for the registration to be complete and for the child to participate in any activity.
Why do we collect it?
Competition data is collected so that winners can be notified if they have won a competition. This is normally sent via email to the parent, but in some cases we contact the child directly, by means of a letter and/or congratulations certificate, along with their prize. Age bracket – for example 13-15 – is required, as some competition prizes have age restrictions.
How do we store it?
If a competition has been entered by post, the physical entry is kept in a locked cupboard and then shredded once the competition winner has been selected and notified. If the entry is made via our website, the details are stored securely in the back end of the website and then deleted from our systems once the winner has been notified.
Winners’ details are kept in a locked folder on our server, only the competition manager has access to this.
Why do we store winners’ data and for how long?
We keep winners’ details to allow First Group Enterprises Ltd and prize providers to contact winners and ensure prizes are delivered and received as per each individual competition prize offered.
Winners’ entries are kept for six months and then all data is deleted/shredded. All other competition entries are deleted from the system or website and/or shredded once the winner has been notified and the prize accepted.
Surveys
First Group Enterprises Ltd, working in partnership with Opinion Matters, will occasionally feature surveys to get children’s views on topics which concern them. We will only share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person.
First Group Enterprises Ltd works with Survey Monkey to gather feedback from our customers regarding our products and services. We use this information to improve our products and services.
We only hold personally identifiable data for customers who have chosen to supply this to us (often to be entered into a competition or if they would like further communication following their feedback from a survey). Such information is stored securely and deleted once the purpose of collection has been realised. The data is stored on a secure server hosted by Survey Monkey whose privacy policy gives details of the steps they have taken to ensure the security of your personal data.
Website Data
Like most websites, firstnews.co.uk and firstwonderbox.co.uk collect data from users at several different points on our website. We only share aggregated demographic information for Under 16s with our partners and advertisers. In plain English, this means that we don’t share data that is linked to any personal information or can be used to identify any individual.
Additionally, we will only share personal information for Over 16s if you tell us we can.
We do not sell, share, or rent this information to others in any way that differs from this statement. By registering or placing an order on this website, you consent to the collection, use and transfer of your information under the terms of this policy.
Storage of website data
Stored and processed under the General Data Protection Regulations and the Data Protection Act 2018 and is not processed outside the EEA. We operate a retention policy to allow us to keep data for the minimum amount of time necessary and therefore we delete your data at various intervals according to this.
How we use Cookies on our websites
A cookie is a small text file that is stored on a user’s computer for tracking and record-keeping purposes. We use session cookies to allow you to sign in to our site easily, and you can remove cookies via your browser’s ‘clear cookie’ function. Please see allaboutcookies.org for more information about blocking cookies on your particular web browser. You can read further details on the cookies that we use below.
Unless you have adjusted your browser setting so that it will refuse cookies, we will drop cookies as soon as you visit our site.
By agreeing to the terms of this privacy policy, you consent to the cookies referenced above being dropped onto your machine.
What we share with Third Parties
We use an analytics company that drops cookies via our website to collect user data. This data helps us to understand how you use our website and contains no personally identifiable information about you.
We do not have access to or control over these cookies. More information about our cookies can be found below. By agreeing to the terms of this privacy policy, you consent to cookies being dropped onto your machine.
Cookie Information
PHPSESSID
The user’s current session id. This keeps track of the user as they move around the site. This is an essential cookie to the operation of the site.
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Google Analytics: We use Google Analytics to monitor traffic levels, search queries and visits to this website. These cookies enable Google to determine whether you are a return visitor to the site, and to track the pages that you visit during your session.
iHub Data and Privacy
The First News iHub is an interactive education platform, purchased and used by schools only.
Information you provide to us
We collect the information you provide to us so that we can deliver the Service. This information includes your name, email address and school name.
In order for pupils to register and log in, we collect their names and dates of birth; by collecting dates of birth, we allow two children from the same school with the same name to be identified when they register.
First Group Enterprises Ltd admin staff cannot access any personal data that you supply belonging to either adults or children, save that of the adult administrative contact who purchased the product initially.
First Group Enterprises Ltd does not process any data held within the iHub for any purpose, marketing or otherwise.
Information we collect automatically
We automatically collect basic functional information regarding the use of the iHub when you visit our iHub. This information is known as Functional Data and Additional Usage Data and it is collected using cookies and similar technologies when you use, access or interact with the iHub.
We may, for example, collect information about the type of device you use to access our iHub, the operating system and version you are using, your IP address, your general geographic location as indicated by your IP address, your browser type, the web pages you visit within the iHub, which ones you interact with and how.
How We Use Personal Information
First Group Enterprises uses the data collected to deliver the iHub service effectively and improve your experience. We also use the data to communicate with you. For example, we may need to update you about your account, introduce new products or services, or inform you about security and other technical updates. Please note, we NEVER communicate directly to the children. We use data for the following purposes:
Providing our Product Experience: We use data to provide, operate, support and improve the iHub service to ensure you can use the application as easily and smoothly as possible. This processing is necessary for the performance of the agreement we have with you.
Customer Support: We use data to respond to customer enquiries, diagnose Product problems, and provide other customer care and support services. This processing is necessary for the performance of the agreement we have with you.
Product Improvement: We continually use data for research purposes and to develop and improve our Products and Services. We develop and add new features and capabilities, using error reports to improve security features, using search queries and clicks to improve the relevance of search results and using usage data to determine what new features to prioritise.
Security, Safety and Dispute Resolution: We use data to protect the security and safety of the iHub and our customers, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.
Business Operations: We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.
Communication, Marketing and Advertising: We use the data we collect to deliver and personalise our communications with you. For example, we may contact you by email to inform you about new First Group Enterprises Ltd Products or Services, security or feature updates, update you on a support issue or invite you to take part in a survey.
Security, Storage and Retention of Personal Information We Collect
Security
While no Service is completely secure, we take precautionary measures to help prevent information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems in managed, controlled facilities. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transition over the Internet.
You can only access your iHub account information and our service through the use of an individual user login and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please notify us immediately if you believe your password has been misused. You should always log out and close your browser when you finish your session.
If you have any questions about the security of personal information submitted through the iHub, you can contact us at digital@firstnews.co.uk
General Privacy
Personal Information Security
First Group Enterprises Ltd security policies, rules and technical measures have been implemented to protect your personal information from unauthorised or improper use and from accidental loss. All employees that have access to and are associated with the processing of your personal data are legally obliged to respect the confidentiality of your data and are bound by contract to do so.
Privacy Support
If you have an enquiry or concern about our Privacy Notice, please contact: First Group Enterprises Ltd, 58 Southwark Bridge Road London, SE1 0AS. You have the right to complain if you believe there has been a security breach. In the first instance please contact us directly at newsdesk@firstnews.co.uk. You may also inform the Information Commissioners Office (ICO).
If we decide to change our Privacy Notice, we will post changes on this page so that you are always aware of what information we collect, how we use it and under which circumstances we disclose it.
In the event of any part of First Group Enterprises Ltd either being sold or going into receivership, we reserve the right to continue to share your data to third parties in accordance with the latest preferences you have provided. You will be informed should any change of ownership occur, and the new owner will manage your personal information preferences.
Address and contact details
The registered office for First Group Enterprises is 58, Southwark Bridge Road, London, SE1 0AS. You can contact us by phone on 0203 1952000 and by email on newsdesk@firstnews.co.uk