2. HOW WE COLLECT AND USE INFORMATION
Personal Information: Some of the information that we collect when you use this Site, such as your name, company name, postal address, email address, credit card number or telephone number, may allow you to be identified. We call this information “Personal Information.”
Registration: When you register on a Site, such as to receive a publication or email newsletter, you will be asked to provide certain Personal Information, which we use to provide the publication or newsletter to you.
Surveys: We may ask you to complete surveys or opinion polls from time to time. Participation is voluntary. We only use the information that we collect from surveys in an aggregate manner, not in individually identifiable form.
Blogs and Forums: Our Sites may provide an opportunity for you to post information to blogs, forums or other public areas. By doing so, you consent to the posting of any Personal Information that you provide. You should be aware that such Personal Information can be read, collected, or used by other visitors to these public areas. We have no control over how these visitors use your Personal Information.
Web Logs: We maintain web logs that automatically record basic information about everyone who visits the Sites. We use web log information to help us design our websites, to identify popular features, and for other managerial and analytic purposes. We may also use web logs to help identify any person attempting to break into, damage or misuse any of the Sites. These logs contain:
- The Internet domain from which you access any of the Sites.
- Your IP address.
- The type of browser and operating system that you use.
- The date and time you visited any of the Sites.
- The pages that you visited on any of the Sites.
- The address of the website you linked from to get to any of the Sites.
Communicating with You. We may use information that we collect from you for the purpose of communicating with you and responding to your inquiries. Those communications could, for example, take the form of news updates, promotions for products or services that we or one of our marketing partners provide, or e-newsletters.
Service Providers: We sometimes contract with third party service providers to perform functions for us. These service providers may be given access to your information for the purpose of performing those functions, but they may not use this information for any other purpose.
Marketing Partnerships: From time to time, we may make your Personal Information available to other reputable organizations to market, or allow others to market, products or services that may be of interest to you.
Business Transfers: If we were to transfer all or substantially all of our assets, or the assets pertaining to one or more Site(s), to another company, one of the assets we would likely include in the transfer is the relevant database of Personal Information.
Webinars: From time to time, a Site may host webinars or similar events in conjunction with cosponsors. We may share Personal Information of attendees of these webinars with the cosponsors.
Disclosures for Legal Reasons: We will disclose Personal Information when we are required to do so by law, regulation or securities exchange requirement, for example, in response to a court order or subpoena. We also may disclose such information in response to a law enforcement agency’s request or when we believe such disclosure is appropriate to protect our legal rights or to safeguard anyone’s property or safety.
3. COLLECTION OF INFORMATION BY THIRD PARTIES
We use a third-party advertising company to serve ads when you visit our Sites. This company may use information (not including your name, address, email address or telephone number) about your visit to this Site in order to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements to this site, our third-party advertiser may place or recognize a unique “cookie” on your browser.
4. YOUR PRIVACY CHOICES
If you would like us to stop sending you email or other communications; would like us not to disclose your Personal Information to marketing partners or advertisers; or would like to access your registration information to correct or delete it, you may send us a request at firstname.lastname@example.org. We will endeavor to satisfy such requests within a reasonable time. Removing registration information from our main files does not remove your records from any of our backup systems. It may take months before backup records are completely recycled and related data are completely removed. Backup records remain subject to the same protections as our other records. We take reasonable steps to ensure that the information we collect is reliable for its intended use, accurate, complete and current.
We maintain all Personal Information with physical, electronic, and managerial safeguards to help ensure the security and confidentiality of the data against reasonably foreseeable risks. Security is designed to prevent unauthorized use, access, disclosure, destruction, and changes of data. For example, we restrict access to our computing facilities to individuals identified by management as needing access to perform their jobs. We also review changes in technology and security measures and regularly train our personnel.
The Sites are intended for use by adults. We do not target, or knowingly collect any Personal Information from, children under the age of 13.
7. DATA PROTECTION
We take our obligations under the following Data Protection legislation very seriously and have taken steps to ensure full compliance
( i) EC Directive 95/46/EC (up to and including 24th May 2018); and
(ii) the Data Protection Act 1998 (up to and including 24th May 2018); and
(iii) the GDPR (from and including 25th May 2018); and
(iv) Replacement National Legislation; and
(v) the Privacy and Electronic Communication Regulations 2003; and
(vi) any judicial or administrative interpretation of them, any guidance, guidelines, codes of practice, approved codes of conduct or approved certification mechanisms issued by any relevant Supervisory Authority,
This is a statement of the data protection policy adopted by Strategic Insight.
As a company that reports news for Retirement and Chief Investment Offices, primarily in the US, we act as a data Controller. The collection of your subscription, defines our responsibility as a data controller. Our subscription Data is stored in the US.
Specifically, the Principles of the Data Protection require that personal data:
- shall be processed fairly and lawfully; and, in particular, shall not be processed unless specific conditions are met;
- shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes;
- shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;
- shall be accurate and, where necessary, kept up to date;
- shall not be kept for longer than is necessary for that purpose or those purposes;
- shall be processed in accordance with the rights of data subjects;
- shall only be processed in accordance with the instructions of the Data Controller (submitter)
Therefore, Strategic Insight will, through appropriate management, and strict application of criteria and controls:
- observe fully the conditions regarding the fair collection and use of information;
- meet its legal obligations to specify the purposes for which information is used;
- collect and process appropriate information, and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;
- apply strict checks to determine the length of time information is held;
- ensure that the rights of the people about whom information is held can be fully exercised under the current legislation. (These include: the right to be informed that processing is being undertaken; the right of access to one’s personal information; the right to prevent processing in certain circumstances; the right to rectify, block or erase information which is regarded as wrong information.);
- take appropriate technical and organisational security measures to safeguard personal information, including physical security, passwords, backups etc.;
- retain or destroy data accordingly to client requests, meeting company guidelines.
In addition Strategic Insight will ensure that:
- there is someone with specific responsibility for data protection in the organisation.
- everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice;
- everyone managing and handling personal information is appropriately trained to do so;
- everyone managing and handling personal information is appropriately supervised;
- anybody wanting to make enquiries about handling personal information knows what to do;
- queries about handling personal information are promptly and courteously dealt with;
- methods of handling personal information are clearly described;
- a regular review and audit is made of the way personal information is managed;
- methods of handling personal information are regularly assessed and evaluated;
- performance with handling personal information is regularly assessed and evaluated
- there are procedures in place to deal with notification of any breaches
- there are procedure in place to deal with any Data Subject Requests including updates and Rights to Forget
- that we will support our clients in any reasonable ways to facilitate Data Subject requests from their clients.
- that we have appropriate Insurance in place specifically for data protection