Privacy Policy

PRIVACY POLICY AT ECONOMIC HERALD

This policy covers the processing of personal data by Economic Herald, and its associated Group companies (“Future”, “we” or “us”). Future is committed to protecting the privacy of your personal information whilst striving to provide the very best user experience. GDPR says that ‘personal data’ is any information relating to a living individual who can be identified, either directly or indirectly, from that information. This could include your name, email address, postal address or telephone number, or information collected online and used to identify you.

WHAT DATA DO WE COLLECT AND HOW DO WE USE IT?

Information you provide to us	When you participate in, access, purchase or sign up to any of our services, activities, online accounts or online content, such as magazine subscriptions, newsletters, surveys, vouchers, competitions, events, webinars, white papers or community forums we receive personal information about you which we use to provide these services. This may consist of data such as your name, email address, postal address and telephone number. We will use this to provide the specific products and services you are seeking, and will ensure we have a lawful basis for doing so, in accordance with the country in which you reside.
Ordering a product or service from us	If you order a product or service from us, you will need to provide certain personal details, including payment information, so the order can be fulfilled. This may be collected, for example, as part of the registration process or when creating an account. In some cases, we will use or direct you to a third party who will collect this information from you and fulfil your order. For example, if you order a subscription to our publications, you may be able to access those products through a digital newsstand such as Apple Newsstand.
Attending an event	If you attend one of our events, awards or conferences we may receive personal information about you, including your name and contact details and any dietary and accessibility requirements. If you attend one of our events remotely, we may share your name and contact details with the platform hosting the event.
Content you share with us	When you choose to share comments, photos, videos and other content with us we may receive personal information about you, for example when you interact with us on social media.
Information we collect automatically when you use our sites/services	We may collect technical and/or behavioural information about your use of our websites or other content online, and the device(s) you use to access the services. For example, this information may include details about how you browse our website and the devices and technology you use to browse our website. This may also include unique online identifiers such as device ID, device type, IP address and approximate location at the time of browsing. This may also include video viewing data and may link to your activity on other sites and allow us to recognise you or your device. We may use this to build a more detailed profile of you and your interests. We may also provide you with location-based services (for example, advertising and other personalised content), where we collect geo-location data. Please see What data is collected on our websites? and our Cookies Policy for further details about how we use this data and information on opting out.
Information for analysis, reporting and research	We also collect statistical and analytical data about your visits and activity on our sites, such as the pages you view, how long for, and which links are followed. This helps us to improve the way we deliver content and the products and services offered to you. We also use this anonymised data to report on our performance and to sell advertising. In addition, we may need to contact you about your experience of a product or service we provide you.
eCommerce	Some of our websites contain links to products and services offered by third-party websites. If you click on those links we will use data collected about your activity on our site to direct you to the third party site. We and the third party may collect data to show us that you have clicked on the link and whether you purchased any products and services. We may receive a commission from the third party if you link to their site from a Future site and purchase goods and services from them.
Direct marketing	We use the information you provide us with, such as email, address, or phone number, to send you marketing communications, either based on your consent or where we have legitimate grounds to do so. You can update your marketing preferences at any time.
Email tracking and online behaviour	We use web beacons in our emails to track the success of our marketing campaigns so if you open an email from us, we can see which of the pages of our website you visited. Our web beacons don’t store any information on your computer but, by communicating with our cookies on your computer, they can tell us which emails you’re interacting with and how you’re interacting with them. For example, we will know when you have opened an email from us and the devices used. We may keep track of the emails that we send you and may use the information we collect to personalise the emails we send to you. We also keep a record of the communications you have selected to receive or not to receive, for example whether you would like to only receive brand marketing from a particular brand, or that you have agreed to receive emails deemed of interest to you from other brands within the Group.  We may also use your email in a hashed, unidentifiable form to help us understand your online behaviour. This may in turn be used for analytics and targeting.
Data matching, to recognise you or your device, and to serve targeting advertising	We may share information that we collect from you (for example, when you browse through our websites or use our mobile applications), such as your email (in hashed, pseudonymous form), IP address, your mobile advertising ID or information about your browser or operating system, with our partners, and their group companies, who use this information to create an online identification code for the purpose of recognising you on your device. This code does not contain any of your identifiable personal data and cannot be used to re-identify you.  We place this code in our first-party cookie or use a partner’s cookie, and allow it to be used for online and cross-channel advertising. This hashed, pseudonymous code may be shared with our advertising partners and other third-party advertising companies globally for the purpose of enabling interest-based content or targeted advertising throughout your online experience (e.g. web, email, connected devices, and in-app, etc). These third parties may in turn use this code to link demographic or interest-based information you have provided in your interactions with them.  We also work with other parties, for example The Trade Desk who acting as “joint controllers” (as applicable and defined in the GDPR) use your email to create an Encrypted Code (called a European Unique Identifier or EUID). This non-identifiable code is then used to recognise you on your device and is also shared with different sites and advertisers who have permission to process the  Encrypted code. As a result other websites, apps, advertisers, and advertising companies are able to show you relevant advertising. You have the right to withdraw your consent or opt-out of processing your personal data at any time. If you would like to withdraw your cookie consent you can do so via the consent management pop-up. To opt-out of your hashed email address being shared for profile-based online advertising, please email dpo@economicherald.net using the subject line ‘opt-out of hashed email ad profiling’. Where we have your email address, We and our partners will store and/or access information on your device and will use the unique advertising identifiers and other personal information for personalized ads and content, ad and content measurement, audience insights, and to develop and improve our products. To do this, personal information may be used to match and combine offline data sources.
When you contribute articles and content	If you write for us, or provide us with content in return for payment, through one of our sites, we may collect your social media profiles, such as Facebook and Twitter, on registration.  This allows us to show links to your social media profiles within the content that you write, allowing other users of the site, and yourself, to share your content with others. This may also involve giving you access to the areas of a website that directly interacts with or makes use of YouTube APIs. This enables us to collect other information needed to upload content such as the source of the video, (for example, from an existing article or original content or playlist), also analytical data such as view counts, and how long watched. We will also use the information you provide us with, such as bank details, to ensure we pay you the correct fees for the content you provide for us.
Research surveys	We may use the information you provide to invite you to participate in surveys and focus groups about our products, clients and services. Participation is always voluntary and the answers you provide are anonymous and aggregated to support our learnings and inform changes we can make to improve our products and services.
Information from other sources, including Group companies	We may receive information about you from other sources (for example, missing information about your postal or email addresses) and add it to the personal information we hold about you. We may also receive data from other sources, such as our business partners, Group companies and social media platforms. For example, when you visit one of our Facebook pages. Other information, such as inferred data and demographics data, may also be collected and used to match, combine and enrich profile information we hold on you. For example, linking your contact or subscriber information with your activity across our sites. In addition, if you opt-in to receive marketing from our Group companies, you may receive emails deemed of interest to you from other brands within the Group.
Business specific data	Some of our websites also collect business data, for example when signing up for a webinar or when downloading a white paper. This may include professional or employment information, such as company name, job title,  job function, level in organisation, company type, company revenue and number of company employees, business phone number, business address, business email, corporate website, employment history, professional designations and educational information. Also location information, such as country, and state (or county), and ZIP code (or postcode).  We typically collect this information directly when you complete registration forms or when you provide other information through our Website or via email. When we collect this information directly, we let you know if providing the information is optional or if it is required to provide our Services. Occasionally we may purchase business data from third-party suppliers which may include, for example, business email address, business job title and business postal address. This may result in you receiving communications from Future regarding your business sector or business interests without you having directly supplied your information to us. For example, we may email you to encourage you to sign up to a webinar. We keep clear records of the data suppliers and provide an unsubscribe option at every contact.

WHAT LAWFUL BASIS DO WE RELY ON FOR PROCESSING?

In order to process your personal data, we must have a lawful reason for doing so. GDPR sets out six lawful bases under which organisations can collect, use and store personal data. We rely on four of the lawful bases:

Necessary for the performance of a contract

If you are our customer, for example a subscriber of a magazine or an attendee at one of our events, we will process your personal data on the basis that it is necessary for us to provide our products and services to you.

Consent

In some instances we rely on your specific consent to process your personal information. This is where you have actively agreed and ‘opted-in’, for example to receive marketing communications from us, and you have the right to withdraw your consent at any time.

Compliance with laws

We may have to process and share your personal data in order to comply with our legal obligations, or to protect our rights or the rights of others. For example, we are required to collect certain information from you when processing your subscription payment for tax or financial reporting reasons.

Legitimate interests

In some situations we rely on our legitimate business interests in order to collect and use your personal data. In these situations, we have conducted a balancing test to carefully consider the impact of the processing on your interests, rights and freedoms. We will only undertake the processing if we are satisfied there is no negative impact on you. We rely on Legitimate Interests for the following activities:

• providing, maintaining, improving and developing our products and services;
• sending direct marketing communications about our products and services to customers, which may, for example in the US,  include content we send on behalf of advertisers;
• sending marketing communications related to the products and services of carefully selected companies in a business-to-business context;
• managing suppression and unsubscribe requests;
• researching publicly available business contact details;
• managing certain aspects of our events;
• analysing the use of our products and services;
• using aggregated, non – personally identifiable statistical and analysis data to identify usage trends, such as your visits and activity on our sites, and to determine the effectiveness of campaigns;
• allowing you to comment on our sites, provide feedback or take a survey;
• dealing with queries and complaints;
• notifying you of product recalls or providing other information concerning products you have purchased;
• personalising your experience on our sites;
• Improving merchandise selections and your overall shopping experience;
• using your data in hashed non-identifiable form to help find you or similar audiences through Facebook’s audience function and Google customer match; 
• identifying fraudulent behaviour and ensuring our websites and systems are secure; 
• building and enriching profiles of users based upon, for example, product selection and online behaviour; and
• sharing the information you provide and other information held about you within our Group companies, for the purposes of this policy. For more information see How we work with Group companies.

WHO MAY WE SHARE YOUR DATA WITH?

Agents

We use third parties to perform certain functions on our behalf including fulfilling orders, sending emails, organising and managing events, running competitions and promotions, conducting surveys or polls, removing repetitive information from customer lists, comment hosting, website analysis, data analysis, and processing credit card payments. They will have access to your personal information if necessary to perform their function but they cannot use it or disclose it for any other purpose unless you have specifically given them consent to do so.

Aggregate Information

We may share aggregated, non-personally identifiable information, such as demographics and website usage statistics, with advertisers, sponsors, and other organisations. This may include, for example, tracking your cookie ID,  IP address and engagement metrics, when you are online in the course of business,  which is then aggregated to create a profile of a company, not an individual.

Products or services offered in partnership with third parties

Certain products or services available through this website may be provided to you in partnership with a third party (“ Co-Branded Areas”) . That third party may require you to disclose personal information to them in order to receive such products or services. If you request a product or service offered in partnership with a third-party, the identity of the third party will be disclosed to you and your personal information will be transferred to that third party.

Also, if you sign-in to a Co-Branded Area with a username and password obtained on the Site, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area.  

Alternatively, when you register for an event, webinar we may share data with the sponsors of the event or webinar, and other partners and advertisers (collectively, “Sponsors”).  This will be in accordance with the privacy laws in the country in which you reside.  For more information see Webinar and Event Registration.

We are not responsible for such third-party’s data collection or practices and you should look to such third-party privacy policies for more information. 

Sweepstakes, Contests and Promotions 

We may offer sweepstakes, contests, and other promotions (any, a “ Promotion”) through the Site that may require registration.  By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.  If you choose to enter a Promotion, personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

Group companies

Economic Herald companies may use and share the information you provide, and other information held about you, for the purposes set out in this Policy. For more information about the Economic Herald please see the Future website. For more information see  How we work with group companies.

Changes in ownership

If we sell any parts of our business, for example a website or a magazine, we may have to share your personal data with the purchaser. For example, to enable them to continue providing a subscription or other service to you. The new owners will use your personal data as set out in their Privacy Policy. 

Ad serving plus measurement and reporting services

We may use a third-party network advertiser to serve the advertisements on this website. Network advertisers are third parties that display advertisements based on your visits to this website and other websites you have visited. This third-party ad serving enables us to target advertisements to you for products or websites you might be interested in. We may also use an audience or traffic measurement service to analyse the traffic on this website. Audience and traffic measurement services allow us to collect traffic and behavioural information from the website by monitoring anonymous visitor activity. This website’s advertisers, sponsors and/or traffic measurement services may themselves set and access their own cookies on your computer if you choose to have your cookies enabled in your browser.

Advertisers and advertising networks

We may also share de-identified information and/or aggregated information with a third party who is helping us select and deliver interesting and relevant advertising to you and/or other potential customers. This includes sharing data with advertising networks and search engines, in order for us to deliver relevant advertising to you, based on what you appear to be interested in. For example when you are searching for information or browsing other sites.

This could also be in the form of an anonymous data segment or an online identification code called a privacy-protective identifier. (A privacy-protective identifier is where we convert the original information, such as an email address or phone number, into a value to keep the original information from being revealed). These third parties may use this code to link demographic or interest-based information you have provided in your interactions with them in order to limit the number of times you see a particular ad, enable interest-based content or provide you with targeted advertising. You have the right to express a choice regarding our sharing of this data for the above purposes; of the creation of this code or of our sharing of the code with our advertising partners. 

Behavioural remarketing services

After you have visited our site, we may use remarketing services provided by companies such as Facebook and Google and Bing, to show you advertising on third-party websites, based on your browsing patterns and interactions. For this purpose, visitors are grouped by certain actions on our services, for example, by duration of visit. This enables us to understand your preferences and to show you personalised advertising even if you are currently on another website within the network.

Social media

We may also share de-identified information with social media platforms for advertising purposes. For example, we may share a hashed, non-identifiable version of your email with, for example, Facebook or Google, with the aim of showing you advertising on those platforms. Alternatively, we may use this data with the aim of excluding you from seeing our advertising on those platforms. We only share data in this way if you have agreed to receive marketing communications from us. Our ability to subsequently tailor (or exclude) ads in this way are determined by your account settings on those platforms. 

Some of our sites enable our users, and contributors, to share information with sites such as Youtube. On these occasions, our websites interact directly with YouTube (via its APIs), and make use of YouTube API services, for example interacting periodically with the YouTube APIs in order to keep any analytical data previously gathered up to date and complete.

By using these services, users are agreeing to be bound by the YouTube Terms of Service, which can be found at https://www.youtube.net/t/terms. In addition to our normal procedure for deleting stored data, users can revoke access to their data as it relates to the YouTube API by visiting the Google security settings page at https://security.google.net/settings/security/permissions.

When we share information with third parties, we only permit them to process this data for specified purposes. We do not share more information with them than is necessary for the relevant purpose and we require them to treat this information with at least the same protection we do.

WHAT DATA IS COLLECTED ON OUR WEBSITES?

‘Cookies’ are small data files which are sent to your computer, mobile phone or other device so that the website can remember information about your browsing activity. We use cookies on our websites for a variety of purposes:

Information storage and access

The storage of information, or access to information that is already stored, on your device such as advertising identifiers, device identifiers, cookies, and similar technologies.

Content selection, delivery, reporting

The collection of information, and combination with previously collected information, to select and deliver content for you, and to measure the delivery and effectiveness of such content. This includes using previously collected information about your interests to select content, processing data about what content was shown, how often or how long it was shown, when and where it was shown, and whether you took any action related to the content, including for example clicking on content. This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, such as websites or apps, over time.

This does not include personalisation, or the collection of information about your use of this service to subsequently personalise content and/or advertising for you in other contexts, i.e. on other services, such as websites or apps, over time.

Personalisation

The collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as on other websites or apps, over time. Typically, the content of the site or app is used to make inferences about your interests, to help us to personalise your experience and show you more relevant content and advertising.

Ad selection, delivery, reporting

The collection of information, and combination with previously collected information, to select and deliver advertisements for you, and to measure the delivery and effectiveness of such advertisements. This includes using previously collected information about your interests to select ads, processing data about what advertisements were shown, how often they were shown, when and where they were shown, and whether you took any action related to the advertisement, including for example clicking an ad or making a purchase. 

This does not include personalisation, which is the collection and processing of information about your use of this service to subsequently personalise advertising and/or content for you in other contexts, such as websites or apps, over time.