Privacy Notice
This version last updated: 5 August 2026
Introduction
Welcome to the GAY TIMES LIMITED (t/a GAY TIMES Group) privacy notice.
GAY TIMES LIMITED (“GAY TIMES”) respects the privacy of all third parties that it has a relationship with and is committed to protecting personal data. This privacy notice will inform you as to how we look after your personal data (in all situations where we collect your data) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- Important information and who we are
- The data we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- How to complain
- Glossary
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how GAY TIMES collects and processes your personal data through all means, such as when you subscribe to the GAY TIMES publication; sign up to receive our website content or other GAY TIMES digital content; supply services to us; or use this website, including any data you may provide when you sign up to our newsletter, download a guide, or take part in a promotion.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements those other notices and is not intended to override them.
Controller
For the purpose of UK data protection law (the UK GDPR and the Data Protection Act 2018), and, where applicable to you, the EU General Data Protection Regulation (“EU GDPR”), the data controller is GAY TIMES Limited, Office 32 Epsilon House, West Road, Ipswich, Suffolk, England, IP3 9FJ (collectively referred to as GAY TIMES, “COMPANY”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.
Contact details
Our full details are:
Name of DPM: Solomon Thomson
Email address: solomon.thomson@gaytimes.com
Postal address: GAY TIMES Limited, Office 32 Epsilon House, West Road, Ipswich, Suffolk, England, IP3 9FJ
Before contacting the Information Commissioner's Office (ICO), we would appreciate the chance to deal with your concerns directly - see Section 10, “How to complain”, below. You also have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk).
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 23 July 2026.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data: invoicing address, email address and telephone numbers.
- Financial Data: bank account and payment card details.
- Transaction Data: details about payments to and from you and other details of services you have purchased from us.
- Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data: your purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data: information about how you use our services and website.
- Marketing and Communications Data: your preferences in receiving marketing from us and our third parties, and your communication preferences.
We also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law, as it does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data in accordance with this privacy notice.
We do collect some Special Categories of Personal Data about you, but only where you expressly provide such data to us (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and information about your health). We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under our terms of service, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our website or a subscription to GAY TIMES magazine).
3. How is your personal data collected?
We use different methods to collect data from and about you, including through:
Direct interactions. You may give us your Identity, Contact and Financial Data when subscribing to GAY TIMES magazine, filling in forms on this website, or corresponding with us by post, phone or email. This includes personal data you provide when you:
- enquire about or contract with us for our services;
- subscribe to our publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties, including:
- Technical Data from analytics providers, advertising networks, and search information providers;
- Contact, Financial and Transaction Data from providers of technical and payment services;
- Identity and Contact Data from data brokers or aggregators; and
- Identity and Contact Data from publicly available sources.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below a description of the ways we plan to use your personal data, and which legal basis we rely on to do so.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you — this is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us, purchased services from us, or provided your details when entering a competition or registering for a promotion, and in each case you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transaction.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to understand how processing for a new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below, for the purposes set out in the table in Section 4 above:
- External Third Parties, as set out in the Glossary.
- Specific third parties listed in the table in Section 4 above.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process it for specified purposes, in accordance with our instructions.
6. International transfers
Some of our external third parties are based outside the United Kingdom, so their processing of your personal data will involve a transfer of data outside the UK. Where we, or our EU/EEA-based partners, transfer personal data outside the EEA, similar considerations apply under the EU GDPR.
Whenever we transfer personal data internationally, we ensure an appropriate degree of protection is applied by using one or more of the following safeguards:
Adequacy: transferring personal data to countries that the UK government (or, for EEA-originated data, the European Commission) has formally recognised as providing an adequate level of data protection. Since the Data (Use and Access) Act 2025 reforms took effect on 5 February 2026, the UK applies a revised, risk-based “data protection test” when assessing adequacy of destination countries, rather than the previous binary adequacy standard.
UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses (SCCs): used for contracts with importers in countries without a UK adequacy decision. These replaced the pre-2022 EU SCCs for UK-originated transfers.
EU Standard Contractual Clauses (2021 version): used by our EU/EEA-based partners for transfers of EEA-originated personal data to non-adequate countries, together with a transfer risk assessment where required.
EU-US Data Privacy Framework (DPF) and its UK Extension: where personal data is transferred to organisations in the United States that have self-certified under the DPF (and, for UK-originated data, the UK Extension to the DPF, in force since 12 October 2023), that transfer is treated as benefiting from an adequacy-equivalent decision. We check the US Department of Commerce's DPF list to confirm an importer's current certification status before relying on this mechanism.
Please contact us if you would like further information on the specific mechanism used for a particular transfer of your personal data outside the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure; the purposes for which we process it and whether those purposes can be achieved by other means; and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, for tax purposes.
In some circumstances, you can ask us to delete your data — see Section 9 below. In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection law in relation to your personal data, including the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing of your personal data.
- Request transfer of your personal data.
- Withdraw consent.
- Complain to us directly about how we have handled your personal data, and, separately, to the ICO (see Section 10 below).
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data, or to exercise any other right. However, we may charge a reasonable fee, or refuse to comply, if your request is clearly unfounded, repetitive or excessive.
What we may need from you
We may need to request specific information from you to confirm your identity and ensure your right to access your personal data (or exercise any other right). This is a security measure to ensure personal data is not disclosed to anyone who has no right to receive it. We may also contact you for further information to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests; in that case we will notify you and keep you updated.
10. How to complain
If you consider that we have infringed data protection law in how we have processed your personal data, you have the right to complain to us directly, before or instead of contacting the ICO.
You can submit a complaint to us by:
- emailing our DPM at solomon.thomson@gaytimes.com with the subject line “Data Protection Complaint”; or
- writing to us at GAY TIMES Limited, 118 Hackney Road, London, United Kingdom, E2 7QU marked for the attention of the DPM.
When you complain, please provide enough detail for us to understand the issue (for example, what personal data is involved, and what you believe we have done wrong). We will:
- acknowledge your complaint and take appropriate steps to investigate it without undue delay;
- keep you informed of progress and of the outcome without undue delay; and
- keep a record of your complaint and how it was resolved, in line with our accountability obligations.
Making a complaint to us does not affect your right to complain to the ICO at any time, whether before, during or after we have handled a complaint you have raised with us directly (www.ico.org.uk).
11. Glossary
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you (positive and negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted to by law. You can obtain further information about how we assess our legitimate interests by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
Third parties
External third parties
- Service providers acting as processors, based within or outside the UK, who provide services that support the services we supply to you.
- Professional advisers, including lawyers, bankers, auditors and insurers, who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your legal rights in detail
You have the right to:
- Request access to your personal data (a “data subject access request”): to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it.
- Request correction of the personal data we hold about you: to have incomplete or inaccurate data corrected, though we may need to verify the accuracy of new data you provide.
- Request erasure of your personal data: to ask us to delete or remove personal data where there is no good reason for us to continue processing it, including where you have successfully objected to processing, where we may have processed it unlawfully, or where erasure is required to comply with local law. We may not always be able to comply for specific legal reasons, which we will explain to you at the time.
- Object to processing of your personal data where we rely on legitimate interests (or those of a third party) and something about your particular situation makes you want to object, or where we process your data for direct marketing purposes. In some cases we may demonstrate compelling legitimate grounds that override your rights and freedoms.
- Request restriction of processing of your personal data, for example while we establish its accuracy, while a legal claim is being resolved, or while we assess an objection you have raised.
- Request the transfer of your personal data to you or to a third party, in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use, or which we used to perform a contract with you.
- Withdraw consent at any time, where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw consent. If you withdraw consent, we may not be able to provide certain products or services, and we will advise you if this is the case.
- Complain to us directly, and separately to the Information Commissioner's Office, about how we have processed your personal data (see Section 10 above).