Privacy Policy

A- Type of Personal Data Processed

Name, Last name, Contact Details and other Personal Data

Panini UK may ask your personal information such as: first name, surname, e-mail address, month and year of birth, postcode, town, county and country of residence.

We may process other Data such as any text messages, drawings or registration information received by us, on the occasion of participation in competitions, promotions, and initiatives of any kind. Further Personal Data may be collected during the management of each relationship with Panini UK or may consist of those that you decide to provide to Panini UK through the use of the Contact area on the Website.

Payments are not directly processed through the Website, and are processed through the panini.co.uk, paninisubscriptions.co.uk and https://pocketmags.com/doctor-who-magazine websites. Data collected relating to payment will be processed in line with their respective privacy policies which can be accessed here: https://legals.paninigroup.com/en_GB/privacy/store-uk, https://www.paninisubscriptions.co.uk/privacy.htm and https://pocketmags.com/privacy-policy.

We may process data coming from your submission of texts or registration information, on the occasion of participation in competitions, promotions, interactive games and initiatives of any kind. Further Personal Data may be collected during the management of each relationship through the Website itself or may consist of those that you decide to provide to Panini UK through the use of the Customer Service area of ​​the Website.

Some sections of the Website can include free text fields in which it is possible to provide Panini UK with information that may contain Personal Data.

Being free fields, you may choose to communicate (even inadvertently) particular categories of Personal Data, such as those revealing political opinions, religious or philosophical beliefs, or union membership, as well as genetic data, biomedical data which can be used to uniquely identify a specific person, data related to health or sex life or sexual orientation.

Panini UK asks you not to disclose any of these types of Data, unless you consider it strictly necessary to pursue the request you forward to us. Since the provision of such information is, as said, totally optional, if you choose to do so, Panini UK shall process such Data only with your explicit consent and in compliance with the applicable legislation. If you submit these types of data, Panini UK will be entitled to treat such submission as indicating your explicit consent to the processing of these particular categories of Personal Data.  Panini UK underlines the importance of expressing your explicit consent to the processing of these particular categories of Personal Data in case you decide to share them with Panini UK. You may request the removal or deletion of this data at any time by contacting us.

Personal Data of Third Parties

As mentioned in the previous paragraph, free text fields in the Website make it possible to create any type of message, including those that contain Personal Data relating also to other people. In the event that you do decide to share such Data, you will be considered an autonomous data controller (i.e. the entity that determines the purposes for which and the means by which Personal Data is processed) and, as such, you will have to assume all the relevant legal obligations and responsibilities. Therefore, in this regard, you agree to be responsible for and to protect Panini UK from and against any dispute, claim, request for compensation for damage from data processing etc. that could reach Panini UK from people whose Personal Data have been forwarded by you without their consent or otherwise in violation of the applicable rules on the protection of Personal Data.

As, in such cases, Panini UK does not collect this information directly from the data subjects (but indirectly from you), you guarantee that this specific processing can be based on the consent of these data subjects or on another suitable lawful basis that legitimises the processing of the information in question. You agree to indemnify and keep Panini UK indemnified against any claims from third parties whose Personal Data you may have provided without their consent.

IP address spatial coordinates

When you create a profile/account on the Website, we will collect the approximate spatial coordinates (state, city) of your IP address associated, only, with your last log-in. We will keep this information only to the extent strictly necessary and proportionate to ensure the Security of the Website and to identify anomalies, fraudulent activities and/or abuse in the use and access to the Website.

Browsing Data and Cookies

As you interact with our Website, we will automatically collect system and technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. The computer systems and software used to run the Website acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected by Panini UK to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow data subjects to be identified. This category of Data includes the IP addresses or domain names of the computers used by the users connecting to the Website, the addresses in URI (Uniform Resource Identifier), notation of the requested services, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (good result, error, etc.) and other parameters related to the operating system, browser and the user’s device.

The information on the use of cookies is available in our Cookie Policy, which we kindly ask you to read by clicking on the following symbol  and/or (Manage Cookies) in the Website footer.

B- Personal Data Processing of Children below the Age of 13

The Website is intended for use by those individuals aged 13 and over. You are not permitted to use this Website or send your personal information to us if you are under the age of 13. Panini UK does not knowingly collect, use or disclose personal information from children under 13.

C- Purposes of the Personal Data Processing

We will process your Personal Data for the following purposes:

• allowing the execution of operations strictly connected and instrumental to the management of relationships with you, such as managing the response to queries received from you via the contact forms or received by Panini UK (electronically and/or on paper) via any of the addresses/contact details indicated on the Website; allowing you to participate in games, initiatives, competitions and prize events; allowing the correct execution of the contractual obligations we have assumed towards you and vice-versa; and also supporting you when you subscribe or purchase online any product related to doctorwhomagazine.com on other sites such as, for example, panini.co.uk or www.paninisubscriptions.co.uk  or https://pocketmags.com/doctor-who-magazine (Services Provision & Contractual Obligations);
• complying with laws, regulations of UK or EU legislation (as applicable) or with provisions issued by authorities empowered by law and provisions issued by Supervisory and Control Bodies, as well as allowing tax and accounting compliance (Legal Compliance);
• to get the information required to identify anomalies, illegal activity and/or abuse of the use of the Website towards Panini UK or third parties (Security).

• carrying out information activities about our products and/or services as well as promotional, commercial, marketing campaigns and market research through the use of automated systems (for example, e-mail), through the official pages managed by Panini UK on social networks; through traditional methods of contact, such as the postal service; performing customer satisfaction surveys (by sending questionnaires, conducting surveys or telephone surveys). Other than Existing Customer Marketing as described above, we will only send you direct marketing via email, post or telephone if you have consented to receiving marketing via that method (Marketing);
• if you are using or have used a service on our Website or if you are purchasing or you have purchased a product or a service through the Website, we may send you direct marketing and promotional communication via e-mail about similar products or services unless you have elected to not receive such communications (Existing Customer Marketing);
• setting-up groups of users by processing the Data provided by our users so that we don’t send generalised commercial and promotional communications to all users in an indistinct way. This enables us to segment users, creating groups based upon common features for example, on the country of origin, language, gender, previous purchases, etc. This allows us to send commercial communications – through the use of automated systems (for example, e-mail), but also through traditional methods of contact, such as the postal service – that are the most relevant and least invasive possible, limiting as far as possible the circumstance that you receive messages not of your interest.
• If you have simultaneously provided consent for the purpose of “Marketing”, this then allows us to send you commercial and promotional communications that are not generalised and indistinct and, therefore means that you receive the most relevant and least invasive communications for you, limiting as far as possible the circumstance that you receive messages that are not of your interest. Communications may be sent via automated systems without operator intervention (e.g. email); traditional methods of contact (e.g. post, telephone; Panini UK’s official social pages (such as Facebook, Instagram and other social platforms – reach them through the social icons on our Websites) with the related online publication of personalised and specific ads / posts / advertisements relating to the Panini world (with custom activities audience or custom audience); (Customising our communications).
• to provide contact data for specific initiatives to create an account or profile on the Website to third parties – individually and specifically indicated each time in the relevant consent form, when present at the time the Data is provided – with which Panini UK has commercial relationships in order to allow the latter to send you promotional, marketing communications and commercial information or to carry out market research for the products and services of those third parties (Communication to third parties).

D- Lawful Basis for Processing Personal Data, Mandatory/Discretionary Provision of Personal Data and Consequences in case of not providing

The lawful basis for processing the Personal Data by Panini UK, in accordance with the purposes set in the earlier Section of this Privacy Policy (“C- Purposes of the Data Processing”), is as follows.

The provision of Personal Data and the related processing for the purposes related to Services Provision and Contractual Obligations, is necessary for the performance of the requested service and the correct execution of the contractual relationship with you. Consequently, failure to provide the Personal Data requested for this purpose, or the inaccuracy of the data provided, will make it impossible for Panini UK out the service and the contractual relationship and would legitimise Panini UK to carry it out.

The provision of Personal Data, and the related processing for purposes related to Legal Compliance, is necessary for Panini UK to comply with the related legal obligations deriving from the laws of the EU / UK (as applicable). When you provide your Personal Data to Panini UK, we must process the Personal Data in accordance with applicable laws which may include the storage and communication to the competent authorities for compliance with tax, customs or other obligations.

The provision of Personal Data and their processing for purposes related to Security are based on  the interest of Panini UK to identify and prevent any illegal behaviour and to determine the responsibilities in the event of computer crimes to the detriment of the Website such as to compromise the availability, authenticity, integrity and confidentiality of the Personal Data stored or transmitted, and in your interest in order to detect and follow up the appropriate checks in case of fraudulent access or acts illegal through the profile you created on the Website.

The provision of Personal Data, and the related processing of such data for the purposes related to the Marketing activity, is based on your consent collected through a specific checkbox. You are not forced to provide such consent to Panini and, if you do so, you are free to withdraw it at any time without suffering any consequence (other than not receiving marketing communications from Panini). You can withdraw your consent for this purpose by following the instructions contained in the “Data Subjects Rights” section of this Privacy Policy or, where the communications are sent by email, by using the link at the bottom of each of the emails received for that purpose.

The provision of Personal Data, and the related processing, for the purposes related to the activity of Existing Customer Marketing is based on the legitimate interest of Panini to send marketing communications via e-mail regarding products and services similar to those you have already used or purchased through the Website. You can stop the receipt of these communications without suffering any consequence (other than that of not being able to receive further communications of this kind by Panini) using the link at the bottom of each of the e-mails received for that purpose.

The provision of Personal Data, and the related processing, for the purposes related to Customising our communications is based on your consent collected through a specific checkbox and based on our legitimate interests. You are not obliged to provide such consent to Panini and, if you do so, you are free to revoke it at any time without suffering any consequence (other than not being able to benefit from the personalisation of Panini’s commercial offers). You can withdraw your consent for this purpose by following the instructions provided in the “Data Subjects Rights ” section of this Privacy Policy.

We will use a specific checkbox to collect your consent to provide and permit the relevant processing of your Personal Data for Communication purposes to third parties. You are under no obligation to provide Panini with this consent and, if you do so, you are free to withdraw it at any time. The only consequence will be to prevent communication of your personal data to any third parties, specifically named individually from time to time in the relevant consent form when you provide your Data, so they may subsequently send you marketing communications. We wish to specify that this particular consent form is provided and is present only when specific initiatives are running. You can withdraw your consent to the communication of your Data by following the instructions in “Data Subject Rights” in this Privacy Policy

E- Recipients of the Data

Personal Data will be made known to the Panini UK staff in charge of the development and management of the Website, who are authorised to process it for the purpose of achieving the aforementioned purposes and who are committed to confidentiality or otherwise have received an appropriate legal obligation to confidentiality.

The Data will be disclosed to subjects who hold the role of system administrators: these are our employees or our data processors who are entrusted with the management of our IT systems and who therefore have the power to access, modify, suspend and limit the processing of your Data. These subjects have been previously selected and appropriately trained.

Personal Data may be shared, used and transferred within the companies belonging to the Panini group for accounting and administrative purposes.

Personal Data will be disclosed to third parties who are appointed as Data Processors, who process Data on behalf of Panini UK (for example, companies responsible for managing and processing sales orders, suppliers with whom it is necessary to interact for the service provision such as hosting providers, platform providers for sending e-mails or, again, suppliers who perform technical maintenance activities including the maintenance of network equipment and electronic communications networks, suppliers who develop interactive games and competitions).

Personal Data may be shared with third parties with whom Panini UK has ongoing contractual relationships concerning services functional to the performance of the activity (such as audit firms, persons, companies or professional firms that provide assistance and advice on the subject, administrative, legal, tax, financial and credit recovery firms relating to the provision of the services).

Where you have given consent to Data being shared for Communication purposes to third parties Data will be shared with the applicable third parties for whom consent has been given.

Finally, Personal Data will be communicated when requested to the competent taxation offices, or to other public bodies, according to the provisions of the laws in force.

Personal Data is not intended for publication or dissemination.

More information is available by writing to Panini UK at the following address: webprivacy@panini.co.uk

F- Personal Data Transfer

Given the international presence of Panini group, some of your Personal Data may be shared with recipients, referred to in the previous paragraph, which could be found in countries outside the UK and European Economic Area. Panini UK ensures that the processing of your Personal Data by these parties will be in compliance with applicable law. Therefore, the transfers will be made with adequate guarantees, such as adequacy decisions, models of Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.

More information is available by writing to Panini UK at the following address: webprivacy@panini.co.uk

G- Personal Data Retention

The Personal Data processed for the purpose of Services Provision and Contractual Obligations will be retained by Panini UK for the time strictly necessary for the execution of the requested service and for the correct execution of the contractual relationship with you. As this Personal Data is processed to provide you with the services and allow the execution of the contractual relationship, Panini UK may keep them for a longer period, in particular for what may be necessary in order to protect the interests of Panini UK against possible claims arising from the services provision.

In any case, Panini UK specifies that the retention time related to any orders and purchases you have made is equal to 24 months from the order payment. Panini UK specifies that it will keep your authentication credentials to the Website services for up to 54 months from the date of the last login. Before the expiration date, Panini UK will send you an e-mail to the e-mail address you have provided to notify you about the next cancellation of your account. After the end of the retention period, your personal data will be deleted or will be made anonymous.

Your requests, and the data contained in them, collected via Contact area on the Website will be maintained for one year from the closure of the request in order to allow Panini UK to handle any additional requests received after closure. At the end of this period the Data that permit the identification, even indirect, of a physical person (such as name, surname, email) will be made anonymous and will only be retained in the form of aggregated data, for statistical purposes.

The Personal Data processed for the purposes of Legal Compliance will be retained by Panini UK for the period necessary to comply with specific legal obligations or applicable legislation.

Personal Data processed for the purposes of Security will be kept by Panini UK for such period Panini UK considers necessary for the said purposes.

The Personal Data processed for the purposes of Marketing and Customising our Communications will be retained by Panini UK until the revocation of the consent you have given and reviewed periodically. Once your consent is withdrawn, Panini UK will no longer process your Personal Data for such purposes, but may retain them, particularly as may be necessary in order to protect Panini UK from legal action or other risks based on such processing (i.e. some of your identification data may be stored as necessary for Panini UK to be able to demonstrate the correct acquisition and / or revocation of your consent at a given time). Panini UK, from time to time, for the execution of “Marketing” and “Customising our Communications” purposes, may use the details of any order and purchase you have made in the previous 24 months.

Storage times of Personal Data processed for Communication to third parties are the same as those indicated above for authentication credentials. The reason behind this is that the information provided, following consent, consists only of the contact data provided when you created an account or profile on the Site or via the App. Nevertheless, it remains understood that if you revoke your consent, Panini UK will stop communicating that Data to third parties individually and specifically indicated in the relevant consent form.

The Personal Data processed for the purpose of Existing Customer Marketing will be kept by Panini UK until you object to the process through the link found at the bottom of each of the Existing Customer Marketing e-mails sent or until we consider that such Personal Data is no longer accurate or necessary.

H- Data Subject Rights

As Data Subject, you have the following rights, which can be exercised at any time:

• to request access to your Personal Data, (and/or a copy of such Personal Data), as well as further information on the current treatment of them;
• to request the correction or updating of your Personal Data processed by Panini UK, where they are incomplete or out of date;
• to request the deletion of your Personal Data from the Panini UK databases, where you deem the processing unnecessary or illegitimate;
• to request the limitation of the processing of your Personal Data by Panini UK, where you believe that your Personal Data is not correct, necessary or is unlawfully processed, or if you had opposed its processing;
• to exercise the right to data portability, i.e. to obtain a copy of the Personal Data supplied to Panini UK that relates to you in a structured format, for common use and readable by an automatic device, or to request transmission to another Data Controller;
• to oppose the processing of your Personal Data, using a legal basis relating to your particular situation, which you believe should prevent Panini UK from processing your Personal Data; with reference to exercising the right of opposition with respect to the purpose of “Anti-fraud controls” the same may not be given if Panini UK believes that there are compelling legitimate reasons for proceeding with the processing in any case;
• to revoke your consent to cookies for profiling purposes when using the Website by clicking on the Settings button in the appropriate banner, always accessible by clicking on the following symbol  and/or (Manage Cookies) located in the footer of the Website;

• to revoke your consent for purposes of Marketing, Customising our Communications and Communication to third parties and to oppose processing for the purpose of Existing Customers Marketing. Please remember that consent expressed by sending promotional communications for the purposes of Marketing and Customising our Communications extends not only to communications sent using automated systems without an operator (e.g. email), but also via traditional contact methods, e.g. postal services and telephone. You can always revoke your consent to processing, even separately, e.g. by deciding to receive communications only by post and not via automated systems such as email, or also by blocking the use of third party profiling cookies on Panini websites to stop receiving such communications.

Please note that the Personal Data you provided to Panini UK may be changed at any time by writing to us. You may exercise the above rights by writing to Panini UK at webprivacy@panini.co.uk

We inform you that for the Marketing and Existing Customer Marketing Soft Opt-In purposes you can revoke and terminate at any time the sending of this commercial information, by writing to the e-mail address indicated above, in addition to using any unsubscribe options set out in the relevant e-mails.

In particular, if the information provided by you is not sufficient to identify you unambiguously and / or with a sufficient degree of certainty, taking into account the specific type of right exercised (such as, in particular, those of access, copy and cancellation), Panini UK will request further information from you as required by specific regulatory provisions regarding the protection of personal data. In the event that Panini UK detects the absence or lack of suitable data to identify you and therefore there are reasonable doubts about your identity, Panini UK may then ask you to provide a copy of an identification document or any additional information deemed useful for your identification. In the event that you provide such a document, personal details such as your first and last name and your address should be clear in order to be able to identify you correctly, while any other information such as your photo or any other personal characteristics not necessary for identification should be removed or obscured before sending. We specify that our use of the information on your identity document is strictly limited to fully accounting for your request: in fact, such Data will be used only to verify your identity and will not be kept for longer than necessary for this purpose.

You can also stop receiving Marketing to Existing Customers by using the appropriate link at the bottom of each email received (via the “Unsubscribe” button).

We inform you that for Marketing purposes you can revoke and terminate at any time the sending of this commercial information, by writing to the email address indicated above or, in the case of communications received through IT tools, following the procedure indicated at the bottom of the communication (via the “Unsubscribe” button).

As regards Marketing via push notifications on your device (if you are using the Application), you can revoke your consent via the settings on your Device. More specifically, on an iOS device you need to go to “Settings”, then “Notification centre”, select the App and disable the relevant notifications. If you have an Android Device, go to “Settings”, scroll to the bottom to “Notifications”, use “Show All” or “Sent recently” to select the App and block notifications via “Show/Consent Notifications”.

Consent for the purpose of Customising our Communications can be revoked by changing, at any time, the preferences of the user profile that can be created on the Site or by writing to the email address to the email address webprivacy@panini.co.uk.

If, on the other hand, you are using the Site and intend to block the use of third party profiling cookies and therefore prevent, when for example using social networks, the display of communications (such as specific ads/posts/insertions regarding the Panini world) please refer “How to manage or delete cookies” section in the cookie policy.

You can revoke your consent for Communication to third parties– Panini UK at any time, by modifying your user profile preferences, which can be created on the Site (also accessible via the Application), or by writing to the email address: webprivacy@panini.co.uk. To stop receiving third-party marketing communications, to which you have already agreed, specified and identified individually each time, you must read the procedures in the specific Privacy Policy provided by the third party as that third party will be acting as a Data Controller in their own right. Panini UK informs you that you always have the right to lodge a complaint with the competent Supervisory Authority (for example that of the State in which you have your habitual residence: in UK, this is the Information Commissioner’s Office or “ICO”, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113, www.ico.org.uk.) if you believe that the processing of your Data is contrary to the legislation in the field of personal data protection currently applicable.

I- Privacy Policy Amendments

This Privacy Policy 2.0 version is effective from 21 November 2023. Panini UK reserves the right to modify or update its content (in part or completely), including where there are changes to the applicable legislation. Panini may not inform you of these changes as soon as they are introduced, but they will be applicable as soon as they are published on the Website. Panini UK invites you to visit this section regularly to review the most recent and updated version of the Privacy Policy in order to understand the Personal Data collected and the use that Panini UK makes of it.

Panini UK Ltd (company number: 01275893), Brockbourne House, Mount Ephraim, Tunbridge Wells, Kent TN4 8BS.