Privacy Policy

Privacy Policy

Please read this Privacy Policy to learn more about how we treat personally identifiable information. We provide this Privacy Policy because you have a right to know what information we collect, how it is protected and used, and the circumstances under which it may be disclosed. If you have comments, suggestions, questions, or concerns about our Privacy Policy, please contact us via email at contact@portalcorp.com or in writing at: Privacy Query: Portal Corp LTD, 51 Scrutton Street, City, London, EC2A 4PJ

Online Privacy Standards.

While there are limited official standards governing privacy practices on the internet, we follow the principles supported by the Federal Trade Commission’s Fair Information Practices Principles, currently available at https://www.ftc.gov/reports/privacy-online-fair-information-practices-electronic-marketplace-federal-trade-commission, the California Consumer Privacy Act of 2018 (“CCPA”), and the Data Protection Act 1998 and Regulation (EU) 2016/679 of the European Parliament and of the Council of the 27th of April 2016, General Data Protection Regulation (“GDPR”).

What This Policy Covers.

This policy covers Portal Corp LTD’s treatment of personally identifiable information that we obtain when you visit our website or use our services. We regard personally identifiable information as information that someone can use to identify or contact you in person, such as real name, telephone number, birth date, email address, or physical mailing address.

What This Policy Does Not Cover.

This policy does not cover the privacy practices of third parties that we do not own or control, such as our partners and advertisers. In addition, we may provide links to other services and on occasion to other sites that may interest you. All of these sites operate independently of Portal Corp LTD and they have their own privacy or security practices. For your best on-line experience, we encourage you to review their policies before submitting any personal information to them.

HOW WE COLLECT INFORMATION

INFORMATION YOU PROVIDE

Registration Information. During the email newsletter registration process, we collect your email address.

INFORMATION WE DO NOT COLLECT

Children. You must be 13 years of age or older to register to use our websites. Therefore, we do not knowingly collect personally identifiable information about children. If you believe that we have information from or about anyone under 13 years of age, please contact us via email at contact@portalcorp.com or in writing at: Privacy Query: Portal Corp LTD, 51 Scrutton Street, City, London, EC2A 4PJ. Additional regulations apply regarding California citizens, and for these please refer to the section below, “PRIVACY STATEMENT – CALIFORNIA.”

INFORMATION WE TRACK

Log Files. Similar to many websites, we gather certain anonymous, non-personal information automatically and store it in web server log files. This information includes internet protocol addresses, browser type, internet service provider (ISP), site entry/exit pages, operating system, date/time stamp, and clickstream data. We use this information to improve our site, analyse trends, administer the site, track users’ movements around the site, and gather aggregate information about our user base as a whole. Aggregate information is data we collect about a group or category of services or members from which individual member identities have been removed, and therefore does not include your personally identifiable information.

Cookies. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. It can also help us understand how our site visitors click to our site, and what pages they view during their visit. Similar to many websites, we store an encrypted cookie on your computer so we can remember you when you come back to our website without requiring you to log-in every time. Cookies also allow us to track and understand the interests of our users to enhance the overall experience on our site.

Our partners. Some of our business partners may also use cookies on our site. For example, some of our advertising partners may use cookies to collect non-personally identifiable information about your visit to our site in order to provide advertisements about goods and services that may be of interest to you. We have no access to or control over these cookies, and, as noted above, this privacy policy does not govern the use of cookies by our business partners or advertisers. To be excluded from these services, please visit some of our partners’ websites and follow the instructions provided.

• Google: http://www.google.com/privacy_ads.html

• Quantcast: http://www.quantcast.com/docs/display/legal/Opt-out+of+Quantcast+Delivery

You can set your web browser software to disable cookies. To do so, please refer to the help section of your specific browser for more information on how to manage or disable cookies. If you disable cookies, you may still view our site, but some areas of our site will not work properly.

HOW WE USE INFORMATION

Site Statistics. As noted above, we use information collected from our web log files to calculate and publish anonymous, non-personal, aggregate statistics that we believe our members are interested in viewing. For example, we track and publish the total number of users who have viewed a particular web page. We publish this data in aggregate form only, and do not tie it to any personally identifiable information.

For internal reporting and analysis. As noted above, we use information gathered from log files and cookies to improve our site, analyse trends, administer the site, track users’ movements around the site, and to gather aggregate information about our user base as a whole. We do not tie this data to personally identifiable information.

HOW WE SHARE AND DISCLOSE INFORMATION

WITH THIRD-PARTIES

Sharing, Renting, and Selling Information We Collect. We will neither rent nor sell your personally identifiable information to anyone. Occasionally we share anonymous, non-personal, or aggregate information about our user base with partners or advertisers, and we may publish these aggregate usage statistics on our website for the interest of our members. We do not tie this shared or published data to personally identifiable information.

AS NECESSARY IN LEGAL CIRCUMSTANCES

Legal Requirements. We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.

HOW WE KEEP INFORMATION SECURE

Network Security. We have implemented a variety of commercially standard security technologies and procedures to protect information, including your personal information, stored in our computer systems from unauthorised access. Please be aware that no method of transmission over the internet, or method of electronic storage, is 100% secure, thus we strive to use commercially acceptable means to protect your personal information, but we cannot guarantee its absolute security.

Management Procedures. We also maintain standard physical and electronic procedural safeguards that limit access to your personally identifiable information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, need to access your personally identifiable information.

YOUR PERSONAL CHOICES

Receiving Communications. If you subscribe to any optional promotional communications, you will be able to unsubscribe from through the emails we send you.

HOW WE RESPOND TO “DO NOT TRACK” SIGNALS

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to the web sites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how websites should interpret DNT signals, nor a common definition of “tracking”, we do not currently respond to DNT Signals on Portal Corp LTD websites. We engage in so-called online behavioural advertising on third-party sites (also sometimes called “retargeting” or “tracking”), through which information collected about the pages you visit on Portal Corp LTD websites is used to display ads for Portal Corp LTD services on third-party websites. This information may uniquely identify a browser but is not personally identifiable.

PRIVACY STATEMENT – CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained herein and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). Portal Corp LTD has adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We May Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (using “Identifiers”). In particular, we may have collected the following categories of information from consumers within the last twelve (12) months, if identified as ‘YES’ in the column titled ‘Collected’:

Collected information does not include:

• Information excluded from the CCPA’s scope, like:

  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

• Publicly available information from government records.

• De-identified or aggregated consumer information.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly and indirectly from activity on our websites. For example, from keywords input through the search forms on our websites or website usage details collected automatically.

• Indirectly based on criteria that may be used in marketing campaigns. For example, targeting marketing campaigns to women in a given geographic region with an interest in certain entertainment news.

• From third parties that interact with us and our websites in connection with the advertising services we sell. For example, advertisers who may target advertising on our websites to women in a given geographic region with an interest in certain entertainment news.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, from keywords input through the search forms on our websites.

• To provide you with information, products or services that you request from our websites.

• To provide you with email newsletters concerning our websites or news that may be of interest to you.

• To improve our website and present its contents to you.

• For testing, research, analysis and product development.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

• To evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Collected Information

We may disclose your collected information to a Service Provider or Third Party for a business purpose.  When we disclose collected information for a business purpose, we enter a contract that describes the purpose and requires the recipient to not use it for any purpose except performing the contract.

In the preceding twelve (12) months, the following categories of personal information may have been disclosed for a business purpose:

The following information may have been disclosed for a business purpose to Service Providers:

The following information may be disclosed for a business purpose to Third Parties, to whom you authorise us by not exercising an Opt-Out, in connection with products or services we provide to you:

For more information on the Third Parties to whom this information may have been disclosed, and for the ability to Opt-Out of sharing this information with them from the device you are currently using, the following Opt-Out links are provided for each or our site, and please note that you will need to repeat this step on other devices with which you access our websites:

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Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Children. As explained earlier in this Privacy Policy, you must be 13 years of age or older to register to use our website. Therefore, we do not knowingly collect personally identifiable information about children. If you believe that we have information from or about anyone under 13 years of age, please contact us via email at contact@portalcorp.com or in writing at: Privacy Query: Portal Corp LTD, 51 Scrutton Street, City, London, EC2A 4PJ. Furthermore, if you are between the ages of 13 and 16 and decide to use our services, you must exercise the relevant opt-in choices through one of the following links before using the relevant service, and please note that you will need to repeat this step on other devices with which you access our websites:

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Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of Third Parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  • sales, identifying the personal information categories that each category of recipient purchased; and

  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request by emailing contact@portalcorp.com or in writing at: Privacy Query: Portal Corp LTD, 51 Scrutton Street, City, London, EC2A 4PJ

Only you or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided or subsequently requested in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavour to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an email account with us, we will deliver our written response to that email account. If you do not have an email account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

FOR EU DATA SUBJECTS – LEGAL BASIS FOR COLLECTING AND USING YOUR DATA

This section tells you the legal bases we use to collect and use your data:  

Account creation and Profile
Basis: Contract

Advertising
Basis: Legitimate interest when serving advertising using non-personalised mode through our ad server; Consent when serving advertising using personalised mode through our ad server and with our header bidding partners

Content Delivery Network (CDN)
Basis: Legitimate Interest

Contests and Surveys
Basis: Consent

3rd Party Cookies, Pixels, and Measurement
Basis: Consent

Livingly Media Cookies and Measurement Using Internal Software
Basis: Legitimate Interest

Newsletters
Basis: Consent

Information, system, network and cybersecurity
Basis: Legitimate Interest

FOR EU DATA SUBJECTS – HOW LONG DO WE KEEP YOUR DATA?

We delete or anonymise your data held in our archives unless retained through Consent, Contract, or Legitimate Interest.  Occasionally personal data is kept for longer than our standard retention policy, if it is required for legal or safeguarding interests or in order to respond to any complaints or claims that you make. If this is the case, we will only keep the data for as long as we need in order to fulfill those purposes.

You have the right to exercise choice/Consent and the possibility to review and change Consent choices at any time. To do so, please contact us via email at contact@portalcorp.com or in writing at: Privacy Query: Portal Corp LTD, 51 Scrutton Street, City, London, EC2A 4PJ. Please note, on some browsers, you may need to use the ‘reload’ button on your browser after visiting the link below, in order to load the form:

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The consequence of your choosing not to provide Consent is that Portal Corp LTD will not call the relevant pre-selected advertising partners services on our webpages for your device after the choice has been made.

You have the right of access, rectification, to be forgotten, portability, to withdraw and the right to object to us processing your personal data for the purposes set out above at any time. Unless we can show that we have a Legitimate Interest to continue processing your personal data, we will stop processing it.

FOR EU DATA SUBJECTS –  DATA PROTECTION OFFICER

The Data Protection Team for Portal Corp LTD can be contacted by emailing contact@portalcorp.com

FOR EU DATA SUBJECTS –  COMPLYING WITH THE LAW

We are complying with the Data Protection Act 1998 and Regulation (EU) 2016/679 of the European Parliament and of the Council of the 27th of April 2016, General Data Protection Regulation referred to as “GDPR”.

FOR EU DATA SUBJECTS –  COMPLAINTS TO THE SUPERVISORY AUTHORITY

You have a right to complain to the Information Commissioner’s Officer (ICO), which regulates data protection compliance in your country, if you are unhappy with how we have processed your personal data. You can do this by visiting the relevant ICO’s site.

UPDATES TO OUR PRIVACY POLICY

From time to time, we will review and make changes to our privacy policy. The last update to this Privacy Policy was the 4th June 2021.