Privacy Policy
1. Who we are
1.1 Controller: Bauer Media Outdoor International Limited, The Lantern, 75 Hampstead Road, London, NW1 2PL, United Kingdom.
1.2 This Privacy Notice explains how we process personal data through Bauer Media Group’s political advertising transparency website, hosted at http://www.bauermedia-ttpa.com.
1.3 In this Privacy Notice, “we”, “us” and “our” mean Bauer Media Outdoor International Limited. Although this website supports political advertising carried by Bauer Media Group entities in EU Member States, Bauer Media Outdoor International Limited operates the website and is responsible for collecting, publishing and retaining the transparency information processed through it.
2. Scope and what this site does
2.1 This site supports compliance with Regulation (EU) 2024/900 on the transparency and targeting of political advertising (the Political Advertising Regulation), which requires publishers of political advertisements to collect, publish and retain certain information relating to those advertisements.
2.2 It applies to political advertising carried by Bauer Media Group entities in EU Member States. However:
a) If a political advertising campaign runs only in Norway or the United Kingdom, the Political Advertising Regulation does not apply.
b) For political advertising campaigns in the Netherlands, the sector website www.politiekereclame.nl is used instead.
3. Data we collect and process
3.1 We collect the following information through the transparency submission form to comply with the Political Advertising Regulation:
a) Country where the campaign will run
b) Sponsor and funder details:
- full legal name of the sponsor,
- sponsor’s public contact email,
- whether the sponsor is a natural person or an organisation,
- who funded the advertisement (sponsor or other persons/organisations),
- total amount spent for this specific advertisement with Bauer Media Group (including any benefits in kind),
- type of funding (private, public or both),
- source of funding (within the EU, outside the EU, or both),
- explanation of the calculation methodology (e.g., invoiced, budgeted/estimated, VAT inclusion),
- where the sponsor is an individual, name and address may be collected; individuals may indicate that their address is not made public.
c) Advertisement details:
- advertisement name or identifier,
- description of the political actor/issue/objective promoted,
- website (URL) where the advert’s transparency notice will be published (note: this is optional and only relevant if the advertiser is linking to information on a website other than Bauer Media Group’s political advertising transparency website),
- start and end dates of the advertisement,
- whether the advertisement (or an earlier version) has previously been suspended or discontinued due to an infringement of the Political Advertising Regulation.
d) Use of data-driven or targeting techniques by the sponsor:
- whether personal data (or data derived from personal data) was used to influence where, when or how the advert was placed.
e) Submitter contact details (not published; used to administer submissions and seek clarification where necessary):
- name and email address of the person submitting the form.
- If required information is not provided, we cannot run the campaign.
4. Publication of transparency information
4.1 We make transparency information publicly available for the duration of the relevant political advertising campaign.
4.2 The information we make publicly available includes: sponsor identity and funding information, the amount spent on the advertisement, the subject matter of the advert, campaign dates, and whether personal data was used in planning.
4.3 We require, but do not publish, the personal contact details of the individual submitting the form.
5. Purposes and legal basis
5.1 We process the above information to:
- collect, publish and make available the transparency information during the campaign and retain it thereafter, as required by Articles 11 and 12 of the Political Advertising Regulation;
- retain the transparency notice (and any modifications) for seven years after the last publication of the advertisement (Article 12(4) of the Political Advertising Regulation);
- check that the required transparency information has been provided and seek clarification where necessary. We do not assess or approve the political message itself. Where information appears incomplete, inconsistent or incorrect, we may seek clarification or supporting information before publishing or continuing to display a political advertisement;
- refuse, delay or remove campaigns where required information is missing, unclear or inconsistent, or where there are legal or compliance concerns;
- respond to requests from competent national authorities (Article 16) and from eligible “interested entities” (Article 17 of the Political Advertising Regulation) during and after the campaign.
5.2 Our legal basis is Article 6(1)(c) GDPR (processing necessary for compliance with a legal obligation), namely our legal obligations under the Political Advertising Regulation. Where a sponsor is an individual, publication of their personal data forms part of those legal obligations under the Political Advertising Regulation.
6. Disclosures and recipients
6.1 Public access: during the campaign, transparency information is freely available on our website.
6.2 Competent authorities: we may disclose information to competent national authorities to verify compliance.
6.3 “Interested entities” (as defined in Article 17 of the Political Advertising Regulation): following the campaign, we may disclose transparency information on request to interested entities, including vetted researchers (within the meaning of the Digital Services Act), qualifying civil society organisations, political actors, recognised electoral observers and journalists.
6.4 Internal handling: submissions and requests from competent authorities are coordinated centrally and may be routed to the relevant market team.
7. Retention
- We retain the transparency notices (and any modifications) for seven years after the last publication of the advertisement, as required by Article 12 of the Political Advertising Regulation.
8. Where data comes from
- We obtain the data directly from the sponsor or an authorised representative via the submission form and related communications.
9. Accuracy of transparency information
9.1 Sponsors and their authorised representatives are responsible for the completeness and accuracy of the transparency information they provide. We review submissions for compliance with the Political Advertising Regulation but, except where required by law, do not independently verify the information provided. Publication does not imply that we have confirmed its accuracy.
9.2 Sponsors and their authorised representatives must tell us promptly if any transparency information changes or they become aware that it is inaccurate, so that we can update the transparency notice where appropriate. Inaccuracies may also be reported via the advertiser’s sales contact in the relevant market or by contacting us at compliance@bauermedia.com.
10. International data transfers
10.1 The website is hosted using Webflow, which stores customer and end-user data in the United States. The API used to process submissions made through the transparency submission form is hosted by Parallax Agency Ltd in Ireland.
10.2 Some of our service providers and subprocessors, including Webflow and Resend, may process personal data in, or permit access to personal data from, countries outside the European Economic Area (EEA), including the United States. Authorised support or administration personnel may also access personal data from outside the EEA where necessary to operate or support the website and its functionality.
10.3 Where personal data is transferred outside the EEA to a country that has not been recognised as providing an adequate level of protection, we use appropriate safeguards in accordance with applicable data protection law. These may include the EU-US Data Privacy Framework, the European Commission’s standard contractual clauses and equivalent UK transfer safeguards, where applicable. For transfers involving our service providers, these safeguards are incorporated into the applicable data processing agreements where required. Further information about the applicable safeguards may be requested using the contact details set out in this Notice.
11. Service providers
11.1 We use external service providers to operate and support the website and the transparency submission form. These include Webflow, which provides the website hosting platform; Parallax Agency Ltd, which provides and hosts the form API; AWS, which provides cloud hosting infrastructure for the form API; and Resend, which provides email delivery services.
11.2 Where these providers process personal data on our behalf, they act as processors and are required to process personal data only in accordance with our documented instructions, implement appropriate technical and organisational security measures, and comply with applicable data protection law. We enter into appropriate data processing agreements with such providers as required by applicable data protection law.
12. Your rights
12.1 Depending on applicable data protection law, you may have the following rights in relation to your personal data.
- Right of access to your personal data and related information (e.g., purposes, categories, recipients, retention).
- Right to rectification of inaccurate data.
- Right to erasure in the cases provided by law; note that where we must retain data to comply with a legal obligation, erasure may not be available during that period (Article 17(3)(b) GDPR).
- Right to restriction of processing in the cases provided by law.
- Right to lodge a complaint with a supervisory authority.
- Right to object: this applies only where processing is based on Article 6(1)(e) or (f) GDPR. As our processing is based on Article 6(1)(c) GDPR (compliance with a legal obligation), this right will not generally apply.
13. Data Protection Officer
You can contact our Group Data Protection Officer at DataProtection@bauermedia.com.
14. Updates to this Notice
We may update this Notice from time to time to reflect legal or operational changes.