Euromoney Institutional Investor PLC - Privacy Notice
INTRODUCTION – WHO WE ARE
Euromoney Institutional Investor PLC is a global information business providing essential B2B information to global and specialist markets.
Euromoney and its group companies are committed to respecting the privacy of every person who visits, registers with or subscribes to our websites, publications, events and other products or services, or about whom we otherwise collect personal data.
Euromoney Institutional Investor PLC is the data controller of personal data collected through this website (www.euromoneyplc.com). If you are a customer or user of another Euromoney group website or service, then the Euromoney group company which operates that website or service will be the data controller of personal data collected through that website or service. Therefore it is possible that more than one Euromoney group company will be a controller of your personal data. You may contact any of these companies directly, or you can contact Euromoney by emailing email@example.com or writing to the Data Protection Officer at Euromoney Institutional Investor PLC, 8 Bouverie Street, London EC4Y 8AX, United Kingdom or using the contact details set out in the “Who We Are” section of this Privacy Notice.
References in this Privacy Notice to “Euromoney”, “we”, “us” or “our” refer to the Euromoney group company or companies which are data controllers in respect of your personal data. For a full list of our brands and group companies, please click on this link.
This Privacy Notice was updated on 1 November 2021.
OUR APPROACH TO YOUR PRIVACY
This Privacy Notice outlines the information we may collect about you in relation to your use of our products or services (“personal data”). It also explains the legal rights that you have in relation to your personal data and how you may exercise these rights.
Some of our group companies may collect and use personal data for different purposes; those companies have their own websites and privacy notices. For example, some of our companies provide what we call people intelligence services whereby they collect, use, transfer, and distribute publicly available data on certain individuals. Different privacy policies available on those services apply to our collection and use of such data.
We will process your data for the following lawful purposes: with your consent; where it is necessary for us to perform a contract we have with you, or because you have asked us to take specific steps before entering into a contract (for example, when you register for any of our services, subscribe to a publication, sign-up for an event or purchase a product from us); because the processing is necessary for us to comply with the law; or where the processing is necessary for our legitimate interests or the legitimate interests of a third party. We review the bases for our processing decisions carefully and you can object to these activities at any time (see the “Your Rights” section of this Privacy Notice).
WHAT PERSONAL DATA WE COLLECT & WHY
Our primary goal in collecting personal data from you is to give you a relevant customised experience of our products and services.
◆ Registration, Free Trials & Subscriptions
When you register with our website and/or sign up for a free trial of our products or services, we may ask you to provide your name, address, email address and telephone number, and details relevant to your occupation or employer.
If you subscribe to one of our products or services, we will also ask for payment details. Credit/debit card payments are processed using a third party supplier and we do not retain the credit/debit card data (see the “Third Party Sites” section of this Privacy Notice). Address details may be shared with third party service providers engaged by us for order fulfilment, delivery and payment collection. This personal data is used by us to complete subscription requests.
◆ Events & Conferences
If you have registered for an event through a group website, or by telephone or by any other means, we may collect personal data including name, job title, company, address, telephone number and email.
This information is necessary so that we can complete your registration for the event and provide you with relevant event materials.
We may also share delegate details (e.g. name, email address) to event sponsors who may contact you for their own purposes.
◆ Advertising & Marketing
We may use the personal data you provide us and which we collect from you to inform you about other related products and services which we provide. We may send you marketing communications that are sponsored by our partners and which are targeted to your interests based on information you have provided us such as job title, employer and/or industry. We may share your personal data with Euromoney group companies so that they can send you marketing materials that may be of interest to you, in accordance with your preferences. You can opt out from receiving such materials at any time by clicking the “unsubscribe” link at the bottom of any communication we send. You can also visit our Preference Centre.
The personal data we may use for advertising and marketing purposes includes your name, email address, job title, phone number, company name/employer, geographical location, postal address and data collected using cookies and other similar technology (please read our separate Cookies Policy to find out more about which cookies we use, how they work and how you can control your cookie options).
Marketing materials are sent electronically, by post and we may occasionally call you.
◆ Online Targeted Advertising
We use targeted advertising on our websites to display advertisements that are relevant to what we believe are your interests. In order to deliver appropriate advertisements, we use third parties to deliver cookies that collect information about your IP address and how you interact with our sites (e.g. browsing information, which articles you have read etc.). This data is used by the third parties to determine which advertisements may be of interest to you.
We may also share your personal data with third parties to deliver targeted advertising to you on other websites (e.g. Twitter Tailored Audiences or Facebook Custom Audiences). This could include your email address, cookie data, and information obtained from third parties. Third party cookies may also be used to enable us to target advertisements to you on other websites that you visit.
◆ Lead Generation and Scoring
We occasionally use the services of trusted third parties in order to ensure that the personal data we use for advertising and marketing purposes is accurate and up-to-date. To do this, we transfer personal data of individuals (such as name, email, job title, location and phone number) securely to these third parties who conduct research to verify the data – primarily against public information
We also use algorithmic software technology to help us improve the quality and relevance of our marketing activities. The personal data analysed by the software includes email address, phone number, job title, address, purchase history and account information. This allows us to provide offers that are relevant to your specific profile.
Additionally, we may receive your personal data from other sources, such as public databases, marketing partners and other third parties for use in accordance with this Privacy Notice.
◆ Monitoring Transaction Data
We process information from Apps, through your browser or device and your IP address (collectively called Transaction Data) to:
- monitor usage and performance of our products, services, processes and platforms; perform analysis (e.g. statistical, market, product analysis), reporting and forecasting.
- understand how you interact with our products, services and platforms;
- perform checks and prevent, detect, investigate and report usage contrary to our Terms and Conditions
When processing your information for these purposes, we are relying on our legitimate interest to help us understand, develop, improve and market out products and services and our legitimate interest to manage risk and security.
◆ Surveys, Market Research & Customer Feedback
We want to understand the needs of our readers and customers. We may therefore use the information you provide us – including your name and contact details – to contact you to request your feedback, or to participate in our customer and market research.
◆ Public forums, message boards and blogs
Some of the pages on our group websites may include message boards, blogs or other facilities for generating content from users. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to post any personal data. User generated content is also subject to our site Terms and Conditions.
◆ Social media
When you download and use an App, we may track and collect App usage data, such as the date and time the App on your device accesses our servers, the pages you use and what information and files have been downloaded to the App based on your device number.
◆ Through your browser or device
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that our services are function properly.
◆ IP address
Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be logged automatically in our server log files whenever you access our services, along with the time of the visit and the pages visited. Collecting IP addresses is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our services. We may also derive your approximate location from your IP address.
◆ Business or Asset Sale
If we sell a business or assets we may need to disclose your personal data to the prospective buyer of such business or assets.
If Euromoney, or any of our group companies, is sold or sells our assets or is acquired by a third party, then personal data about our customers will be acquired by that third party. A transfer of your personal data in these circumstances would be necessary so that the services you have contracted for can still be delivered, or so that you can continue to enjoy the benefits of our products and services. You will receive notice if a new controller assumes responsibility for your personal data.
◆ Additional Third Party Disclosures
We may disclose your personal data to other third parties in the following situations:
- To third party partners who help us by providing services such as technology, marketing, advisory or other services. These third parties only receive encrypted data and may only process personal data to provide those services to us.
- Where we are required by law or regulation to do so. In each case we will seek, where practicable, to minimise the amount of data that is disclosed.
- If required to protect the rights and interests of other users and/or Euromoney and its affiliates (including our employees, agents and contractors), or as otherwise set out in our Terms and Conditions. This may include exchanging information with other companies and organisations for the purposes of fraud protection.
◆ Email Tracking
We may include small pixel tags (small image files) within the emails we send you in order to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. We may also collect browser, location and the device used to engage with our email communications. This information allows us to better understand whether we are meeting our users’ needs and how we can improve our communications. No other information is collected. You can opt out of receiving our direct marketing emails either by following the instructions in each email, writing to Euromoney’s Data Protection Officer (firstname.lastname@example.org) or by contacting us (see the “Who We Are” section of this Privacy Notice).
Some of the Euromoney group companies are based outside the United Kingdom (UK) and European Economic Area (EEA). Any of our group companies that receive your personal data will be controllers of that personal data.
We may also transfer personal data to third party service providers as described in this Privacy Notice which are located outside the UK or EEA
Where we conduct the transfers detailed above, we take all appropriate safeguards to ensure that your personal data remains protected, in accordance with applicable privacy legislation and this Privacy Notice. Such protections include implementing the European Commission’s Standard Contractual Clauses for transfers to non EEA members, relying on data protection adequacy decisions by the UK or the European Commission, or any such similar provisions which offer the security and protection mandated by legislation and this Privacy Notice.
We have a data retention policy that ensures we don’t use or store your personal data for longer than necessary. We consider the following issues to determine retention periods:
- Guidance from the UK Information Commissioner or other regulatory agency, or industry best practice recommendations;
- The use(s) of the personal data;
- The business rationale for collection and expiry of the purpose for which personal data was collected;
- Our ongoing ability to ensure the accuracy of the data; and
- Legal and regulatory requirements.
We may occasionally need to keep personal data for either shorter or longer periods than specified in our retention policy. In such circumstances, application of the retention period to the data will be temporarily suspended. The suspension of an applicable retention period will be carried out in a manner that respects the rights and interests of all persons concerned.
HOW YOU CAN SET YOUR DATA & PRIVACY PREFERENCES
You can use our Preference Centre to select the topics that are of interest to you so that we can send you publications and information about our products and services that are especially relevant to you. You can also choose the channels we use to contact you (email, phone, post, etc.) and can also opt-out of receiving communications.
FOR INDIVIDUALS WHO ARE IN THE UK AND EUROPEAN UNION: YOUR RIGHTS
You have certain rights in relation to your personal data which include the following:
◆ Access & Portability
You may request access to any personal data of yours for which Euromoney is responsible as controller. Unless there are legal or regulatory reasons for not doing so, we will confirm whether we process any of your personal data and if we do, we will provide you with the following information: the purposes of the processing, the categories of personal data, any recipients of your personal data, the applicable retention period and the data source. Copies of your personal data will be made available to you in a structured, machine-readable format or as otherwise agreed between us.
You may also request that we transfer the personal data that you have submitted to us, to another controller, where it is technically feasible for us to do so.
You have the right to request that Euromoney rectify any errors in the personal data that we process. In some circumstances, you may also be able to ask for the erasure of personal data, and/or request that the processing of your personal data be restricted. You may also object to the processing of your personal data for sales or marketing purposes.
◆ Deletion (the right to be forgotten)
You have the right to request that Euromoney delete your personal data (the right to be forgotten).
◆ How to Exercise Your Rights
To exercise any of these rights, please contact us by post or email at the following addresses:
Data Protection Officer
Euromoney Institutional Investor PLC8 Bouverie Street
London, EC4Y 8AX
Web form: Please click here
We may need to check your identity prior to processing a request.
Euromoney will do our best to respond to any questions and address any of your concerns. You also have the right to complain directly to the Regulator regarding the processing of your personal data with the UK Information Commissioner or the regulatory body of the country you live. You can contact the UK Information Commissioner at the link provided or in writing to:
Information Commissioner's Office
For other regulatory bodies, this information is readily available but you can contact us at email@example.com should you require assistance.
FOR INDIVIDUALS WHO ARE CALIFORNIA RESIDENTS
◆ How We Collect, Use, and Disclose Your Information
If you are resident in California (USA) you have certain rights with respect to your personal information under the California Consumer Privacy Act (CCPA) (California Civil Code Section 1798.100 et seq.) in which case this section headed ‘For customers who are California residents’ applies to you. Please note, we do not sell your personal information.
We may collect or have collected the following categories of personal information: identifiers, commercial information, internet or other electronic network activity, professional or employment-related information, and inferences. For examples of the precise data points we collect, the categories of sources of such collection, and the purposes of such collection, please see the section above called “What Personal Data We Collect and Why”. In addition we may disclose or have disclosed, the following categories of personal information for business purposes to the following categories of recipients:
|Category of Personal Information
||Categories of Recipients
||Euromoney Institutional Investor PLC group companies, partners, service providers, data analytics providers, government entities, operating systems and platforms, social networks.
||Euromoney Institutional Investor PLC group companies, partners, service providers, data analytics providers, operating systems and platforms
|Internet and other electronic network activity
||Euromoney PLC group companies, partners, service providers, data analytics providers, operating systems and platforms
|Professional or employment-related information
||Advisers, service providers, operating systems and platforms, government entities
||Euromoney PLC group companies, partners, advisers, service providers, data analytics providers, government entities, operating systems and platforms, social networks
◆ Your Rights
Subject to certain limitations, you have the right to : request to know more about the categories and specific pieces of personal information we collect, use, and disclose; request deletion of your personal information; opt out of any “sales” of your personal information that may be occurring; and not to be discriminated against for exercising these rights.
To access any of your rights described in this section (for customers who are California Residents), please submit your request by submitting the CCPA Data Request form. When you exercise your rights, we may seek to verify your identity, for example by verifying purchases you have made with us. If we receive your request from an authorised agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorised agent seeking to make a request, please contact us. We will not discriminate against you for exercising your rights.
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:
- 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
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.
You can request access to your personal information or obtain a copy of your personal information.
- 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.
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;)
You can transfer your personal information to a personal information processor designated by you when it meets the conditions stipulated by the authorities
- 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.
- 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:
- 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 firstname.lastname@example.org 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.
THIRD PARTY SITES
Our site may contain links to other websites – including, for example, providers of payment processing services. Euromoney is not responsible for the privacy and data collection practices of third party sites and we therefore recommend that you review the privacy policies and terms of service of each site you visit.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right, at any time, to add to, change, update, or modify this Privacy Notice so please review it frequently. If we make a material change to our Privacy Notice, then we will revise the date at the top of this Privacy Notice and, in some cases, we may notify you by email or by posting a notice on our website. In all cases, use of information we collect is subject to the Privacy Notice that is in effect at the time such information is collected. If you do not agree with any changes or modifications to the Privacy Notice, please do not continue using our products and services. You will be deemed to have consented to any modification of the Privacy Notice when you use our products and services after the effective date of the modification.