Who is the data controller for Culture Observer?
Sliema Media Limited, a private company registered in Malta (Malta Business Registry number C 84217), is the data controller responsible for your personal data when you interact with Culture Observer. Our registered office is Level 3, Tower Business Centre, Tower Street, Swatar, Birkirkara BKR 4013, Malta.
Although the operating company is based in Malta, Culture Observer is a digital entertainment publication focused on UK audiences. We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 in respect of all personal data we collect from readers, subscribers, tipsters and other individuals in the United Kingdom. Our main phone number is +356 2779 4100 and our UK editorial line is +44 20 4587 9485. You can read more about our ownership and funding on our Ownership & Funding page.
What personal data do we collect?
We collect personal data that you provide directly (such as your email address when subscribing to our newsletter) and data generated by your visits (such as technical and analytics information, and advertising and affiliate tracking cookies). Full details of cookie-related data are set out in our Cookie Policy.
Specifically, the categories of personal data we may collect include:
- Correspondence data – your name and email address when you contact us via editorial, tips, press, complaints, corrections or other function emails.
- Newsletter subscription data – email address, subscription preferences and engagement metrics (e.g., open rates, click-through rates).
- Technical and analytics data – IP address, browser type and version, operating system, referring URLs, page views and session duration, collected through Google Analytics and similar services.
- Advertising and affiliate tracking data – cookies and similar technologies used to serve relevant advertisements and track affiliate purchases. This is covered in our Cookie Policy.
- Tip and source data – information you provide when submitting a tip or confidential material via our Tip Us page. We take additional steps to protect source confidentiality (see below).
We do not collect special category data (e.g., racial or ethnic origin, political opinions, health data) unless you voluntarily provide it in correspondence, in which case we will process it only with your explicit consent.
How do we use your data and what is our legal basis?
We use your personal data for specified, explicit and legitimate purposes: to operate and improve the Culture Observer website, to send newsletters you have subscribed to, to respond to your enquiries and tip-offs, and to enable advertising and affiliate revenue. Each processing activity is supported by a lawful basis under UK GDPR.
The table below summarises the main purposes and corresponding lawful bases:
- Newsletter delivery – consent (you opt in via the subscription form; you may withdraw at any time).
- Responding to correspondence (editorial, complaints, corrections, tips) – legitimate interest (to manage reader communications and fulfil our editorial function).
- Technical analytics (Google Analytics) – consent (via cookie banner; you can manage preferences).
- Advertising and affiliate cookies – consent (as required by ePrivacy regulations).
- Source confidentiality and tip handling – legitimate interest (to protect whistleblowers and maintain journalistic integrity) and legal obligation (if required by law).
- Legal compliance and safeguarding – legal obligation (e.g., maintaining records for regulatory compliance).
For more detail on our editorial and advertising practices, please see our Editorial Policy and our Advertising & Affiliate Disclosure.
How long do we keep your data?
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Email correspondence is retained for up to 24 months after the last communication. Newsletter subscriber data is retained until you unsubscribe or for 12 months of inactivity, after which it is deleted. Analytics data is anonymised after 26 months. Tip and source records are retained for up to seven years in a secure, access‑restricted environment to protect journalistic confidentiality.
When retention is no longer necessary, we delete or anonymise the data in accordance with our internal data retention schedule, which is reviewed annually.
Do we share or sell your personal data?
We never sell your personal data to third parties. We share data only with trusted processors who act on our instructions and are contractually bound to protect your data. These processors include email service providers (e.g., Mailchimp), analytics providers (e.g., Google), hosting infrastructure providers, and affiliate network partners. All processors are located in the UK, EEA or in jurisdictions with an adequacy decision, or are covered by Standard Contractual Clauses.
We may also disclose data if required by law, to enforce our Terms of Use, or to protect the rights, property or safety of Culture Observer, our readers or the public. We never share tip‑related data without explicit consent unless compelled by a court order, and we will challenge any such order to protect source confidentiality.
What are your rights under UK GDPR?
You have the right to access, rectify, erase, restrict processing of, and port your personal data, as well as the right to object to processing based on legitimate interests or direct marketing. You also have the right to withdraw consent at any time where processing is based on consent. These rights apply regardless of where you live, as long as we process your data in connection with UK activities.
Specifically, you may:
- Request a copy of the personal data we hold about you.
- Ask us to correct inaccurate or incomplete data.
- Request deletion of your data where it is no longer necessary or where you withdraw consent.
- Object to processing for direct marketing (including newsletter profiling) or for legitimate interests.
- Request transfer of your data to another controller in a structured, commonly used format.
We will respond to all valid requests within one month (extendable by two months for complex or multiple requests). There is no charge for exercising your rights unless the request is manifestly unfounded or excessive.
How can you exercise your rights or contact us?
To exercise any of your data protection rights, or if you have any questions about this Privacy Policy, please email our Data Protection Officer at privacy@cultureobserver.uk. You may also write to us at the registered office address above, marking the envelope “Data Protection Enquiry.” For complaints regarding editorial content, see our Complaints Procedure.
If you wish to submit a tip or confidential information, please use our Tip Us page. We treat all tip-related data with the highest level of confidentiality. We will never voluntarily disclose a source’s identity or the content of a tip without the source’s express permission, and we will resist any legal attempt to compel such disclosure.
If you are not satisfied with our response, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO). You can contact the ICO via their website at https://ico.org.uk/ or by telephone on 0303 123 1113. We encourage you to contact us first so that we can attempt to resolve the matter.
Our commitments
- We will never sell your personal data to third parties.
- We will always provide a clear, accessible means for you to access, rectify or delete your data.
- We will protect source and tipster confidentiality as a core journalistic principle, resisting disclosure unless legally compelled and after independent legal review.
- We will review and update this Privacy Policy at least annually and notify subscribers of any material changes.
- We will comply with UK GDPR and ICO guidance in all data processing activities related to UK readers and users.