Privacy notice
This notice explains what personal data is processed when you use weareapacc.com, why, on what legal basis and what you can ask us to do about it. It describes the website as it is actually set up.
1. Who is responsible
The controller is PushImpact OÜ, Ahtri tn 12, 15551 Tallinn, Harju County, Estonia, registry code 16908233, represented by its management board member Stephan Alexander Hofmann.
Email for data protection matters: privacy@weareapacc.com · Telephone: +372 5847 2913
The controller is established in Estonia, so the EU General Data Protection Regulation (EU GDPR) and Estonian data protection law apply, and the lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon). Because this website is written for readers in the United Kingdom, the data of UK readers is also covered by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. In this notice “GDPR” means both; the article numbers are the same in each.
2. In short
- You can read every article without entering any personal data.
- Fonts and images are served from our own server, not from third parties.
- On content pages the Outbrain measurement pixel is active (see section 5). No other advertising or analytics tag is active.
- Your cookie choice is stored in your own browser.
- For the newsletter we need only your email address and your consent.
3. Visiting the website and server logs
When you open a page, your browser sends technical data to the server: IP address, date and time, the address requested, the amount of data transferred, the referring page, and browser and operating system details. This data is processed in server logs to deliver the website, keep it secure and fix faults. This happens before any cookie choice, because it is part of delivering the site.
The legal basis is our legitimate interest in running a secure, working website (Article 6(1)(f) GDPR). Logs are kept only as long as needed for these purposes and then deleted. The site is run by a hosting provider acting as our processor under Article 28 GDPR.
4. Storage in your browser
The website itself does not use cookies to track you (for the Outbrain pixel, see section 5). It stores only two small entries in your browser:
- Your cookie choice (local storage,
pl-consent-v1), so the notice does not appear on every page. It contains only that choice. Legal basis: strictly necessary storage to remember the choice you made (the exemption for strictly necessary storage under the ePrivacy rules and, in the UK, the Privacy and Electronic Communications Regulations), and Article 6(1)(f) GDPR. - Campaign parameters (session storage,
pl-src-v1), such as utm_source or a click_id, if you arrived from an advertisement. They are kept only for the visit and sent with a newsletter sign-up, so we can see which advertisement led to the sign-up. Legal basis: Article 6(1)(f) GDPR.
Details are on the cookies page, where you can also reset your choice.
5. Advertising measurement: the Outbrain pixel
This website is promoted through paid advertisements on other websites, for example in recommendation areas run by advertising networks. These networks usually provide a measurement tag that records whether a visit came from an advertisement.
Outbrain pixel. The Outbrain measurement pixel is active on this website. Outbrain is the advertising network we use to promote the site. The pixel loads on content pages: the home page, the articles, the four section pages (State Pension & benefits, Tax, Savings, Home & health), the About us page and the newsletter page. It loads as soon as the page opens, which means before you make any choice in the cookie notice. It never loads on this page, the imprint, the cookies page, the terms of use, the contact page, the newsletter confirmation (thank-you) page or the error (404) page.
The pixel tells Outbrain that a page was viewed. In doing so Outbrain receives technical data such as your IP address, the address of the page, the referring page, browser and device information, the time of the visit and any Outbrain cookie identifiers. We use this to measure which advertisements bring readers to the site and to manage our campaigns. We receive only aggregated reports from Outbrain, nothing that identifies you personally. Outbrain may process data outside the UK and the European Economic Area; its safeguards, and how to opt out of personalised advertising, are described in Outbrain’s privacy policy.
The legal basis is our legitimate interest in measuring the performance of our advertising (Article 6(1)(f) GDPR). You can object at any time by emailing privacy@weareapacc.com and through Outbrain’s opt-out. You can also stop the pixel with your browser settings or a content blocker; every article stays fully readable.
6. Newsletter
For the Thursday Briefing we process your email address, the time of your sign-up and confirmation and, where applicable, the campaign parameters described in section 4. The legal basis is your consent (Article 6(1)(a) GDPR), which you give with the tick box.
Sign-up uses a double opt-in: after you submit the form, you receive an email with a confirmation link, and your address is used for sending only after you click it. Unconfirmed sign-ups are deleted. You can withdraw your consent at any time through the unsubscribe link in every issue or by emailing privacy@weareapacc.com. After that we delete your address, apart from a minimal record of the unsubscribe so that we do not email you again. An email delivery provider may be used as our processor. We do not sell, rent or share your email address with other companies.
7. Contacting us by email or telephone
If you write or call, we use the details you give us to answer your enquiry (Article 6(1)(b) or (f) GDPR) and delete them when they are no longer needed for that. Please do not send us your National Insurance number, bank details, award letters or health information. For your own case, the responsible official bodies, such as the Pension Service or HMRC, are the right contact.
8. Links to other websites
Articles link to official websites such as gov.uk, nhs.uk or moneyhelper.org.uk. You leave this website only when you click such a link; the operator of that website is then responsible for any processing there.
9. Your rights
Under the GDPR you have the right of access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20) and to object to processing based on legitimate interests (Article 21). Where we rely on consent, you can withdraw it at any time with effect for the future. To use any of these rights, write to privacy@weareapacc.com. We reply within one month.
10. Complaints
You are welcome to contact us first. You also have the right to complain to a supervisory authority.
Lead authority in the EU: the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia, www.aki.ee
For readers in the United Kingdom: the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, ico.org.uk
11. No automated decision-making
We make no automated decisions within the meaning of Article 22 GDPR and do not create profiles ourselves. How Outbrain uses the data it receives through the pixel for advertising is governed by Outbrain’s privacy policy (see section 5).
12. Governing law and changes
This notice and our processing are governed by Estonian law, without depriving you of the mandatory protections of the law of the country where you live. If we change what we process or why, for example by activating another measurement tag, we will update this notice beforehand and change the date below.