Relationship Science
PRIVACY POLICY
Last Updated: 11/2/2021
This privacy policy explains how Relationship Science ("RelSci," "we", "our" and "us"), collects, uses, shares and protects information obtained from visitors to www.relationshipscience.com or www.relsci.comwebsite (the "Site") and RelSci Pro and RelSci Lite subscribers.
This Privacy Policy, together with the Master Subscription Agreement (“MSA”) constitute a single agreement between you and us (the "Agreement"). Please read this Privacy Policy carefully. By visiting the Site and providing information to us you consent to our collection, processing, storage, sharing and use of your information consistent with the terms of this Privacy Policy and to all terms and conditions contained in the MSA. If you do not agree to be bound by these terms, your only choice is not to use our Site.
NOTICE TO EU DATA SUBJECTS (INCLUDING VISITORS TO THE SITE FROM THE EU AND INDIVIDUALS FROM THE EU WHOSE DATA WE USE TO PROVIDE THE SERVICES): Please read this Privacy Policy and accompanying MSA carefully and click here for further information about your privacy rights.
Personal Information and Other Data We Collect
We consider all information that can be used to identify a specific individual, such as name, mailing address, email address and telephone number, to be personally identifiable information ("PII" or "personal information").
RelSci collects several types of information about or relating to you, including:
- Information that you voluntarily provide to us, including personal information, such as when you create an account on the Site, including your name and contact details, email address, and phone number
- Information about your social and business connections (collectively, "Contacts") that you choose affirmatively, or enable us to, upload to the Site, including the Client Data (as such term is defined in the MSA). We collect information about your Contacts when you directly input it to the Site, and also when you synchronize non-Site content, such as your electronic address book (e.g., your contact information stored on an email server, on your computer or mobile phone) with your account on the Site
- Information about you and your Contacts that we obtain from third parties, such as data aggregators, public sources, and advertising networks, which we may combine with the information received about you and your Contacts through our Site
- Information about you and your visits to our Site, but which does not specifically identify you, such as the pages you view, search terms you enter, and other actions you take in connection with the Site. We may also collect certain information from the browser, server, computer or other device you used to come to our Site, such as your Internet Protocol (IP) address, browser type and language, the operating system on your computer or device, the device identifier for your mobile device, the time you accessed our Site, what country or general geographic area you are located in, the Uniform Resource Locator (URL) of the website that referred you to our Site and to which URL you browse away from our Site if you click on a link on our Site. We will collect this information regardless of whether you subscribe to any of our Services (as defined in the MSA) or only visit the Site for informational purposes. This information may be collected automatically when you navigate our Site. While this information does not in and of itself identify you, we may maintain it or associate it with personal information that we collect in other ways or receive from third parties. Doing this helps us improve our Site and to deliver a better and more personalized service to you, including enabling us to store information about your preferences, allowing us to customize our Site according to your individual interests, speed up your searches, and recognize you when you return to our Site. Additionally, persons to whom we make such non-identifying information available as described in this Privacy Policy may be able to aggregate such data with other data available to them and thus be able to identify you.
You may provide us your information when you register to use our Site, when you subscribe to receive our Services, when you create a user account, when you use one of our online tools, when you carry out a transaction on our Site (such as making a payment), or when you report a problem with our Site. You understand that by creating an account, uploading information to our Site, or interacting with us in any of these ways, we and other users of the Site or our Services will be able to identify you.
Cookies
When you visit the Site, whether or not you are a subscriber, we may send one or more "cookies" (small data files) to your browser to uniquely identify you, let us help you log in faster and enhance your navigation through the Site. A cookie may convey anonymous information about how you browse the Site to us, but does not collect personal information about you unless you are a subscriber to one of our Services, in which case your name may be included in the cookie to facilitate faster access to the Site.
We may use both persistent and session cookies. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Site. Most persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears or becomes inactive after you close your browser.
You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, keep in mind that some features of the Site may not function properly if the ability to accept cookies is disabled.
Do Not Track
We will attempt to respect your wishes when you set your browser to "do not track" (a setting that your Internet browser may make available to you, which allows you to choose not to have your online behavior tracked). However, we cannot guarantee that in all instances your information will not be tracked by our Site or by a third party performing services for us (such as Google Analytics).
Log Files
Log file information is automatically reported by your browser each time you access a web page. When you use the Site, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, IP address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
Children
Minors (those under the age of 18) may not use the Site. We do not knowingly collect personal information from anyone under the age of 16, and no part of the Site is designed to attract anyone under the age of 18. Because we do not intentionally collect any information from children under the age of 18, we also do not knowingly share or disclose such information to third parties. If you have reason to believe that a child under 18 years of age has provided us with personal information, please contact us at PIPrivacy@euromoneyplc.comand we will take appropriate action under applicable law.
How We Use Your Information
We may use your personal and non-personal information, information about your Contacts (whether PII or not), and other content and information you provide to us or that we acquire from data aggregators, ad networks, public sources and other third parties (collectively, your "information" as used in this Privacy Policy) in the following ways:
- to present our Site and its contents to you;
- to provide you with information, products or services that you request from us;
- to notify you of opportunities, developments or offers available through RelSci, its affiliates, or business partners;
- to provide personalized content and services on the Site and on other RelSci websites;
- to aggregate your information with information provided by others;
- to identify potential clients;
- to understand what our target market is and determine where and how to advertise our services to others;
- to customize, analyze, and improve our products, services (including the content on the Site), technologies, communications and relationship with you;
- to customize your experience on our Site;
- to notify you about new tools and features on the Site;
- to notify you about changes to our Site, to the MSA, or this Privacy Policy;
- to respond to your inquiries and requests for Services or assistance;
- to allow you to participate in interactive features available on our Site;
- to track content and users as necessary to comply with applicable law;
- for our own research and development purposes and for the improvement of our Services;
- to provide you a better, more intuitive experience on our Site ;
- to provide employment opportunities and employee benefits; or
- otherwise, as you may consent or we may notify you at the time of collection.
You agree that information you provide to us and that you upload to our Site may be visible to third parties and may be used by us to provide our Services. By providing your personal information on the Site, you are expressly and voluntarily accepting our MSA and this Privacy Policy, consenting to our use of such information in our business, and to our storing, using, processing and transmitting of your personal information in the ways set out in this Privacy Policy.
Use of your Information by Third Parties
We share your information, as you provided it to us, or aggregated with data we collect from others or with third party data, across our different services among all of our affiliated companies (meaning entities controlled by us, controlling us, or under common control with us). Any information you post or upload to our Site, and any content you provide to us, may be seen by others. We may also share this information with third parties, whether as part of our Services or in connection with other transactions in which we may engage. You specifically consent to this sharing.
We make certain third party tools and services available, such as software widgets, tools or applications, which allow you to synchronize your desktop and/or mobile device’s calendar, email or contacts residing on third party applications with our Services. Your use of these tools means that you have granted permission to us and to the applicable third parties to access your information and information about your Contacts. We and these third parties may also be able to access your email, calendar and other accounts, and we and they may collect and store some or all of this information for our/their own purposes.
How We Communicate with You
We may communicate with you through e-mail, notices posted on the Site, and messages sent to you through the Services. Examples of these communications include: (1) welcome and engagement communications informing you about how to best use our Services, new features, etc.; (2) service communications, such as messages to inform you of service unavailability, security, and other issues about our Services; and (3) promotional communications, which may contain promotional information about our Services, or those coming directly or on behalf of our partners.
We may also send you surveys or polls, requesting your feedback regarding our Services. Your responses are appreciated, and help us improve the quality of our Services.
Disclosure of Your Information
We may disclose and share with third parties and our affiliates aggregated information about our users, and other non-personal information, without restriction.
We may share any personal information obtained from you or as a result of your activities on our Site, and information about you and your Contacts which we collected through third party sources:
- with third parties, including our affiliates, and with our contractors, service providers and other parties we use to support our business (e.g., website hosting providers, credit card processors and processing banks, CRM and marketing service providers, server hosting providers, etc.). These third party service providers ("Providers") perform functions on our behalf, like sending out and distributing our administrative and promotional emails. We may share your information with such Providers to remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit card payments, operate the website, troubleshoot, and provide customer service
- with a buyer or successor to our business in the event of a merger, divestiture, restructuring, reorganization, or other sale or transfer of some or all of our assets or voting securities, whether as a going concern, or in bankruptcy, liquidation, or similar proceeding, in which information held by us is among the assets to be transferred
- With third parties for the purpose of offering our products and services
- If required to do so by law or by court order
- If we believe that it is reasonably necessary to comply with a law, regulation or legal request
- To protect the safety of any person
- To address fraud, security or technical issues
- To protect our rights or property
We may also share or disclose your information with your consent, such as if you choose to sign on to the Site through a third-party service, or using credentials from a third party website, such as Facebook. Please note however, that we are not responsible for the privacy practices of third party websites (even if we offered links to third party websites on the Site) and those third parties are under no obligation to comply with this Privacy Policy. Before visiting another website and before providing any information to the party that operates or advertises on that third party website, users should review the privacy policy and practices of that website to determine how information that they collect from users will be handled.
Where Your Information Will be Stored
Your information will be held, by us or our service providers, in the United States. If your information is gathered outside the United States, it may be transferred to RelSci's United States offices to be used consistent with the terms of this Privacy Policy, and it may be transferred to and shared with any of RelSci's worldwide locations. You may request a full list of all subsidiaries and affiliates of RelSci by contacting us at PIPrivacy@euromoneyplc.com.
Your use of the Site from outside the United States of America is at your own risk. We cannot and do not guarantee that our business operations, infrastructure or security measures comply with any laws in your country of origin or residence. You specifically consent to the application of United States law in all matters concerning the Site, your use of it, and our collection, use, sharing and processing of your personal information and all Client Data.
IN USING OUR SERVICES, YOU REPRESENT, WARRANT AND AGREE THAT YOU HAVE THE RIGHT TO, AND THE CONSENT OF ALL APPLICABLE THIRD PARTIES, TO PROVIDE ALL CLIENT DATA, INCLUDING THE PERSONAL INFORMATION OF YOUR CONTACTS (INCLUDING THOSE LOCATED OUTSIDE THE UNITED STATES OF AMERICA) TO RELATIONSHIP SCIENCE. YOU AGREE TO DEFEND AND INDEMNIFY RELATIONSHIP SCIENCE AND ITS AFFILIATES AND THEIR RESPECTIVE DIRECTORS, EMPLOYEES, SHAREHOLDERS, MEMBERS, MANAGERS, AGENTS AND REPRESETNATIVES FORM AND AGAINST ALL CLAIMS, LOSSES, DAMAGES, SUITS OR PROCEEDINGS THAT MAY ARISE AS A RESULT OF YOUR BREACH OF THE FOREGOING WARRANTY.
How We Protect Your Information
RelSci uses commercially reasonable physical, administrative, and technical safeguards in an attempt to preserve the integrity and security of your information. Unfortunately, the transmission of information via the internet is not completely secure, and we can therefore not guarantee the security of your information transmitted to or through our Site. Any transmission of information is at your own risk.
In the event that PII is compromised as a result of a breach of security, we will promptly notify those persons located in the United States of America whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.
We will make reasonable efforts to notify subscribers in other countries (except as otherwise set forth in this Privacy Policy or as required by laws we are subject to, such as the GDPR) if there has been a breach of security involving their personal information, but cannot guarantee that such notifications will be made in compliance with applicable local foreign laws or that they will be timely.
Your Choices About Your Information
You may, of course, decline to submit your personal information or that of your Contacts through the Site, in which case RelSci may not be able to provide certain Services to you.
You may update or correct your account information and email preferences at any time by logging in to your account on the Site.
You may cancel your account at any time, consistent with the MSA. Note, however, that if you cancel your account on the Site, we will retain all information you have already provided, and may continue to use such information consistent with the terms of this Privacy Policy.
Links
The Site may contain links to websites that Relationship Science does not operate. Please make sure when you leave the Site that you have read all privacy policies, MSA and other governing documents applicable to such third party websites that you visit, as this Privacy Policy applies solely to information collected by our Site to any other website to which it is posted.
Relationship Science is not responsible for and does not monitor the content of third party websites, and you should direct any concerns regarding those websites to their respective site administrators or webmasters.
Changes to This Policy
We may make changes to our Services over time, and in the future may make new or different tools available to synchronize information with our Services that are not available today. Such improvements in our service may involve collection of new data about you or your Contacts. Furthermore, we may enter into partnerships with new third parties, and in doing so, such additional third parties may be allowed access to your information. If we start collecting substantially new types of information or using or sharing it in materially different ways, we will update this Privacy Policy. Please be sure to review this Privacy Policy often, as we may amend this policy as such service offerings expand.
RelSci may update this policy in its discretion from time to time. Any changes to this Privacy Policy in the future will be posted to the Site. Your continued use of our Site after the revised terms are posted will indicate your consent to the amended terms of this Privacy Policy and our MSA. If you do not agree with any amendments to the MSA or this Privacy Policy, please stop using the Site and notify us immediately at PIPrivacy@euromoneyplc.com.
Contact
All comments, queries and requests relating to our use of your information are welcomed and should be addressed to the following e-mail address: PIPrivacy@euromoneyplc.com or to Legal Department, 5 Pennsylvania Plaza, 15th Floor, New York, NY 10001.
CALIFORNIA SPECIFIC NOTICES
This section of the Privacy Policy applies solely to California residents.
We adopt this Section of the Privacy Policy in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Certain terms used in this Section of the Privacy Policy are defined in, and shall have the meanings ascribed to them in the CCPA.
Note that the term Personal Information, as used in this California Specific Section of the Privacy Policy uses the term as it is defined in the CCPA, and not as defined in the main body of this Policy.
California Residents
California Civil Code Section § 1798.83, known as the “Shine The Light” law, permits users of our Site who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding year, and the names and addresses of those third parties. You may request this information from us no more than once a year, but such request will be handled by us free of charge to you. To make such a request, please send an email to PIPrivacy@euromoneyplc.com.
Do Not Track
Please see DNT disclosure set forth in main body of this Privacy Policy.
Data Collection
RelSci has collected the following categories of Personal Information within the last twelve (12) months:
Category of Personal Information[1] |
Categories of Sources of Collection |
Business or Commercial Purpose for Collection |
A. Identifiers. |
Publicly available information Third-party data vendors User requests for profile updates Provided by clients Collected from RelSci platform activity Provided by business partners Provided by employees Provided by website users |
To provide our products and services To improve our products and services To identify potential clients To produce analysis and reporting about people and companies (ex: "Most Connected Lawyers" list) To market our products and services |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
Publicly available information Third-party data vendors User requests for profile updates Provided by clients Collected from platform activity Provided by business partners Provided by employees Provided by website users |
To provide our products and services to clients To improve our products and services To identify potential clients To produce analysis and reporting about people and companies (ex: "Most Connected Lawyers" list) To market our products and services |
C. Protected classification characteristics under California or federal law. |
Publicly available information Third-party data vendors User requests for profile updates Provided by employees |
To provide our products and services to clients To improve our products and services To produce analysis and reporting about people and companies (ex: "Most Connected Lawyers" list) To offer employment, to provide insurance and benefits, for background checks |
D. Commercial information. |
Provided by clients Internal Records |
To provide our products and services To maintain business relationship with partners |
E. Biometric information. |
None |
None |
F. Internet or other similar network activity. |
Activity on platform by clients, site users and employees |
To provide our products and services To market our products and services To improve our products and services (e.g., usage pattern data) To track employee actions for internal reports and information security purposes |
G. Geolocation data. |
None |
None |
H. Sensory data. |
None |
None |
I. Professional or employment-related information. |
Provided by clients Publicly available information Third-party data vendors Business partners User requests for profile updates Job applicants Employees |
To provide our products and services To market our products and services To improve our products and services To produce analysis about people and companies To provide employment opportunities and employee benefits |
J. Inferences drawn from other personal information. |
Provided by website users |
To provide our products and services To market our products and services To improve our products and services For research and development |
RelSci does not knowingly collect any Personal Information of persons under the age of 16.
California Consumer Rights Pursuant to the CCPA
California consumers have specific rights regarding how your Personal Information is collected and used.
- You have the right to request that RelSci disclose to you or your authorized agent acting on your behalf the following information covering the past 12 months:
- Specific pieces of Personal Information that we have collected;
- Categories of Personal Information collected;
- Categories of sources from which Personal Information is collected;
- Categories of Personal Information sold or disclosed for a business purpose.
- Categories of third parties to whom we sold or disclosed the Personal Information for a business purpose;
- Our business purpose for collecting (or selling) Personal Information;
- You have the right to request deletion of your Personal Information (with exceptions noted by law – more on this below);
- You have the right to request that your Personal Information not be sold to third parties; and
- You have the right not to be discriminated against because you exercised these rights.
Data Deletion
As permitted by the CCPA, in the event you request deletion of Personal Information that we have collected about you, RelSci may be unable to comply with such a request if your Personal Information is necessary to:
- Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between RelSci and you;
- Detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another Consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with a legal obligation; or
- Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Specifically, we will not do any of the following unless permitted by the CCPA:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Do Not Sell My Personal Information
RelSci sells Personal Information, as the term “sale” is defined pursuant to the CCPA.
As a California consumer, you have the right to opt out of the sale of your Personal Information to third parties.
In the 12 months prior to the posting of this Policy, we have sold to third parties the categories of Personal Information about California residents set forth below:
Categories of Personal Information Sold |
Categories of Third Party to Which Personal Information Was Sold |
|
|
In the 12 months prior to the posting of this Policy, we have disclosed for a business purpose the categories of Personal Information about California residents set forth below:
Category of Personal Information Disclosed for a Business Purpose |
Category of Persons to Whom Personal Information Was Disclosed |
|
|
How to Exercise Your CCPA Rights
You can exercise all of your rights granted to you pursuant to the CCPA by clicking here or contacting us at 1-888-800-7955 or PIPrivacy@euromoneyplc.com.
California law requires us to verify your identity before processing your request. In order make a request pursuant to the CCPA, you must provide us with your first and last name, email address (preferably from a corporate email address that you think we have on file for you), and information about at least two (2) affiliations you have (this may include employers, board positions, education history, and awards received, among others). If you are requesting specific pieces of Personal Information that we have collected about you, you will also be required to email us at PIPrivacy@euromoneyplc.com a signed declaration under penalty of perjury that you are a California resident and that you are the consumer whose Personal Information is the subject of the request. Note that we will not process your request to disclose specific pieces of information we have about you until we receive this signed declaration, and your request will not be considered timely submitted until we have this document in our possession.
We will review the information you have provided against the information in our databases, and attempt to verify your identity. However, please note that under certain circumstances, we may require you to provide additional information in order to allow us to confirm your identity and your residency before we can process your requests. Also note that you are only entitled to make a Personal Information request up to twice in a 12-month period.
If (or when) you submit your CCPA request by email, please include “California Privacy Rights” as the subject line. If you make a request to exercise your rights under the CCPA by telephone, we may ask you to provide the request in writing so that we may verify your identity.
We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time or information to verify your identity (and if so, why).
Using an Authorized Agent
A California resident may use an authorized agent to submit a right to know request, a request to delete, or a request to opt-out of the sale of personal information here. To use an authorized agent for these purposes, the agent will be required to verify their identity with us. For this purpose, the agent will be required to submit a request with their first and last name and email address, and will be required to provide via email written authorization from the consumer to act on their behalf in making these requests. If we cannot authenticate the identity of the agent making the request, we may also require that the consumer confirm directly with us that they have in fact authorized their agent to act on their behalf. We may deny a request from an agent who cannot meet these requirements. If the agent has provided a power of attorney pursuant to Cal. Prob. Code Sections 4121 to 4130, then the verification that the consumer has authorized the agent to act on their behalf will not be necessary.
NOTICE TO EU DATA SUBJECTS (INCLUDING VISITORS TO THE SITE FROM THE EU AND INDIVIDUALS FROM THE EU WHOSE DATA WE USE TO PROVIDE THE SERVICES):
In addition to reading the Privacy Policy and accompanying MSA carefully, please note the further information below about your privacy rights.
Who we are
The Site and our Services are operated by Relationship Science LLC of 5 Pennsylvania Plaza, 15th Floor, New York, NY 10001.
The data controller responsible for your personal information processed via the Site or in relation to the Services is Relationship Science LLC.
If you have any questions about this privacy policy or want to exercise any data subject rights you may have in relation to the Site and/or the Services (as explained below), please contact us by sending an email to PIPrivacy@euromoneyplc.com or contacting us at the Legal Department, 5 Pennsylvania Plaza, 15th Floor, New York, NY 10001, USA.
Location of data and processing
Your personal information will be held, by us or our service providers, in the United States. We provide the Services to you from the United States and use our subsidiary in India to process personal information as part of the provision of the Services. You may request a full list of all subsidiaries and affiliates of ours by contacting us at PIPrivacy@euromoneyplc.com.
Legal basis of processing
Our processing of your personal information may be necessary for the performance of a contract with you or to take steps at your request to enter into a contract.
Our processing of your personal information may be necessary for complying with our legal obligations.
Our processing of your personal information may be necessary for our legitimate interests or those of a third party. This includes the purposes set out in the bullet points in this Privacy Policy under the heading "How We Use Your Information" except where, for example, we do so pursuant to a legal obligation or the performance of a contract with you.
Our processing of your personal information might take place on the basis of your consent, given at the time and point of collection on the Site, for one or more specific purposes.
How long do we keep your personal information
We will keep your personal information in accordance with our retention policies and applicable law but we will not keep it for longer than is necessary. Where we have a business relationship with you and unless otherwise agreed we will keep your personal information for the duration of that business relationship with you and for a certain period afterwards. Where we do not have a business relationship with you, for example, where you are a visitor to the Site or use our consumer website at www.relationshipscience.com, we will retain your personal information for our legitimate business interests for at least 38 months subject to you exercising any data subject rights as described below. In considering how long to keep your personal information, we take into account the nature of the information, the nature of the relationship with you, the relevance to our business of the information, and our obligations to comply with applicable laws and regulations.
Confidentiality and security
We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from: unauthorized access; improper use or disclosure; unauthorized modification; and unlawful destruction or accidental loss.
All of our employees, workers and data processors (i.e. those who process your personal data on our behalf), who have access to, and are associated with, the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Site and all users of our Services.
Data subject rights
You have the following rights in relation to the personal information we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make.
Your right of access
If you ask us, we will confirm whether we are processing your personal information and, subject to any applicable exemptions, provide you with a copy of that personal information (along with certain other details) within the timescales or extended timescales provided for by the EU General Data Protection Regulation for complex requests, or where applicable, provide you with an explanation as to why we will not be complying with your request. If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you are entitled to rectification and if we have shared your personal information with others, we will let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your personal information). If you are entitled to erasure and if we have shared your personal information with others, we will take reasonable steps to inform those others where possible and where this would not involve disproportionate effort. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.
Your right to data portability
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or processing your personal information for direct marketing.
Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to your local supervisory authority (data regulator).
A list of contact details for all EU supervisory authorities can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
For Individuals Who Are In People's Republic of China
Euromoney also complies with specific requirements stipulated by PIPL (“Personal Information Protection Law of the People's Republic of China”) and other relevant Chinese rules and regulations.
- Our Legal Basis for Processing the Personal Information
Euromoney will process your personal information in accordance with the principles of legality, legitimacy, necessity, and good faith. We will obtain your consent before processing your personal information. Especially, when we want to process your sensitive personal information, we will obtain your separate consent or your written consent according to laws and administrative regulations.
If we process your personal information beyond the content in this Privacy Notice, we will separately explain the purpose, method, and scope of such processing to you through page tips, interactive processes, website announcements, etc., and obtain your consent again.
When it comes to the following purposes of using your personal information as mentioned above in “WHAT PERSONAL DATA WE COLLECT & WHY”, we will request your consent. You will always be free not to respond. You could easily withdraw the consent at any time.
- Advertising & Marketing
You’re fully aware that Euromoney may process your personal information outside the need to obtain the authority and consent from you, under any of the following circumstances:
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- where it is necessary for the conclusion or performance of a contract to which you are a party, or for the implementation of human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with the law;
- where it is necessary for the performance of statutory duties or statutory obligations;
- where it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person;
- where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of personal information is within a reasonable scope;
- where it is necessary to process the personal information disclosed by you or other personal information that has been legally disclosed within a reasonable scope in accordance with the provisions of this Law; and
- other circumstances prescribed by laws and administrative regulations.
- How We Share Your Information
Euromoney will not share your personal information with a third party unless we obtain your separate consent or in circumstances where your consent is not required according to laws and regulations.
We may share your name, job title, company, address, telephone number and email with event sponsors. Due to the event sponsors will differ from time to time, we will inform you of the name and contact information of the sponsors, purpose and method of processing and obtain your separate consent before sharing your personal information.
Where Euromoney needs to transfer your personal information due to merger, division, dissolution or declaration of bankruptcy, etc., we will notify you of the name and contact information of the recipient, as well as urge the recipient to continue to process your personal information based on this Privacy Notice. Otherwise, Euromoney will request the recipient to obtain your consent again before processing.
- Storage Location and International Transfers
Your personal information will be stored in the UK. Therefore, Euromoney Institutional Investor PLC (https://www.euromoneyplc.com/), who is running the information system , will receive your personal information (name, job title, company, address, telephone number and email).
We may also share your personal information with Euromoney Group companies, for them to send you marketing materials.
We will take necessary measures required by laws including obtaining your separate consent, concluding standard contractual clauses with the overseas recipient to stipulate the rights and obligations between us, and will ensure that the foreign receiving party provides adequate protection for your personal information under applicable laws.
You could contact us or the overseas recipient to exercise personal information rights through the contact information listed in this Privacy Notice.
- Your Additional Privacy Rights
Under the stipulations of PIPL, you have the following rights.
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- Right to be informed
You have the right to know the processing of your personal information.
In addition, you have the right to ask us to explain this Privacy Notice and the rules governing Euromoney’s processing of personal information.
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- Right to access and copy
You can request access to your personal information or obtain a copy of your personal information.
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- Right to correct and supplement
You can request Euromoney to make corrections or supplements where you find that your personal information is inaccurate or incomplete.
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- Right to delete
You can request the deletion of your personal information in certain circumstances (for example while you withdraw your consent, or the purpose of personal information processing has been achieved, it is impossible to achieve such purpose, or it is no longer necessary to achieve such purpose;)
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- Right to transfer
You can transfer your personal information to a personal information processor designated by you when it meets the conditions stipulated by the authorities.
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- Right to make decisions, restrict and refuse
You can make decisions on the processing of your personal information and restrict or refuse Euromoney to process your personal information.
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- Right to withdraw your consent
You can withdraw your consent. Please understand that each service needs some basic personal information to be completed. After you withdraw your consent, Euromoney will not process the relevant personal information, and cannot provide you with the corresponding services as a result. However, withdrawal of consent by you will not affect the previous personal information processing based on your authorization.
For security, Euromoney may verify your identity before handling your request. After verifying your identity, we will respond to your request in time, and give a reply and reasonable explanation within 15 days after verifying your identity, or inform you of the external ways to solve the dispute.
We will not be able to respond to your request under the following circumstances:
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- Related to our compliance with the obligations under the laws and regulations;
- Directly related to national security or defense security;
- Directly related to public security, public health or major public interests;
- Directly related to criminal investigations, prosecutions, trials and enforcement of court decisions, etc.;
- We have sufficient proof that you have subjective malice or abuse of rights;
- For the purpose of safeguarding your life, property and other important legal rights and interests or those of other individuals but it is difficult to obtain consent;
- Responding to your request will cause serious harm to your legitimate rights and interests, or those of other individuals or organizations.
- Involving trade secrets.
- How to Contact Us
If you have any questions or concerns regarding this Privacy Notice and the processing of your personal information, you can send your questions to dataprotectionofficer@euromoneyplc.com or to the following address: Euromoney Institutional Investor PLC, 12/F, V-Point, 18 Tang Lung Street, Causeway Bay, Hong Kong.
Protecting Your Data
Euromoney endeavours to keep your personal data secure and takes appropriate technical and organisational measures to protect your personal data from loss, unauthorised use, disclosure or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk.
All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.
[1] Pursuant to Cal. Civ. Code Section 1798.130(a)(5)(B).