This policy describes how we handle your data when you use “GDN Services,” listed below:
- The Gulf Daily News (GDN) newspaper
- Our websites, gdnonline.com
- Our apps, like the GDN app
- Our email newsletters
- Our pages or ads on social media networks, like our Facebook and Instagram pages
How we handle information about you depends on which GDN Services you use — and how you use them. We use different information about print subscribers than website visitors.
Be aware that certain GDN Services work differently. Some have additional terms that supplement this policy (such as, Reader Submissions).
1. What Information Do We Gather About You?
The information we gather about you depends on the context. By and large, it’s information about you that can personally identify you — either on its own or when combined with other information.
The following describes the information we collect and how we obtain it.
A) Information Collected Through GDN Services.
1. Information You Voluntarily Give Us
When you sign up for a GDN Service (e.g., a subscription), we collect:
- Your Name
- Your Gender (as designated by you)
- Contact information (Email Address and/or Physical Address)
- Mobile Number
Once you’re registered, we assign you a unique ID number. This ID number helps us recognize you when you’re signed in.
If you register for an event or conference, we might ask for additional information (e.g., your company name, your job title, or your dietary restrictions).
To process payments or donations, we collect and use your payment information. This can include your name, your address, your telephone number, your email address, your credit or debit card information, and any other relevant information.
Currently, we do not store this information. This information is given to our payment gateway providers to process the payment.
For User-Generated Content:
We offer you the ability to post content that other users can read (e.g., comments or recipe, restaurant reviews). Anyone can read, collect, and use any personal information that accompanies your posts. See the Comments F.A.Q., or read “User-Generated Content” in our Terms of Service for more information.
We do not have to publish any of your content. If the law requires us to take down, remove, or edit your personal information, we will comply to the required extent.
o For Contests and Special Offers:
When you sign up for these, you give us your name, email, and any other required information.
o For Reader Surveys, Research, Panels, and Experience Programs:
We gather information through questionnaires, surveys, and feedback programs. We also conduct similar research for advertisers. We ask you for your consent to use this information when you participate in these programs and events.
o During Contact with Our Customer Contact Service:
We collect information from you when you place an order over the phone or contact customer service through one of our service numbers.
o Personal Contacts Data:
We never scan your device for your contacts or upload that data. With your consent, we do comply with your requests to collect data about your friends, family, or acquaintances (e.g., Refer a Friend campaigns). This functionality is only meant for Bahrain residents. By using it, you acknowledge and agree that both you and your contacts are based in Bahrain — and that you have everyone’s consent for us to use their contact information.
2. Information Collected Automatically
o With Tracking Technologies in Your Browser and Mobile Apps:
These technologies include cookies, web beacons, tags, and scripts, software development kits (or SDKs) and beyond.
We track and store data about how you visit and use GDN Services, particularly through our websites and apps. The items we log include:
- Your IP address
- Your location
- Your operating system
- Your browser
- Your browser language
- The URLs of any pages you visit on our sites and apps
- Device identifiers
- Advertising identifiers
- Other usage information.
B) Information Collected From Other Sources.
1. Privately Owned Databases:
Marketing, data analytic, and social media-owned databases give us access to a range of information — like public data, survey data, and beyond. This data sometimes includes your mailing address, your gender, your age, your household income, and other demographic data.
2. Social Media Platforms and Other Third-Party Services:
(Social media platforms include Facebook, Instagram, and Linkedin).
You can link your social media or other third-party account to a GDN social media service. By linking the services, you authorize us to collect, store, and use any information they may give us (e.g., your email address). You can disconnect your link registration from third-party accounts at any time.
We also receive information from you when you interact with our pages, groups, accounts, or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender, and location), engagement data (e.g., "likes," comments, shares, reposts, and clicks), awareness data (e.g., number of impressions and reach), and individual users' public profiles.
3. Workplace and Schools:
When your employer or school buys an organization-wide subscription to gdnonline.com, they sometimes provide us with your name and organization email address to grant you access as a user.
Future Product and Service updates:
We are always improving our products and services, and we create new features regularly. These updates sometimes require us to collect new information or use what we already have differently. If there is a significant or material change in the way we handle your personal information, we will notify you as detailed below.
2. What We Do With The Information We Collect About You?
A) It Helps to Provide the GDN Services.
We use your information to help you use and navigate GDN Services, such as:
- Making a GDN Service available to you
- Arranging access to your account
- Providing customer service
- Responding to your inquiries, requests, suggestions, or complaints
- Completing your payments and transactions
- Sending service-related messages (e.g., a change in our terms and conditions)
- Saving your reading list, recipes, or property searches
- Displaying your Crossword stats
- Letting you take part in paid services, polls, promotions, surveys, panels, research, and comments
B) We Personalize Your Experience.
We track your interests and reading habits (e.g., the articles you read) to personalize your reading experience using technology like algorithmic recommendations and machine learning. This is how we highlight articles you might be interested in and de-emphasize articles you've already read. We also show you prices, promotions, products, or services we believe you'll find interesting, based on demographic and usage data.
C) We Allow You to Share User-Generated Content.
Any information you disclose in your content becomes public — along with your chosen screen name and uploaded photo.
D) We Develop Products and Services and Analyze.
We may analyze data on our users' subscription, purchase, and usage behaviors. This helps us make business and marketing decisions. For example, our analysis lets us predict preferences and price points for our products and services. It helps us determine whether our marketing is successful. It also shows us characteristics about our readers, which we sometimes share in aggregate with advertisers. Google Analytics is one of the analytics providers we use. You can find out how Google Analytics uses data and how to opt out of Google Analytics.
E) We Carry Out Administrative Tasks.
- For auditing: We verify that our internal processes work as intended and comply with legal, regulatory, and contractual requirements.
- For fraud and security monitoring: We detect and prevent cyberattacks or unauthorized robot activities.
- For customer satisfaction: We assess users' satisfaction with GDN Services and our customer care team.
The above activities may involve outside companies, agents, or contractors ("service providers") with whom we share your personal information for these purposes.
F) We Offer Competitions and Promotions.
You can take part in our competitions and promotions. Some might have additional rules about how we use and disclose your personal information.
G) We Allow for Personalized Advertising on GDN Services and Create Audiences for Third-Party Advertisers.
We also identify groups of users to whom to serve personalized ads on behalf of our advertisers. To do this, we combine information we collect through surveys or registration with information we collect automatically using tracking technologies while you browse our sites and apps. This combined information is used to build models. These data models are then used to measure users' attributes, like their demographic information or their interests. Working with service providers, we use these measurements to group users by common attributes. Each group is associated with a random ID which is then passed to our ad server for use in targeting ad campaigns on our sites and apps.
Notes on targeted advertising:
- For more about targeted advertising, and how to opt out with your specific browser and device, go to the DAA Webchoices Browser Check and NAI Opt Out of Interest-Based Advertising. You can download the AppChoices app to opt out in mobile apps.
- We try to limit how our third-party advertising technology vendors use the information they gather from you. Many of these providers require us to enter into contracts that allow them to optimize their own services and products or help them create their own.
- These providers combine any information they gather about you through GDN Services with information they receive from their other clients. This helps them target ads to you on behalf of their other clients, not just us. These third parties sometimes use other services to serve ads.
3. Who Do We Share the Information With that We Collect?
A) Within the GDN Company:
We share your information with our affiliates for the purposes listed here.
B) With Service Providers:
We work with service providers, as defined above, to carry out certain tasks:
- Processing your payments
- Fulfilling your orders
- Maintaining technology and related infrastructure
- Offering you customer service
- Serving and targeting ads
- Measuring ad performance
- Presenting and carrying out surveys
- Shipping you products and mailings
- Distributing emails
- List processing and analytics
- Managing and analyzing research
- Managing promotions
When performing these tasks, service providers may often have access to your personal information. At times, we allow them to use aggregated or de-identified information for other purposes, in accordance with applicable laws.
C) With Other Third Parties:
There are situations when we share your information with third parties beyond our service providers. We never share your email address with these third parties without your consent, except in encrypted form to engage in the matched ads process described above.
- If you’re a Bahrain print subscriber, we may share your name and mailing address (among other information) with other reputable companies that want to market to you by mail.
- We share information about participants in our competitions and promotions with the promotions’ sponsors. In those cases, we notify you when you provide us the information.
- We process payments you make through GDN Services with external services. There are two ways this can happen:
- i) We collect your information and share it with the third-party service for processing.
- ii) The third-party service dealing directly with you collects your information for processing.
- In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we would have a legitimate interest in disclosing or transferring your information to a third party — such as an acquiring entity and its advisers.
- We can preserve or share personal information if the law requires us to do so. We can also preserve or share personal information if we believe it would be necessary to:
- Comply with the law or with legal process
- Protect and defend our rights and property
- Protect against misuse or unauthorized use of GDN Services
- Protect the safety or property of our users or the general public (e.g., if you provide false information or attempt to pose as someone else, we could share your information to help investigations into your actions)
- Cooperate with government authorities, which could be outside your country of residence.
- We disclose public activities in our RSS feeds, APIs, and other distribution formats. Your public activities could thus appear on other websites, blogs, or feeds.
4. What Are Your Rights?
A) Can You Opt-Out of Email, Phone, Mail, and Push Notifications?
Yes, you can. The opt-out methods described below are limited to the email address, phone, or device used. They won’t affect subsequent subscriptions.
- Mail or Telephone Promotions:
- Push Notifications:
- Text Messages:
We offer a variety of commercial emails and email newsletters. You can unsubscribe from them by following the “unsubscribe” instructions near the bottom of the email. You can also email us at [email protected].
You can manage your GDN newsletter preferences through your account dashboard.
You can ask us to unsubscribe you from our mail or telephone solicitations. You can also ask us to not share your information with third parties for marketing purposes. To do so, call us on +97317288123 to chat with us. You may also email us at [email protected] with “Opt-Out” in the subject line, and your account number and phone number in the body of the email.
You can opt out any time by adjusting your device settings or uninstalling our app.
You can opt out of text alerts any time by replying “STOP” or any alternative keyword we’ve shared with you.
We complete any opt-out request as quickly as we can. This opt-out request won’t prohibit us from sending you important nonmarketing notices.
B) How Do You Access, Change, Delete, Update, or Exercise Your Other Rights in Relation to Your Personal Information?
You have the right to:
- Access, modify, or delete the personal information we have about you
- Receive an electronic copy of the personal information we have about you, for data portability
- Restrict or object to how we process personal information about you
- Not receive discriminatory treatment by us for the exercise of your privacy rights.
You have the right to object to the processing of your personal information based on our legitimate interest or that of a third party — unless we demonstrate compelling legitimate grounds for the processing of, or the keeping of, your personal information for the establishment, exercise, or defense of legal claims.
If you’d like to exercise any of the above rights, contact us via [email protected]
In your request, please be specific. State the information you want changed, whether you’d like your information suppressed from our database, or whether there are limitations you’d like us to put on how we use your personal information. Please use the email address linked to that personal information — we only complete requests on the information linked to your email address. To verify your identity, we will email the email address you provide us, and which matches our records, and wait for your response. In some instances, we may also ask for additional information. This is how we verify your identity before complying.
Alternatively, you can designate an authorized agent to make a request on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.
We’ll respond to your request in a manner consistent with applicable law.
We might need to keep certain information for record-keeping purposes or to complete a transaction you began prior to requesting a change or deletion (e.g., if you make a purchase or enter a promotion, you might not be able to change or delete the personal information provided until after the completion of the purchase or promotion).
In some cases, your request doesn’t ensure complete removal of the content or information (e.g., if another user has reposted your content).
If you’d like, you can lodge a complaint with a data protection authority.
C) How We Manage Your Digital and Home Delivery Accounts?
You can update your account information and see your transaction history through your password-protected dashboard. If you need further assistance, call our Customer Care Line on +97317299123.
5. Personal Information We Will Not Be Collecting
We generally don’t want to gather any sensitive information about you. This includes:
- Your racial or ethnic origin
- Your gender orientation
- Your political opinions
- Your religion or other beliefs
- Your health, biometric, or genetic characteristics
- Any criminal background
There are rare situations when we may request this information (e.g., a reader survey asks about your political leanings), but you can decline to answer. Outside those situations, we would prefer you never share that information with us.
6. How Long Do We Retain Your Data?
We store your personal information for as long as needed or permitted, based on the reason why we obtained it (consistent with applicable law). This means we might retain your personal information even after you close your account with us.
When deciding how long to keep your information, we consider:
- How long we have had a relationship with you or provided a GDN Service to you
- Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them)
- Whether we have taken any legal positions (e.g., in connection with any statutes of limitation)
Rather than delete your data, we might de-identify it by removing identifying details.
7. How We Protect Your Information?
We protect your personal information with a series of organizational, technological, and physical safeguards — but we cannot guarantee its absolute security. We recommend that you use complex and unique passwords for your GDN accounts and for third-party accounts linked to them. Do not share your password with anyone.
If you have reason to believe your interaction with us is no longer secure, notify us immediately.
8. Are There Guidelines for Children?
GDN Services are intended for a general audience and are not directed at children under (13) years of age.
We do not knowingly gather personal information of children. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at [email protected]. We will remove the data to the extent required by applicable laws.
9. How Is Information Transferred Internationally?
The GDN Company is headquartered in the Kingdom of Bahrain. If you are located outside Bahrain, your information is collected in your country and then transferred to Bahrain — or to another country in which we (or our affiliates or service providers) operate.
If you are based in the European Economic Area (E.E.A.), when we transfer your data out of the E.E.A., we use a service provider in the United States that is Privacy Shield certified.
In certain situations, the courts, law enforcement agencies, regulatory agencies, or security authorities in those countries might be entitled to access your personal information.
10. What Is Your Legal Basis?
In some jurisdictions, like the European Union and the European Economic Area, we only collect, use, or share information about you when we have a valid reason. This is called “lawful basis.” Specifically, this is one of the following:
- The consent you provide to us at the point of collection of your information
- The performance of the contract we have with you
- The compliance of a legal obligation to which we are subject
- The legitimate interests of The GDN or a third party
“Legitimate interest” is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights and interests. “Legitimate interest” also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact.
We have a legitimate interest in gathering and processing personal information, for example:
- To ensure that our networks and information are secure
- To administer and generally conduct business within Al Hilal Publishing & Marketing Group
- To prevent fraud
- To conduct our marketing activities
11. What About Links to Third-Party Services?
If we make a significant or material change in the way we collect, use, or share your personal information, we will notify you at least 30 days prior to the changes taking effect. We will do this via email or prominent notice within GDN Services. If you object to any change, you can stop using the GDN Services.
13. How Can You Contact Us and Who Is the Controller of Your Personal Information?
If you have any questions, email us at [email protected] or write us at:
Al Hilal Publishing & Marketing Group WLL
PO Box 1100
Kingdom of Bahrain
We can also be reached by phone at +97317299123