This privacy policy applies to the information that Oath (UK) Limited or data processors acting under our control may collect about you from any device you use to access Oath or HuffPost UK brand products, services, software, websites, and other goods and services offered, owned, or operated by Oath (UK) Limited, its subsidiaries and Affiliates ("Oath", “We” and/or “Us”) (collectively, the "Oath Services"). Some of these services may provide you with additional information and choices about your privacy, which you should review.

This policy does not apply to information about you collected by third party websites and offerings linked to or otherwise accessible from Oath Services. The information collected or received by third parties is subject to their own privacy policies.

Further, Oath and its affiliates collect and process personal information from users within the European Union in connection with their various product and service offerings, which include portal services (such as AOL.co.uk); and advertising services (such as those offered by Oath brands, such as ONE by AOL advertising services.

Collection of Your Personal Information

We collect or receive information about you when you register for and use the Oath Services. Registering with Oath Services such as AOL Mail or HuffPost UK is optional and we may collect information even if you do not register. Depending on how you use the Oath Services, your personal information (“Personal Information”) may include:

  • registration-related information (such as name, addresses, e-mail addresses, telephone numbers, birth date, or gender) which you may provide when you register for or log into an Oath service or HuffPost account, order products or services from Oath Services, or enter prize promotions;
  • information about the Oath Services that you use, how frequently you use them (such as your use of AOL Mail or AOL Instant Messenger); and your responses to the offerings and advertisements presented on Oath Services or other features made available by Oath, including those available on third party websites;
  • information about the searches you perform through Oath Services and how you use the results of those searches;
  • personal financial information related to the use of Oath financial features (such as My Portfolios).
  • transaction-related information (such as credit card or other preferred means of payment, billing or shipping information, or a history of products purchased through the AOL UK Lifestore);
  • your customer service information (including web services account activity histories and records of your communications with our customer services team);
  • records of your communications with us (whether in writing, by email or by telephone) for the training and monitoring of our staff and to improve our service;
  • location data and other information about devices used to access and interact with Oath Services;
  • other information specifically related to your use of Oath Services, including information that you publicly post using tools made available by Oath; or
  • information about your online activities – for example, your patterns of browsing, clicking, purchasing and searches you perform when using the Oath Services – so that we can tailor your experience of the Oath Services according to your apparent preferences, as expressed through those patterns of activity.

Your Personal information may be supplemented with additional information from other companies such as:

  • publicly available information, information about households,
  • commercially available demographic information which we obtain from third party organisations (for example, Experian) in order to deliver customised advertising and/or content to you. In most cases this will involve the physical transfer of Personal Information held by Oath to that third party organisation, but strictly on the basis that such third parties will act as Data Processors on Oath’s behalf in respect of such data, and as such will have no independent rights of access to or use of the Personal Information. This means that, among other things, the third party organisation in question must securely delete/return to Oath all such data when Oath’s arrangements with that third party come to an end, and may not use the data in any way other than as specifically instructed by Oath,
  • third party social networking services (such as Facebook or Twitter) when you access such third party social networks through Oath Services, your username and connection lists for those services (for further information on this, see our ‘Social Media Interactivity’ below)
  • and other information which we may append or match to your Personal Information.

Oath Services may also receive or collect certain technical information when you use Oath Services. This may include: your browser or operating system, your manner of connecting to the Internet (including the type of device you are using) and the name of your Internet service provider or wireless carrier; your Internet protocol (IP) address; your unique Device Identifiers; information about Oath Services that you used prior to registering; and data relating to malfunctions or problems occurring when you use your device with Oath Services. Additionally, we may collect information about other software on your device for the limited purpose of protecting your security or improving your online experience.

Social Media Interactivity

To customise your experience on Oath Services and to simplify our registration processes, we provide you with the opportunity to access or interact with third-party services, such as Facebook and Twitter. When you login to Oath Services through these third-party services, we may share information about you with these third-party service providers and they may share data about you with us.

When you allow us to access your data through a third-party service to create an account, we may use this data for several purposes, including:

  • Creating relationships automatically within our system. For example, if you connect to us via a service with a public friend list, like Twitter, we may check to see if any people you follow on Twitter also hold Oath Services accounts. If we find a match, we will replicate your Twitter relationship with those Oath Services members, setting them to be fans, followers, or friends on the Oath Services.
  • Suggesting relationships. For example, if you connect via a service that has a private contact list (like Google and Yahoo!), we check for people in your contacts who are Oath Services members and suggest that you become a fan of these users. This process is not automatic; you must affirmatively choose to become a fan of these suggested users.
  • Populating a list of potential friends to whom you can send emails. When users share content with their friends using, for example, the forward-to-a-friend feature on AOL, we may use friend lists from third-party services to create a list of contacts to whom you may choose to send the email message.
  • Populating a list of potential friends to whom you can send service-specific messages. For example, we may use friend lists from a third-party service to create a list of contacts to whom you may choose to send an invitation to view an interactive slideshow.
  • To enhance and personalize your experience on Oath Services. When you are connected via a third-party service, we may access certain account information, such as your profile picture, what stories are popular in your network, and what your friends are saying about certain articles or blog posts, in order to enhance and personalize your experience on Oath Services.

In addition, if you connect to a Facebook account, your experience on the Oath Services may be personalised. For example, you may automatically see what stories are popular in your network, and what your friends are saying about particular stories.

Please note that you may disconnect third party accounts at any time. You also may be able to modify your privacy settings directly with the third-party service. In addition, you can modify your Facebook privacy settings and your Twitter privacy settings.

Please remember that we do not control the privacy practices of these third-party services. We encourage you to read the privacy policies of all third-party service providers.

How Your Personal Information is Used

Your Personal information is used for purposes that include:

  • to operate and improve the Oath Services;
  • to personalize the content and advertisements provided to you (including to present offers to you on behalf of business partners and advertisers);
  • to fulfill your requests for products, programs, and services;
  • to communicate with you by electronic methods (including email, text, picture, video and SMS messaging), about offers and information on the products and Oath Services offered by Oath or third parties and respond to your inquiries;
  • to conduct research about your use of Oath Services;
  • to help offer you other products, programs, or services that may be of interest;
  • to provide you with an open, but also civil, discussion forum on HuffPost UK. We track user involvement in our HuffPost UK community discussions.

If we propose to use your Personal Information in a way which is not covered by this Privacy Policy, we’ll tell you how we propose to use it at the time we collect it.

In accordance with our Cookie Policy, Oath may use cookies, web beacons, or other technologies in combination with your Personal information to enhance and personalize your experience on Oath Services.

Oath Services may use information about your use of certain communication tools (for example, AOL Mail or AOL Instant Messenger); however, when you use Oath communication tools, Oath does not read your private online communications without your consent.

International Transfers of your Personal Information

Oath is headquartered in the United States of America, and we may transfer your Personal Information to our group offices or Affiliates in the U.S. in the course of providing our services to you. In addition, many of our business partners and the companies that process information on our behalf are also based in the U.S. or in other countries outside of the European Economic Area (the "EEA").

This means that your Personal Information (which can include information you provide about your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or concerning health or sex life) may be transferred to countries which are both inside and outside the EEA.

These countries may not have similar data protection laws to the EEA.  However, where we transfer your information outside of the EEA in this way, we will take steps to ensure that an adequate level of protection is applied to your Personal Information, and that your privacy rights continue to be protected in compliance with applicable data protection law and this Privacy Policy. Such steps may include, (to the extent applicable) data transfer agreements based on EU Commission approved standard contractual clauses, or your consent.
 
By using our services, or by providing us with your Personal Information, you consent to the transfer of your Personal Information to Oath offices, affiliates and third parties located in countries outside of the EEA.  

Details of the companies processing your Personal Information, and the countries in which they are located, will be provided on request, by writing to the Data Controller: Details of Data Controller

How Long do we Keep Personal Information?

We may retain your Personal Information as long as is necessary for the purposes for which we collected it or for the period to which you consent under the Oath UK Web Services Agreement, as explained here or under the specific terms applicable to your use of the Oath Services, or as is otherwise required by applicable law. We may process your Personal Information for a reasonable period after your Oath Services account is cancelled. However please note that any information that we have copied may remain in back-up storage for a longer period.

If you have purchased any paid for Oath Services (for example, via the AOL Lifestore), we may retain payment-related information, such as a payment card number which you supplied to us for billing purposes for an unlimited period after your paid for Oath Services account has been cancelled for fraud prevention purposes.

Sharing of Your Personal Information

Oath does not rent or sell your Personal information (such as name, address, telephone number, screen name, and debit or credit card information) to third parties for their marketing purposes. Oath may share your Personal information with third parties to provide products and services you have requested, where you have clearly indicated you would like this to happen, or as described in this Privacy Policy and our Oath UK Web Services Agreement.

Your Personal information may be shared with sites and services consistent with this Privacy Policy. You have choices about how your Personal information is used. Oath may be obliged to disclose the contents of your online communications, as well as other information about you as an Oath user, in the following circumstances:

  • if we or an entity processing your Personal Information our behalf is compelled to do so by law in response to lawful governmental requests or legal process (for example, a court order, search warrant or subpoena),
  • in other circumstances in which Oath believes that a crime has been or is being committed by an Oath user, or that there is a threat to the safety of you or another person,
  • or otherwise in accordance with applicable laws and regulations.

Please note that if you use Oath communications tools to disclose information about yourself publicly (for example, by leaving a comment on an Oath Service), others outside of Oath may obtain access to information you provide.

Oath Services may include features or functionalities provided by third parties. In the process of providing such functionalities within the Oath Services, your browser may automatically send certain technical information to the third party provider. The use of these third-party provided features or functionalities is subject to their own privacy policies. In addition if you make any online purchases and/or registrations from third parties whilst using Oath Services, make sure that you review their privacy policies and contact them directly if you have any questions. They may have privacy policies that differ from Oath and they may therefore use Personal Information which you provide to them differently.

Business partners or other third parties may receive data about groups of Oath Services users, but do not receive information that personally identifies you.

We may use agents and contractors in order to help operate Oath Services. Their use of information is limited to these purposes.

In the event that ownership of Oath was to change as a result of a merger, acquisition, or transfer to another company, your Personal Information may be transferred. If such a transfer results in a material change in the use of your Personal Information, you will be provided notice about the choices you have to decline to permit such a transfer.

Display of Advertising

Your Oath information may be used for the presentation of advertisements. Oath and its advertisers may use ad networks (including ONE by AOL advertising services) to customize and display advertising on the Oath Services. Oath may collect and share certain information about you as a user (such as age, post code, or other information we have collected or received) with certain ad network and service providers to help them deliver more relevant content and advertisements through their networks. These ad network and service providers may use cookies, or web beacons or similar technologies on your device to tailor content, advertisements to your preferences, help target, measure and track your visits and the effectiveness of advertisements and promotions, using data gathered over time and across their networks of sites to determine or predict the characteristics and preferences of their audience and to provide security within shopping baskets or transactions. The use of cookies, web beacons, or similar technologies by other ad network, content, and service providers is subject to their own privacy policies, not this one.

As noted above, we use the data we collect or receive about users' online activities to help us show ads for products or services users are likely to be interested in. Please note that we retain certain information for a limited time to aid in the targeting of ads, as well as for fraud detection and prevention. Data used to create segments for ad targeting is retained for no longer than 2 years. Other data (for example, data used to determine long-term or seasonal trends) may be retained for as long as Oath has a legitimate business reason for retaining it.

Oath adheres to the European Interactive Digital Advertising Alliance's ("EDAA") principles.

You can learn more about advertising displayed on or by Oath Services as well as how you can control the use of your Personal information for such advertising.

Your Choices about Your Personal Information

  • AOL provides you with access to your registration information and where you have purchased any fee-based AOL services, any billing information, as well as the ability to edit this information and cancel fee-based AOL services at My Account.
  • You can change and review your AOL Marketing Preferences and make choices about how your Personal Information may be used to provide marketing offers to you. These preferences do not apply to communications that are directly related to your registration with AOL, or the fulfillment of a specific transaction you have requested (for example, a service advisory from AOL, or an acknowledgment of a purchase order).
  • Visit Advertising, Analytics, and Privacy to learn more about your choices related to online advertising.
  • Some Oath Services (AOL Search, for example) may also offer you the ability to manage and control information collected or used when you use these services.

Our Commitment to Security

Oath has established safeguards to help prevent unauthorized access to or misuse of your Personal Information, but cannot guarantee that your information will never be disclosed in a manner inconsistent with this Privacy Policy (for example, as a result of unauthorized acts by third parties that violate applicable law or Oath and its affiliated providers' policies). To protect your privacy and security, we may use passwords or other technologies to register or authenticate you and enable you to take advantage of Oath Services and before granting access or making corrections to your Personal Information.

Protecting Children

Oath Services are intended for a general audience, and children should not register without the consent of a parent or guardian. We urge all parents to educate their children about online safety and the need to protect their Personal Information. In any event, Oath does not collect any Personal Information of anyone under the age of 13 without disclosing how that information will be used or without parental consent.

How to Contact Us

If you wish to gain access to your Personal Information (as defined in the UK Data Protection Act 1998), or if you have any questions or concerns about the Oath UK Privacy Policy or its implementation, you may contact the data controller, Oath (UK) Limited, as follows:

In writing to:

Data Protection Officer
Oath (UK) Limited
Shropshire House
11-20 Capper Street,
London, WC1E 6JA
or via email to: datainfouk@aol.com

Changes to this Privacy Policy and Additional Information

Oath may update this Privacy Policy from time to time, and so you should review this Privacy Policy periodically. If there are significant changes to Oath’s information practices, you will be provided with appropriate online notice. You may be provided other privacy-related information in connection with your use of offerings from Oath as well as for special features and services not described in this Privacy Policy that may be introduced in the future.

Oath (UK) Limited is registered with the UK Information Commissioner’s Office under registration number: Z5298132.

Last Updated: 13 June, 2017