Introduction and contents
Our values guide everything that we do – including our editorial approach and how we use personal data. We are strongly committed to keeping your personal data safe. This commitment exists throughout the lifecycle of your personal data, from the design of any Guardian service which uses personal data to the deletion of that data.
To complement our global approach to privacy protection, this policy also incorporates specific information privacy rights granted to individuals under Californian and Australian privacy law. This reflects our relationship with our readers in these locations where we provide localised editions of our editorial content.
We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics:
Information about your rights, the choices available to you, and our obligations in the European Union, in California, in Australia, and elsewhere
Transparency about how we collect and use your personal data, including when and how it is shared
Information on how we protect your personal data
Information on how we will facilitate your rights and respond to your questions
Find out more about how we manage your personal data below:
- 1Introduction and contents
- 3Who we are and how to contact us
- 4The types of personal data we collect about you
- 5How we collect personal data
- 6How we use your personal data
- 7Personal data that we receive about you from other organisations
- 8Using children’s personal data
- 9Security of your personal data
- 10When we share or sell your personal data
- 11International data transfers
- 12How long we keep your personal data
- 13How we may contact you
- 14Cookies and similar technologies
- 15Your privacy and data protection rights with regard to the personal data that we hold about you
- 16Your California privacy rights
- 17Your rights under the Australian Privacy Act
- 18Contact us for information about how we use your personal data
Personal data is any information about you by which you can be identified or be identifiable. This can include information such as:
your name, date of birth, email address, postal address, phone number, mobile number, financial details, such as payment cards you use to purchase products, subscriptions or support our journalism
information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based)
information relating to how you use and interact with our sites, apps and services
When we refer to “personal data” in this policy, we are also referencing “personal information,” as it is defined under California law, which you can read more about here, and as it is defined under Australian law, which you can read about here.
Some of our other sites provide additional privacy information. You can read that information using these links:
Guardian Jobs (jobseekers)
Guardian Jobs (recruiters)
Guardian Crowd (pdf)
Who we are and how to contact us
Guardian News & Media Limited, Kings Place, 90 York Way, London N1 9GU is the data controller in respect of your personal data. This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us directly, you can find our contact details in the “How to contact us” section below.
The types of personal data we collect about you
We collect your personal data when you visit our sites and apps, subscribe for products or services, contribute to the Guardian or when you interact with us. We will only collect your personal data in line with applicable laws. We collect your personal data in various ways:
directly from you, when you sign up for our services and when you browse our sites or use our apps
personal data we generate about you, e.g. personal data we use to authenticate you, or personal data in the form of your IP address or your preferences
personal data we collect from third parties, e.g. personal data that helps us to combat fraud or which we collect, with your permission, when you interact with your social media accounts
More detail about these three categories of personal data are provided below.
The personal data we collect when you register for a Guardian account
When you register for a Guardian account on theguardian.com, we collect:
your user name
your email address
other details such as your residential or billing address when you sign up for membership or a subscription
some limited data from your social media profile (further information on this is below), if you have signed in to theguardian.com using your social media details
your photograph, if you add one to your profile page
You can change or remove these details using the profile and settings area of your Guardian account.
Personal data we generate about you
When you register for a Guardian account, we assign you a unique ID number that we use to recognise you when you are signed in to our services. This will recognise you if you sign in using the same account on a new device or through a different application such as the Guardian app on mobile devices.
your IP address - a numerical code to identify your device, together with the country, region or city where you are based
your geolocation data - your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data and data about connection with local Wi-Fi equipment
information on how you interact with our services
your browsing history of the content you have visited on our sites, including how you were referred to our sites via other websites
details of your computer, mobile, TV, tablet or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content
We will not collect special categories of data from you - such as personal data concerning your race, political opinions, religion, health or sexual orientation - unless you have chosen to provide that type of personal data to us.
When you use our apps
The Guardian apps use personal data based on the content you have viewed. Information on bugs and crashes is also sent to us when you use our apps. A list of the articles that you have recently viewed is also cached in the local storage on your mobile device. You can delete this reading history in the settings of the app. You can choose to receive notifications on your mobile device via the app, and manage these notifications in the settings of the app.
Using your social media details to sign into your Guardian account
When you sign in to our sites or apps using your Facebook login details, you give permission to Facebook to share with us your email address and certain aspects of your Facebook profile if you have made these public on your Facebook profile. This only includes your first and last name, age range, link to your Facebook profile and profile picture. We do not have access to updates on your Facebook profile. If you use your Google login details, you give Google permission to share the personal data that you have made public in your Google profile. This only includes your first and last name, your email address and whether your email address has been validated, your age range, a link to your Google profile and, if you have one, your profile picture. If you register or sign in with your Apple ID, you give Apple permission to share your personal data with us. You can also choose to hide your email and Apple will create a random email address so your personal email can stay private. This email address will be linked to your Guardian profile and will be used to retrieve your subscribed content.
We will then use this personal data to form a profile for your Guardian account. If you remove the Guardian app from your Facebook settings, or from your Google settings, or your Apple ID, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your Guardian account using your Facebook, Google login, or Apple ID.
Personal data when you post comments about the Guardian on other social media sites
If you have mentioned the Guardian in posts on social media sites, then we may collect your social media handles. For example, when you mention the Guardian in a tweet, we may collect your Twitter handle.
When you post publicly (comments) on our sites
When you post on a discussion board or comment publicly on an article on one of our sites, the personal data you post, including your username and other information about yourself, are publicly accessible. This personal data can be viewed online and collected by other people. We are not responsible for the way these other people use this personal data. When contributing to a discussion, we strongly recommend you avoid sharing any personal details, including information that can be used to identify you directly such as your name, age, address and name of employer. We are not responsible for the privacy of any identifiable information that you post in our online community or other public pages of the site.
How we collect personal data
We collect personal data when you:
become a supporter or register for an account on theguardian.com
make contributions to fund and support the Guardian
pay for a subscription or purchase any other products/services for yourself or others
attend our events
enter our competitions and surveys
take part in our call-outs
sign up for our editorial emails
post in our online community
sign up for marketing communications
use mobile devices to access our content
access and interact with any of our sites and app
through cookies and other similar technology
when you contact us via email, social media, our apps or similar technologies or when you mention us on social media
How we use your personal data
We use personal data collected through our sites and apps only when we have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which we have collected your personal data.
Legal grounds for using your personal data
The legal ground may be one of the following:
Consent: Often we will use your personal data because we have asked for your consent, which you can withdraw at any time. Examples of where we ask for your consent include:
to send marketing emails to you, when we have asked your permission. You can withdraw your consent to receiving these emails at any time by clicking on the “unsubscribe” link at the bottom of the email or through your email preferences in the “emails and marketing” tab, when signed into your Guardian account.
to analyse your registration data and data collected from cookies to personalise advertising. We do this by analysing your data to predict what you might be interested in. We will also compare your registration data with trusted partners.
Performance of a contract with you (or in order to take steps prior to entering into a contract with you): We will use your personal data if we need to in order to perform a contract with you. For example, where you have purchased a subscription from us, we will need to use your contact details and payment data in order to process your order and deliver your subscription.
Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
Our legitimate interests: We may process your personal data where it is necessary for our legitimate interests in a way that might be expected as part of running the Guardian and in a way which does not materially impact your rights and freedoms. For example it is in our legitimate interests for us to understand our readers, promote our services and operate our sites and apps efficiently for the creation, publication and distribution of news, media and related journalistic content both online and in print form, globally. Examples of when we rely on our legitimate interests to use your personal data include:
when we analyse what content has been viewed on our sites and apps, so that we can understand how they are used and improve our content.
to analyse our readers and supporters to better understand your interests and preferences so that we can make our marketing more relevant to you. This includes when we promote our own products and services. For example, we look at what you have viewed on our sites and apps and what products and services you have bought (including what you have looked at and what products or services you have bought on our other platforms, for example Guardian Jobs). You can opt out from having your personal data used for marketing analyses by going into your account to the tab “emails and marketing”.
to show you more relevant advertising based on that analysis by creating “segments” of particular types of audiences so that we can show you advertisements that may be more relevant to you and the ‘’segments’’ you may be in.
to keep you informed about the Guardian if you have subscribed or supported us in the past, and have not opted out from receiving our communications.
for internal administrative purposes related to our services - such as our accounting and records.
to inform you of any changes to our services, such as updates to our terms and conditions.
to collect and log IP addresses to improve and manage our site and apps.
to personalise our services (for example when you sign in) by remembering your settings, and recognising you when you sign in on access the Guardian in different ways, such as by our app and on our site.
enabling you to share our content with others using social media or email.
contacting you directly via social media or email if you send us emails, enter competitions or engage with the Guardian on social media or contact us.
when we respond to your queries and to resolve complaints.
Access permissions when you are using the Guardian app
When you use the Guardian app, we will ask for permissions to access particular functions of your mobile device. When we ask for permissions will depend on the operating system of your mobile device, but can include:
when you decide to store content including photographs on your mobile device to read or use when offline. We will need your permission to save content to your mobile device.
asking permission to access your contact details/profile on your mobile device, so that we can add or find your Guardian account on your phone;
if you decide to submit content, such as photographs, to the Guardian we will ask permission to access your camera or photographs.
Updating your personal data and your profile page on our sites
When you register for an account with theguardian.com, you have access to a profile page. Under “edit profile” you can review and update what personal data is public when you comment on our articles, or if people look up your profile.
You may also update your marketing preferences in the “emails and marketing” tab in your account.
Personal data that we receive about you from other organisations
Adding to or combining the personal data you provide to us
When you sign up to our services we may add to the personal data you give us by combining it with other personal data shared with us by other trusted organisations. This includes, for example, the region that you are located in, so that we can show you the prices for subscriptions or other products in your local currency. We may also add personal data to improve the accuracy of your delivery address when we send out mail. We may also obtain your personal data from partners whose offers we include in some of our marketing communications and we use this personal data to ensure that we do not send you irrelevant marketing and to ensure the accuracy of the information we hold.
Personal data shared by event partners
When you register or book a ticket for a Guardian event organised by an event partner, your registration data may be shared with us by the event partner.
Using children’s personal data
We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal data about children under 13. Some of our services may have a higher age restriction and this will be shown at the point of registration. We also note that California law prohibits sale of personal data of consumers between 13-16 years of age unless the guardian has authorised the sale. We comply with this requirement.
Security of your personal data
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending any information, including personal data, via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.
When we share or sell your personal data
Within the Guardian group of companies
Depending on where you live, we may share your personal data within the Guardian group of companies in the UK, US, or Australia. We may share it in order to perform a contract with you, for administrative purposes, or when we have a legitimate interest in doing so. For example:
If you book an event held in Australia, at first we may hold your data on our systems in the UK and then we may share it with the Guardian in Australia for administration purposes
If you are going to one of our events hosted by an event partner, we may share your personal data with that partner for event administration purposes
Sometimes we may receive a letter, email or another form of communication from you that we consider to be significant to the history of the Guardian. We may decide to share this with the Guardian Archive run by the Guardian Foundation for historic and archiving purposes
We may share your data to understand how you interact across our group products or to tailor and offer relevant advertising to you.
With external organisations
We share your personal data with other organisations that are not directly linked to us under the following circumstances:
Service providers - We may share your data with other organisations that provide services on our behalf. We may do this to perform a contract we have entered into with you, where it is in our legitimate interests or with your consent. Examples of when we may share your data with service providers include sharing with:
companies that help deliver newspapers and subscription vouchers, such as i-Movo
online payments processors who process credit and debit card transactions on our behalf
fraud management providers that help us to identify and prevent online fraud
internet and cloud hosting services providers, such as Amazon Web Services (AWS)
life-cycle engagement platforms such as Braze, to help us build and manage our campaigns
software service providers such as Salesforce that assist us with our customer relationship management
communications services providers, such as our podcast service provider called Acast
error tracking software providers, such as Sentry and Google Firebase, to help us diagnose and fix errors and optimise the performance of our website and apps
service providers that help us carry out analytics, facilitate audience creation and segmentation and to measure our audience engagement. For example, Permutive provides us with data management platform services
service providers that help provide us with insights and analytics that help us to improve our products and services. For example, we use Google Analytics to understand how visitors engage with our sites or apps
data management companies, such as Formstack, that help us collect data via online forms and surveys
service providers that help provide online identity-as-a-service and access management services such as Okta
service providers that allow us to compare your personal data with information held by advertising partners and identify if you are know to both us and our advertising partner, such as Infosum
Agencies and authorities if required by law - We may reveal your personal data to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if we are required to do so to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect our rights or the rights of anyone else (for example, in response to valid and properly served legal process such as subpoena or warrant). If we have your contact details, we will take reasonable steps to attempt to notify you prior to disclosing your data unless (i) prohibited by applicable law from doing so, or (ii) there are clear indications of unlawful conduct in connection with your use of GNM services.
Event sponsors and partners - we may share your personal data with sponsors of Guardian events and partners who we hold events with for marketing purposes when you have given your permission for us to do so.
Social media organisations - We may share your personal data with other organisations when our web pages use social plug-ins from these organisations (such as the “Facebook Recommend” function, Twitter’s retweet function, Google+ function). These other organisations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, personal data they collect may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies.
When we share your personal data, as specified above, with any organisation which accesses your data in the course of providing services on our behalf, they will be governed by strict contractual restrictions to make sure that they protect your data and comply with applicable law. We may also independently audit these service providers to make sure that they meet our standards.
International data transfers
Whenever we transfer your personal data out of the UK or the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:
We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.
We may also use specific approved contracts that use Standard Contractual Clauses for the protection of personal data where appropriate, with our service providers that are based in countries outside the UK or the EEA, including those based in the US and Australia. These contracts give your personal data the same protection it has in the UK or the EEA.
If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the UK or the EEA.
How long we keep your personal data
How we may contact you
From time to time we may send you service emails, for example, telling you your subscription is coming to an end or thanking you when you contribute or place an order with us.
Marketing communications and editorial newsletters
If we have your permission or you have not opted out, we may send you materials we think may interest you, such as new Guardian offers and updates. Depending on your marketing preferences, this may be by email, phone, SMS or post.
We offer a range of editorial newsletters. You can manage your subscription to these emails through your profile page when you are signed in to your Guardian account.
You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email or through your email preferences in the tab “emails and marketing” when you are signed in to your Guardian account.
Sometimes we may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by signing into your Guardian account and going to the tab “emails and marketing”.
Responding to your queries or complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
Special Note to California Users
If you elect to use the “do not sell” button, we will not recontact you about that choice for at least 12 months.
Cookies and similar technologies
When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technologies.
Your privacy and data protection rights with regard to the personal data that we hold about you
You have a number of rights with regard to the personal data that we hold about you and you can contact us with regard to the following rights in relation to your personal data:
You have the right to receive a copy of the personal data we hold about you
You have the right to correct the personal data we hold about you
Where applicable, you may also have a right to receive a machine-readable copy of your personal data
You also have the right to ask us to delete your personal data or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request
Where applicable, you have the right to object to processing of your personal data for certain purposes
Where you have provided us with consent to use your personal data, you can withdraw this at any time
If you do not want us to use your personal data for marketing analysis, you can change your settings in the “Emails and marketing” tab of your Guardian account
If you would like to exercise any of your rights specified above, please email email@example.com or write to the Data Protection Officer at Guardian News & Media Limited, Kings Place, 90 York Way, London N1 9GU. We will deal with requests within one month.
We may need to request specific information from you to help us confirm your identity. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of 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.
Your California privacy rights
Under the California Consumer Privacy Act, California Civil Code Section 1798.100, if you are a resident of California you may contact us with regard to the following rights in relation to your personal data:
Right of Access: You have a right to request access to the personal data we may hold on you for the past twelve (12) months. You may submit up to two (2) requests per year of access to your personal data.
Right to Opt-In/Opt-Out of Sale of Personal Data: For individuals sixteen (16) years or older, you have the right to opt-out of sale of personal data we may hold on you. You can exercise this right at any time by pressing the “California resident - Do not sell” link in the footer of every page on our site. For individuals between thirteen (13) to sixteen (16) years old, you have the right to opt-in to the sale of personal data we may hold on you.
Right to Deletion: You also have the right to ask us to delete personal data we may hold on you or restrict how it is used. There may be exceptions to the right to deletion for specific legal reasons which, if applicable, we will set out for you in response to your request.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your California Consumer Privacy Act rights.
If you want to make any of these requests, please contact firstname.lastname@example.org or by calling our designated toll-free number (888) 777-6069. We will deal with requests for access to your personal data within forty-five (45) days for California-specific requests.
To help us respond as you expect, please specify that you are making a request under the California Consumer Privacy Act. We may need to request specific information from you to help us confirm your identity.
Your rights under the Australian Privacy Act
The Australian privacy Act has rules around how we handle your personal information that may be different to rules in other regions. These rules are set out in the Australian Privacy Principles in force under the Privacy Act 1988 (Cth) (the Australian privacy Act). We are required to treat your personal information in line with those principles, including to disclose to you what personal information we collect and how we use it, to store your information securely and to support you in exercising your rights.
Personal information we collect and use
When we refer to “personal data” throughout this policy, we are also referencing “personal information,” as it is defined under Australian law, which you can read about here.
Your rights to privacy are also protected by the Australian Privacy Act, including your:
Right of access to the personal information held about you; and
Right of correction to correct your information when it is incorrect.
Opt out of personalised advertising
Under the Australian Privacy Act, you have the right to opt out of the use of your personal information for the purpose of direct marketing, including in relation to personalised advertising. You can opt out of personalised advertising across our website and apps at any time by going to Privacy settings at the bottom of the page. You will still see non-personalised advertising.
If you have contacted us at email@example.com with a privacy related complaint and you are not satisfied with our handling of that complaint, you may refer that complaint to the Office of the Australian Information Commissioner:
GPO BOX 5218, Sydney NSW 2001
T 1300 363 992
Contact us for information about how we use your personal data
If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection Officer at Guardian News & Media Limited, Kings Place, 90 York Way, London N1 9GU. Or, email firstname.lastname@example.org.
Complaints will be dealt with by the Data Protection Team, and will be responded to within 30 days.
If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.
If you have a question about anything else, please see our Contact us page here.
For individuals based in the European Union:
Since we do not have an establishment in the European Union, we have appointed an EU based representative to serve as a direct contact for data protection authorities and individuals on our behalf, who can be contacted at email@example.com or MCF Legal Technology Solutions Limited, Riverside One, Sir John Rogerson’s Quay, Dublin 2, Ireland.
28 January 2022
8 October 2021
20 November 2020
12 August 2020
30 June 2020
A list of all previous changes are available upon request.