1. Introduction

This is the privacy policy for InBoxx LLC (collectively referred to as “InBoxx”, “we”, “us” or “our” in this policy), our sites such as inboxx.life (“our sites”), and our associated apps and services. 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 of our services which use 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:

2. About this privacy policy

This privacy policy explains how we collect, use, share, transfer and sell (for California residents only) your personal data when you use the services provided on our sites and our apps or interact with us. This privacy policy also explains your data privacy rights.

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, gender, email address, postal address, phone number, mobile number or financial details, such as payment cards you use to purchase products or subscriptions or to 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, and as it is defined under Australian law.

3. 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 or when you interact with us. We will only collect your personal data in line with applicable laws. We collect your personal data in the following ways:

Directly from you, e.g. when you sign up for our services, purchase products or services, including by signing up for newsletters or selecting specific topics you are interested in, 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 and/or payment service providers (e.g. Paypal). More details about the types of personal data we collect are provided below.

The personal data we collect when you register for an account

Personal data we generate about you

When you register for an account or sign up for a newsletter, we assign you a unique ID number. We use this to manage your preferences, for example, the newsletters you have subscribed to. When you register for an account we use your unique ID 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 our app on mobile devices.

When you use our sites or apps we may also use cookies or similar technologies to collect extra data, including:

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

InBoxx 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 device. You can delete this reading history in the settings of the app. You can choose to receive notifications on your device via the app, and manage these notifications in the settings of the app.

Using your social media details to sign into your account

When you sign in to our sites or apps using your social media ID, we will use this personal data to form a profile for your account. If you remove the app 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 account using your Google login, Apple ID, or any other social media sign in.

Apple

If you register or sign in with your Apple ID, you give Apple permission to share your personal data with us. This only includes your first and last name, and your email address. 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 profile and will be used to retrieve your subscribed content.

Google

When you sign in to our sites or apps using 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, a link to your Google profile and, if you have one, your profile picture. This email address will be linked to your profile and will be used to retrieve your subscribed content.

4. 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. Please refer to the table below for examples of where we ask for your consent. 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 or we may contact you directly via social media or email if you enter competitions, prize draws, bids or respond to call-outs.

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 our services 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 ways to support us, 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. Please refer to the table below for examples of when we rely on our legitimate interests to use your personal data.

In addition to the above, we also rely on the legitimate interests below to use your personal data:

InBoxx LLC is a media organisation and publisher. Data protection law includes certain exemptions when personal data is processed for the purposes of journalism. Those exemptions apply to some of the ways we use personal data. This privacy policy does not cover personal data that the InBoxx LLC processes for the purposes of journalism.

5. 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.

We also use personal data based on the content you have viewed on our sites and apps and your interaction with the content to add you to groups with similar interests and preferences, so that we can make our online advertising more relevant. Sometimes we use data about your interests or demographics that some of our global third parties have collected from you online to add you to these groups.

Personal data shared by event partners

When you register or book a ticket for an event organised by one of our event partners, your registration data may be shared with us by the event partner.

6. 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. 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.

7. When we share your personal data

Within our group of companies

Depending on where you live, we may share your personal data within our 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.

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:

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.

California resident - Do not sell

These transfers to third parties may constitute “sale” of your personal information under California law. Third-parties do not sell personal information that has been sold to them by us unless you have first received explicit notice and are provided an opportunity to exercise the right to opt out.

8. International data transfers

Data we collect may be transferred to, stored and processed in any country or territory where one or more of our group companies or service providers are based or have facilities. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal data that we transfer in line with this privacy policy.

9. How long we keep your personal data

We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.

10. How we may contact you

Service communications

From time to time we may send you service emails or SMS, 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 offers and updates. This may be by email, phone, SMS or post.

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 account.

Market research

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 clicking a link in the message.

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.

11. 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.

12. 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:

We may need verification of your identity to proceed with a request. If you provide us with proof of identity containing information that does not match our records, we may request further proof of identity from you. This is a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it.

13. 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:

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. If you provide us with proof of identity containing information that does not match our records, we may request further proof of identity from you.

14. 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.

Details about the personal information that we collect, use and disclose is set out throughout this privacy policy.

Your rights

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.
These principles and rights are reflected throughout this privacy policy.

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.

We and our partners use cookies and similar technologies to collect information about your use of the website to help create reports and statistics on the performance of the website. Analytics cookies such as Google Analytics collect information such as your IP address, device type and operating system, referring URLs, location and pages visited. If you don’t want Google Analytics to be used in your browser, you can install the ‘Google Analytics Opt-Out Browser Add-On’, provided by Google.

15. 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 email [email protected].

Complaints will be dealt with by the Data Protection Team, and will be responded to within 30 days.