Privacy & Data
What is personal information?
As used herein, the term “personal information” means information that specifically identifies an individual (such as a user’s name, address, telephone number, e-mail address, credit card or other account number) or that is associated with an identifiable person (such as demographic information or information about a person’s activities when such information is linked to personally identifying information). Personal information does not include “aggregate” information, which is data we collect about the use of the Sites or categories of Site users, from which any personal information has been removed. For example, information that forty-seven percent of the Site’s registered users identify themselves as male, but without identifying any specific individuals as male, is aggregate information. We collect aggregate data for a number of purposes, including to help us understand trends and user needs so that we can better consider new publications, products and services, and tailor existing publications, products and services to user desires. This policy in no way limits or restricts our collection of aggregate information.
What is the legal basis for processing personal information?
Personal information may be processed on the following basis:
- the data subject has given consent to the processing of his or her personal information for one or more specific purposes;
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which the controller is subject;
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
What personal information do we collect?
Personal information may be collected in a number of ways when you visit our Site. At several places on our Site, we may collect certain personal information you voluntarily provide to us. For example, if you register for the Site, download our content, send us an email, respond to a survey, register for an event, submit a comment or apply for a job through the Site, we may collect personal information such as your name, address, phone and email and other contact information, as well as demographic and other personal information. Personal information may also be collected if you provide it in connection with participating in forums or other interactive features of the site.
When you visit our Site, some information is automatically collected through the use of log files, such as your computer’s Internet Protocol (IP) address, your computer’s operating system, the browser type, the address of a referring web site and your activity on the Site. We use this information for purposes such as analysing trends, administering the Sites, improving customer service, diagnosing problems with our servers, tracking user movement, and gathering broad demographic information for aggregate use. We also automatically collect certain information through the use of “cookies.” Cookies are small data files that are stored on a user’s hard drive at the request of a Web site to enable the site to recognise users who have previously visited them and retain certain information such as customer preferences and history.
We use the following third party analytics and advertising features on our Site:
- Google Analytics to enable data collection for website performance and Site visitor behavioural analysis,
- Google Remarketing to enable data collection for search and display advertising purposes,
- HubSpot to enable data collection and management of personal information for marketing purposes.
This technology allows third-party vendors, including Google and HubSpot to reconnect with visitors who have already visited our Site to provide targeted Search and Display Network advertising and/or provide a consistent repeat visitor experience. Information generated by these cookies are anonymised as part of these third-party data protection provisions and are not combined by any other data. If we combine cookies with or link them to any of the personally identifying information, we would treat this information as personal information.
If you wish to block, erase, or be warned of cookies, please refer to your browser instructions or help screen to learn about these functions. You can find more information about deactivating Google Advertising Services here. You can find more information about HubSpot cookies here. However, if a browser is set not to accept cookies or if a user rejects a cookie, you will not be able to sign in and will not be able to access certain Site features or Services.
How do we use the personal information we collect?
In general, we use personal information we collect to facilitate your use of the Site, to process your requests or transactions, to provide you with information, products and services you request, and for the purposes for which the information was provided. We may also use personal information to inform you about other products, services, documents, publications, information, promotions and events we think will be of interest and to administer and assist us with the operation of the Site and of our business. For example, we may use the information we collect:
- to send you a welcoming email and to contact you about your use of the Site, such as for administrative purposes or to provide you with customer service;
- to provide you with the services, products or information you requested and to complete any transactions in connection therewith;
- to respond to your emails, submissions, comments, requests or complaints;
- to request feedback and to enable us to develop, customise and improve the Site and our publications, products and services;
- to contact you about our products, services, training, activities promotions or special events or offers and for other marketing, informational, product development and promotional purposes;
- to notify contest winners; and
- for the specific purpose for which the information was provided.
We may also receive information from third parties with whom we have business relationships, and may combine this information with the other personal information we have about you. In such cases, this Policy governs our use and disclosure of such information. You may opt out of having us use your personal information for marketing purposes as set forth below under “What choices do you have regarding the use of your information?”
What steps do we take to protect your information online?
We endeavour to secure your personal information from unauthorized access, use or disclosure by putting into place appropriate procedures to safeguard the information we collect through this Site. For example, your account information is accessible online only through the use of a password and access to passwords are restricted to appropriate personnel. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable. To protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Site by any person using your password. Please advise us immediately by emailing us at firstname.lastname@example.org if you believe your password has been misused. You should also note that email is not secure, and you should not send any confidential or sensitive information to us via an unsecured email.
We endeavour to secure your personal information by encrypting the Site and using secure, encrypted platforms to store your personal information.
What choices do you have regarding the use of your information?
You may “opt out” of receiving marketing or promotional communications from us or from having us share personal information with our marketing partners by emailing us at email@example.com or updating your preferences on our subscriptions page.
You may request access to the personal information we have collected from the Site. This will be provided in a machine-readable format such as a CSV or XLS file.
How long will your personal information be stored for?
Your personal information gathered from the Site will be stored until you withdraw your consent from us keeping your personal information or request deletion of your personal information gathered from the Site. We may also delete your personal information from our records as we see fit.
How can you correct and update your personal information or obtain additional information?
If you have any questions or comments about this Policy or the practices relating to this Site, or you wish to verify, correct or delete any personal information we have collected, please contact us at firstname.lastname@example.org, and we will endeavour to respond to your inquiry or to correct, update or remove the personal information you have provided us as you indicate to the extent possible. You may also delete certain information by closing your account. However, please note that in certain circumstances, we may not be able to remove or change certain information, even in the event an account is closed. For example, we may be required to retain certain information, such as credit card billing information, for a certain period of time, and it may be necessary to retain certain information in order to complete any services or transactions with us.
In lieu of email, you may also contact us by mail at the following address:
Flintfox International Limited
Attn: Chief Marketing Officer
5 Omega Street
PO Box 305-499
Updated: May 17, 2018