Last updated: 12 November 2024

1. What’s in this Notice?

This Privacy & Cookie Notice (this “Notice”) describes how Independent Television News Limited and/or ITV Consumer Limited, including its parent, subsidiaries, affiliates and assigns (collectively, “we”, “us”, or “our”) collect, use and share your personal data in connection with your use of our website or any other websites, pages, features, mobile applications, content, or digital services that may link to this Notice. This Notice also describes the rights and choices you have in relation to our processing your personal data.

These services are targeted at visitors of The Trapped Podcast website only and, therefore, this Notice only relates to the use of website visitors’ personal data whilst using these services. This website is hosted in the UK and therefore any personal data that is collected through your use of the service will be held in compliance with UK Privacy Laws. We have also included information on our use of cookies and similar technologies.

Our services include the following:

• at our discretion, making available to you the content of The Trapped Podcast and any promotional materials thereof;
• when you interact or engage with us, including if you:
• contact us with an enquiry, request or give us feedback.

This Notice does not apply to…

• some websites or apps which have their own privacy policy that we don’t control even though they may be branded similarly,
• social media or third party websites or applications we may link to (for example, if you click on a link in an ad that takes you to the advertiser’s site). Please read their privacy policies carefully.

Our website and other services use cookies and other similar technologies to collect information. When you visit our website, you can choose to accept, manage or refuse cookies and similar technologies unless our services need cookies to work properly or applicable law does not require us to obtain your consent. You can find out more by reading section 12 “Cookies and similar technologies”.

We encourage you to read this Notice carefully to understand how we handle your personal data. By using our services, you are aware of the collection, use and disclosure of your personal data in accordance with this Notice. This Notice constitutes your understanding of how we use your personal data. If you disagree with or are uncomfortable with any part of this Notice, please immediately discontinue access or use of our services.

2. Personal data we collect about you or other people?

We may collect or process your personal data:

• When you contact us:
• to leave feedback or complaints.

Personal data collected through your use of our services (we call this “Usage Information”) includes:

Information about how you use the our services including:

• information about the services you have engaged with in our website,
• your activity within our services (including date and time), such as:
• how you access and use our services,
• your cookie settings.

We may collect the following technical information automatically:

• online identifiers (typically we do this through the use of cookies and similar technologies, please read section 12 “Cookies and similar technologies” for more info) such as a randomly generated number as a client identifier or other user or device ID.
• your interaction with our website, such as, where you have clicked, pages you have seen and for how long.
• information about the devices you use, such as:
• device type (examples: laptop, computer, and other third party devices on your wifi network etc) and IP address,
• brand and version of your device,
• network connection type (examples: wifi, 4G, LTE, Bluetooth),
• broadband provider,
• network and device performance,
• browser type and application used, as well as browser or device-specific identifiers,
• language,
• operating system and version.

3. Why we use your personal data

Here is a general explanation of each potential ‘legal basis’ to help you understand what we mean:

• performance of a contract – to check your personal information before we start a new contract with you, and to perform any such contract to provide you with our services in our website,
• legitimate interest – when we have an interest in using your personal information for a particular purpose. This purpose must be necessary and justified for our business considering any possible risks to you and others. For example, we have a legitimate interest in operating our website, making our hosted content available to website visitors, and calculating visitor, session and campaign data for the website's measurement reports.
• compliance with legal obligations: we may need to use your personal information to comply with the law or regulatory codes.

Considering the aforementioned ‘legal basis’, please note that the applicable basis to you is performance of contract and legitimate interest, as we may have a legitimate interest or the contractual obligation to use your personal data to:

• provide you with our service and ensure that our service functions properly,
• manage and administer the website’s services,
• understand, improve and enhance user experience (including testing different versions of our content or layout on our website), and measure how people are using our service, to monitor and improve the operation, delivery, and general accessibility of our service, this may also include conducting internal research and development of our service,
• monitor fair usage and to detect fraud. We may process your information to protect our rights and property and others and to comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements,
• provide customer support and respond to you,
• to enforce compliance with our Terms, agreements with third parties and business partners, and policies. When you access or use our service, you are bound to our Terms. To ensure you comply with them, we process your personal data by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit, or illegal activities on our service, and send you important service messages to update you about your account and the services you use.

In addition, please note that we also use your personal data to maintain legal and regulatory compliance. Our service is subject to certain laws and regulations which may require us to process your personal data. Without processing your personal data for such purposes, we cannot perform the service in accordance with our legal and regulatory requirements.

4. Sharing your personal data

We will only share your personal data with others as described in this Notice. We may provide your personal data to companies that help us in providing our service, or that assist us in improving our products, content, services, or advertising. These companies are authorised to use your personal data only as necessary to provide these services.

We may share your personal data with:

• with our affiliated companies for the purposes described in section 3 above,
• with unaffiliated companies or individuals we may hire or work with that provide us with professional advice, business support, or perform services on our behalf, including customer support, web hosting, information technology, direct mail and email distribution, and analytics services. These service providers are allowed to use your information to help us provide our service and not for any other purpose,
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or to comply with the applicable law or legal process, or to respond to legal claims,
• in connection with a corporate change including a merger, acquisition, or sale of assets,
• to any other party with your prior consent to do so.

We may combine all the information we collect from or receive about you for the outlined purposes. We may aggregate or de-identify your information and may use or share aggregated or de-identified information for any purpose, and such information is not subject to this Notice.




5. Changes to our business

If we decide to change or restructure our business we may need to pass your personal data to one of our group companies so we can continue to effectively deliver our service. However, if we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction could involve us: (i) retaining the right to continue to use transferred personal data in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal data (including new personal data) with the new owner from time to time following such a transaction.

If there are changes to our business (such as a re-organisation or restructuring), your personal data will remain subject to this privacy notice (as amended from time to time). However, where your personal data is transferred to a new owner following a merger or acquisition it may be subject to a different privacy notice. We, or the new owner, will provide notice to you before any of your personal data becomes subject to a different privacy notice.




6. When and why we might keep your personal data?

We keep your personal data where we have an ongoing legitimate or lawful need to do so. For example,

• maintaining the provision and performance of our service,
• understanding and managing our business and how it is performing and making business decisions including about new features, products and services,
• complying with our legal, contractual or regulatory obligations,
• dealing with intellectual property disputes or other breaches,
• resolving complaints.

When we no longer have a legitimate or lawful need to keep your personal data, we will delete it or anonymise it.




7. Do we send your information outside of the UK?

Yes, our service providers or other third parties we work with may be based outside the UK, for example, in Europe or the United States. In these cases we will ensure that your personal data is protected in line with UK data protection laws.

This means we only transfer your personal data where it is permitted under UK data protection laws. The main transfers take place if:

• the UK government has determined the country has an adequate level of data protection,
• standard data protection clauses (which have been ‘adopted’ by the UK government or European Commission) are in place with the service provider or third party, or
• we can rely on one of the specified exceptions.
• We may also take steps to identify and use additional protections as appropriate for each data transfer. For example, we may require the use of:
• technical protections, such as encryption and pseudonymisation (which means making sure personal data can no longer be linked to you without the use of additional information) and
• policies and processes to challenge disproportionate or unlawful foreign government or other authority requests.

We review our service providers before we use them and also ensure that they are only allowed to access the information they need to perform the services we request.




8. How we keep your personal data safe

We're committed to protecting your personal data and keeping it secure, private and confidential. We put in place appropriate technical and organisational measures to help protect the security of your personal data. Unfortunately, no measures can ever be completely secure. We have implemented various safeguards to protect against unauthorised access and unnecessary retention of personal data in our systems. These include pseudonymisation, encryption, restricting access, and retention policies.




9. Your rights

We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:

• the right to be informed of the personal information we collect and process about you and how we do that (this Notice does this).
• the right to request a copy of the personal data we hold about you. To do this, please contact us making clear that you come from this website, you are requesting a copy of your personal data and including full details of what you require. You may also be required to submit proof of your identity;
• the right to object to your personal data being processed where the legal basis for the processing is our own legitimate interests as a business. In all cases, we will comply with such a request unless there is a lawful reason for not doing so, such as when we need to continue to process your information to defend a legal claim or if this information is necessary for the ongoing provision of our service;
• the right to rectification. You may request that we correct any inaccurate and/or complete any incomplete personal data, subject to confirming with your company the correct information;
• the right to withdraw consent. Where we are processing your personal data on the basis that you have given us your consent to do so, you may withdraw your consent at any time;
• the right of erasure. You may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for retaining your personal data;
• the right to data portability. In certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible; and
• the right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website (https://ico.org.uk) for instructions.



10. Changes to how we use your information

We may change this Notice from time to time and we will notify you by revising the “Last Updated” date at the top of this Notice. If we change this Notice in a way that we believe materially affects how we process your personal data, we will provide you with advance notice such as via email or by posting a notice on our service, if applicable. Your continued access or use of our service after receiving the notice of changes constitutes your acknowledgment that you accept the updated Notice.




11. Links to third party sites

Our service may include links to other sites, products, or services that we do not own and are not operated by us, and whose privacy practices may differ our own. If you click a third party link, you will be directed to that third party's site. If you submit personal data to any such third party sites or otherwise submit personal data to such third parties, your information is governed by the pertinent third party’s privacy policies. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services, and this Notice does not apply to your activities on any third-party sites or services or any information you otherwise disclose to any third parties. We encourage you to carefully read the privacy policy of any site you visit.




12. Cookies and similar technologies we may use

This section describes how cookies and similar technologies are used to support our service and the controls which may be available to you. These are used on our website. There are also other technologies we may use (which do not use cookies to store or access information on your device) - see section 2 above which explains when we collect technical information automatically.

What are cookies and similar technologies?

• cookies are small text files stored by your browser (a browser is the software on your device which enables you to access the internet). The cookie stores a unique identifier (a string of random characters) so that your browser can be singled out from other browsers to show you the information you want (for example, the episode of the programme you want to watch on our streaming service). And it is often used to link your browser to databases that hold data about your online behaviour and inferred interests, along with other data such as your IP address or device ID,
• other types of storage, such as local or “HTML” storage. Some of our services use local storage technologies that are similar to cookies but enable larger amounts of data to be stored. This means we can store information like your preferences on your device rather than on our own systems, and
• pixels are embedded code to recognise your browser and record your interactions with emails, online content or ads. From now on we will refer to these technologies collectively as ‘cookies’. Cookies are typically used by websites or where apps have embedded web browsers which allow them to access the internet.

Why do we use cookies and what types of cookies do we use?

Essential: these cookies are necessary for our service to work. Without these cookies, we can’t provide you with our core functionalities and associated services such as login and security, and help to improve your experience and so these are not optional. Some of these types of cookies also provide you with features which you choose to use. They may also help with the following:

• when you visit our website, we’ll remember your cookie consent preferences, so you don’t have to select them again the next time you visit.
• to keep our site and your personal data secure,
• we may test different versions of our website or content to understand which performs best for user experience,
• we may collect anonymous data on how you use our services in order to make improvements and to identify and fix any technical issues.

Performance and Functionality: these are used to produce reports to help us improve our site and measure how well new features or functionalities perform.

We also use Google Analytics which is an analytics and measurement service provided by Google. Google Analytics sets a cookie in order to evaluate use of our service, where we have implemented it, and compile a report for us. Google Analytics records visits to our website to help us know:

• the date and time of visits,
• how many active users we have at any given time,
• what browsers are used (so we can maximise compatibility),
• the country or region where our users are located,
• we may also use this cookie to derive demographics and interests data for analytics purposes only.

You can find out more about how Google uses data at https://policies.google.com/technologies/partner-sites?hl=en-GB. You can also install a browser plugin - https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en-GB to opt out from Google Analytics across all websites you visit (including our website).




How do I manage cookies?

Please be informed that you have the following controls in our website:

• cookie settings: these enable you to choose what data is stored on or collected from your device and control how this data may be used.

You can also choose how cookies (across all websites) are handled on your device via your browser settings including to block or delete all cookies or just third party cookies. Each browser manufacturer is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.




13. Contact us

Contact us about your data protection queries or requests: Email: dataprotectionteam@itn.co.uk or myprivacy@itv.com. Please be informed that Independent Television News Limited and ITV Consumer Limited are the data controllers of the processing activities pertaining to your personal data. Please mention in the subject of your query or request “Trapped Podcast”.

Write to: ITV Group Data Protection Officer, ITV plc, ITV White City, 201 Wood Lane, London, W12 7RU.