About us

Berw Ltd is the company limited-by-guarantee (with no share capital) which publishes Planet: the Welsh Internationalist magazine in print and digital formats, free online features on Planet Extra and book titles as Planet Books.

Berw Ltd is the data controller and responsible for your personal data (collectively referred to as ‘we’, ‘us’ or ‘our’ in this privacy policy). Personal data means any information about an individual from which that person can be identified.

This privacy policy aims to give you information on how Berw Ltd collects and processes your personal data, including any data you may provide when you (e.g.) become a subscriber, contact us, purchase a publication or other product, take part in a competition, login to manage your digital subscription, submit an advertisement, write an article for us or give us feedback. This website and the products and services provided by Berw Ltd are not intended for children and we do not knowingly collect data relating to children.

Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

How personal data is collected, and the purposes of processing personal data

    We use different methods to collect data from and about you including via the following:

  • Direct interactions: You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, Facebook or Twitter direct message or otherwise.

  • Publicly available information: we may use publicly available contact details for individuals for the purposes of commissioning an article, or organisations for soliciting advertisements, for example.

  • Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, for example. Please see below for more information about cookies.

  • We also receive Contact, Financial and Transaction Data from providers of technical, payment and delivery services, for example Paypal, Amazon or BACS.

  • We only use your personal data when the law allows us to. Most commonly, we use your personal data for the following purposes:
    Processing and delivering your magazine or book order, managing your magazine subscription, marketing, commissioning features, sourcing advertisements, distributing the magazine in shops or at events.

Cookies

    Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

  • The digital format of Planet magazine (‘Planet Online’) is exclusively available to individual subscribers via username and password and is provided by the October CMS platform. A cookie enables this access and is essential to provide this online service. It enables your computer to remember you are logged in, and also gives you the option of remembering your username and password.

  • We use Google Analytics data to analyse how our website is used. This is vital for informing us which web-pages and online articles are popular with users and our readers thereby enabling us to improve our content, for giving an estimate of unique visitor numbers for online articles to funders such as the Welsh Books Council to justify continued support, to give us a sense of which areas of the world (country or city) our users are based through aggregate data, and to provide potential advertising clients with an average estimate of page users. No personally identifiable information is made available to ourselves via Google Analytics, nor is it sent to Google Analytics from the website, rather the data they process is in the form of online identifiers: IP addresses, cookie identifiers and device identifiers.

How to opt out

You may refuse to accept cookies by changing the setting on your browser on your computer, or in your mobile device’s settings. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site. There are a number of ways that you can remove or block cookies at any time, for example by following the help file directions in your internet browser. Further information about cookies, and how to manage them can be found here: http://www.aboutcookies.org/DEFAULT.ASPX?page=2.

Third party cookies

Please note that third parties we link to from our website (including websites which advertise on our system, and the online payment system Paypal) may also use cookies, over which we have no control. Please also note that we have no access to third party cookies and third parties do not have access to the cookies that we use on our website. Any third parties linked to from our site who use cookies should have their own cookie and privacy policies. Please refer to their website for more information about this.

Our legal bases for processing personal data

    Under the General Data Protection Regulation (GDPR) there are 6 legal bases for processing personal data: ‘consent’, ‘contract’, ‘legal obligation’, ‘vital interests’, ‘public task’ and ‘legitimate interests’. See below for a list of the legal bases for the most common uses of personal data we undertake, plus more detail about our ‘legitimate interests’:

  • Processing and delivering your magazine or book order: contract and legitimate interest

  • Managing your magazine subscription in print and digital formats: contract and legitimate interest

  • Marketing the magazine or books: contract, legitimate interest

  • Commissioning features and book titles: contract, legitimate interest

  • Sourcing advertisements: contract, legitimate interest

  • Distributing the magazine to shops and at events: contract, legitimate interest

  • Distributing an e-newsletter: consent

  • Considering magazine and book manuscript submissions: legitimate interest

  • The process of editing written, visual or multimedia material: contract, legitimate interest

  • Correspondence with supporters, patrons & funders: contract, legitimate interest

  • Correspondence regarding feedback about our activities and related debate in the public interest: legitimate interest

  • Processing job or student placement applications: contract, legitimate interest

  • Using data collected through cookies: contract, legitimate interests

If we are not able to receive and process the required personal data from you, we may not be able to fulfil our contractual obligations to you. For example, it is essential that we have your email address for us to be able to give you access to Planet in digital format.

Our legal bases for processing information are determined also by the Data Protection Act 2018. This gives exemptions from certain GDPR provisions if the personal data is being processed for the special purposes with a view to publication by a person of journalistic, academic, artistic and literary material in the public interest. It also gives exemptions from certain GDPR provisions if the personal data is being processed for archiving, research and statistical purposes. More information can be found here: https://www.gov.uk/government/collections/data-protection-act-2018

Our legitimate interests

    These include the following:

  • Sustaining new magazine and book sales, magazine subscriptions and our renewal rate which is essential for our business model and in the public interest as a company which receives public funds to publish for the public good.

  • Marketing and distributing the magazine and books, and sustaining enough income and contributions in kind in ways which are both essential for our commercial interests and in the public interest as a company which receives public funds to publish for the public good.

  • Developing an awareness of the demographic of our readership in order to publish work which is relevant to our readers.

  • The ability to swiftly contact potential contributors for forthcoming publication.

  • Correspondence to enable the editing of material to the highest standards, and maintaining professional relationships with our contributors.

  • Retaining correspondence and other documentation of cultural value and/or in the public interest as a long-standing publicly funded publisher for archival purposes.

  • Correspondence with our authors and supporters to enable us to fulfil our role as a vital contributor to cultural and political debate and the wider public sphere in Wales.

  • Encouraging and retaining correspondence from readers giving feedback on the material we publish to ensure we continue to produce work of the highest quality, and which is popular with our readers.

  • Recruiting employees, freelancers and students on placement in the best interests of Berw Ltd, and in line with the principles of fairness, transparency and equality of opportunity.

  • Sourcing and retaining correspondence and other documents which include endorsements from readers, authors, patrons, supporters to (e.g.) make a strong case for the continuation of our funding, or to pursue new forms of support, to encourage authors to contribute or organisations to advertise. Consent would be sought to share any endorsement communicated in correspondence with third parties.

  • Beyond legal obligations, enabling and retaining correspondence and other documents to effectively fulfil our general obligations to and maintain professional relationships with those who submit work for potential publication, to our funders (public and private), advertisers, Board members, Advisory Board members, complainants, etc.

  • Contacting individuals to pass on a message from a third party or ask if their contact details can be passed on to the third party if in the significant interests of the individual or significant cultural/journalistic/public interest.

  • Initiating and retaining correspondence and other documentation as evidence to protect Berw Ltd and the magazine from potential defamatory claims, copyright infringement claims or other legal claims, as a long-standing business and publisher which receives public funds.

  • Using data collected via cookies to inform us which web-pages and online articles are popular with users and our readers thereby enabling us to improve our content, for giving an estimate of unique visitor figures for online articles to funders such as the Welsh Books Council to justify continued support, to give us a sense of which areas of the world (country or city) our users are based through aggregate data, and to provide potential advertising clients with an average estimate of page users.

Access and control of your personal information

Updating your information

Please ensure you update your personal information or tell us if it changes or is inaccurate. The best contact for this is [email protected] or you can ring 01970 611255 or get in touch via Planet, PO Box 44, Aberystwyth, Ceredigion, SY23 3ZZ.

Withdrawing consent for processing

Where we may rely on your consent to process personal information, you have the right to withdraw that consent at any time. With regard to our e-newsletter, this can be managed through MailChimp settings. Otherwise, please contact us with details of your request. In some instances we may still have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent we may not be able to provide the product or service you have requested.

Other rights

You may request a copy of your personal information from us. You can also ask us to correct any inaccuracies in your personal information. In some circumstances you may be able to ask us to transfer information you have provided to us to another organisation.

You may also have the right to object, erase, or restrict our processing of your information – for example, where we process personal data because this is in our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data.

To exercise any of these rights, please contact us. These rights may be restricted by law, for example we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.

Complaints

If you have a comment, concern, suggestion or complaint, please contact us at [email protected] or ring 01970 611255, or get in touch via Planet, PO Box 44, Aberystwyth, Ceredigion, SY23 3ZZ. If you have a complaint and we cannot resolve the matter, you have the right to complain to the Information Commissioner’s Office in the UK https://ico.org.uk/ . Alternatively you may contact the data protection regulator responsible for your country or region.

Data security and third parties

We have put in place security measures to prevent a data breach, i.e. your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Also, we limit access to your personal data to those employees, agents, contractors, volunteers and other trusted third parties (such as our accountant and website developer and host) who have a legitimate need to know for commercial or legal reasons. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We would not under any circumstances sell your personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Retention of personal information

We will retain your information for as long as necessary for the uses set out in this Policy, or while there is another legitimate reason for doing so. If you ask us to delete your information before that time, we may not be able to do so due to technical, legal, regulatory or contractual constraints. For example, we would need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.

Changes to this policy

From time to time, we make changes to our Privacy Policy and Cookie Policy. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal information. Where necessary, we will seek your consent to these changes. We will always display clearly when the privacy policy was last amended on this webpage.

Privacy policy last amended on: 24.05.18