If you wish to amend any of the personal information that we hold about you, or update your marketing preferences, you can do so at any time through your account or by emailing us.
If you have any queries about how we use your personal information, please contact us: firstname.lastname@example.org
INFORMATION WE COLLECT
If you decide to create an account, sign up for email alerts, register for our events or enquire about one of our products or services, we will ask you to provide us with some specific information, such as:
Basic Personal Details: E.g. name and title
Personal Contact Details: E.g. home address, delivery address, home phone number, mobile phone number and email address
Work Details: E.g. job title, department, company name, company address, work email address and office phone number
Log in Details: E.g. username and password
Payment Details: E.g. your bank account and payment card information
Occasionally, we will ask you to voluntarily provide additional information, for example:
- Your opinion of our products and services
- Your preferences, including newsletters or events
Information such as your dietary preferences and accessibility requirements when attending an event, which may be considered special categories of personal data.
Information we obtain from partners and public sources
In some circumstances, we collect information about you from our partners or from publicly available websites to help us better understand our audience and enhance the relevance of our content. For example, in some cases we obtain the contact details of potential speakers for events from public websites.
Information we obtain through cookies and similar tools
LAWFUL BASIS FOR PROCESSING
We only process personal information where we have a lawful basis for doing so, such as the following:
User Consent: This is where you have given us explicit permission to process personal information for a given purpose. For example, if you complete one of our general enquiry forms, we would ask for your consent if we wanted to use your personal information for any other purpose. You have the right to withdraw this consent at any time. You can manage your preferences within your account or by contacting customer services.
Legitimate Business Purposes: This is where we have a legitimate interest, as a business, to process personal information. For example, where we are aware of copyright infringements on our Site, it is in our legitimate interests as a business to identify those responsible. We take due care to balance our interests against your right to privacy.
Contractual Necessity: This is where we have to process personal information to meet our contractual obligations. For example, if you are a print subscriber, we would need to process your delivery address to fulfil your subscription.
Legal Obligation: This is where we have to process personal information in order to comply with the law. For example, we process and retain customer invoice information to comply with financial regulations.
USE OF PERSONAL INFORMATION
We collect personal information mainly for the following reasons:
Service Provision: We require some of your basic personal information so our services work as you would expect, for example, sending you your weekly news updates, delivering the magazine to your correct address, providing access to our digital content, notifying you of changes to our services and dealing with customer services queries. We may record customer calls for monitoring and training purposes.
Improvement & Maintenance of Service: In order to provide you with the best possible user experience, we need to make sure that our products and services work as they should. Using personal information helps us understand how our readers use our Sites so we can make improvements. This includes testing proposed developments on our Sites, reaching out to our customers with market research surveys and hosting subscriber focus groups.
Customer Billing: We, along with our authorised payments processors, securely process your payment information to take payments, give refunds and to detect and prevent fraudulent activity. We will also update your payment information in the event that a payment is unsuccessful. You can manage your payment information at any time by contacting customer services. If your subscription is provided by your employer or educational institution under a group subscription, we will report how active you are for the purposes of billing.
Compliance Monitoring: We monitor for breaches of our terms and conditions and copyright policies. For example, we reserve the right to inform the subscription holder if, through use of a group subscription, you are using our content in breach of the terms and conditions or copyright policies of our Sites. We also monitor activity on our Sites to detect and prevent invalid or fraudulent traffic.
Personalisation of Products & Services: We improve your experience of our products and services by personalising parts of our Sites and with the information you give us and what we learn about you. This includes showing you articles you may be interested in and recommending emails you may wish to sign up to. Where our Sites have such functionality, you can manage elements of personalisation in your account.
Communication of Product Changes & Offers: We want you to get the most out of our products and services, including showcasing our latest content and newsletters. You are able to change your preferences at any time through your account or by contacting customer services. We also personalise our communications for strategic purposes.
Advertising: We rely on advertising revenue in part to support our journalism. We need to process your information to understand the effectiveness of the advertising we serve to you and others, and to deliver relevant personalised advertising. We use the information you give us and the information we collect about you to serve you with the most appropriate advertisements. You can manage your advertising settings for the Sites that carry out this activity in your account. If you do decide to turn off personalised advertisements or advertisements tailored to you, you will still see the same number of advertisements but they may be less relevant to you. You may continue to see advertisements that are targeted to you based on other non-personal information, for example, the article that you are reading.
SHARING PERSONAL INFORMATION
We disclose personal information to facilitate the running of our business or to provide specific services you have requested. Commonly, we will disclose information to:
Service Providers: We engage service providers who help to support our business and improve our products. These service providers include, for example, fulfilment providers for delivery of our digital content and marketing; customer service agencies; hosts, organisers and sponsors of our events; organisations that host our Sites or databases; and providers of online surveys. We also work with a number of distribution partners to deliver subscriptions. We have contracts in place with these data processors and they can only use your personal information under our instruction. For example, if you have a print subscription with us, we will disclose your information e.g address, contact details to our distribution partners to facilitate delivery of the magazine.
Institutional Customers: If your subscription is provided by your employer or educational institution under a group subscription or trial, we will provide your employer or educational institution with information about your level of activity on the site for the purposes of billing. This information is provided at a high level and your employer cannot track exactly what articles you have read. We may also provide current or prospective institutional clients with activity information about individual subscribers who registered using that entity’s corporate email address. We will always contact individual subscribers before doing so, and will respect any requests not to share this information.
Social Media Providers: Information will be shared with social media platforms where you log in to our Sites via a social media account, or use components on our Sites provided by social media platforms (e.g. the “Facebook Recommend” function). We also share the information of our subscribers with social media partners for the following reasons:
i) To prevent existing subscribers from being targeted with subscription offerings on social media platforms;
ii) To create lookalike audiences for the purposes of targeted advertising on social media platforms
iii) To encourage users to get the most out of their subscription.
Other Users: Our Sites are publicly accessible and anyone around the world who accesses our Sites will be able to see anything you post, such as comments about an article. We encourage you to use a pseudonym when commenting on our Sites if you do not wish to be identifiable to other readers.
Our Companies: We share your information within our group of companies to provide our services and to better understand the relationship between our products.
PERSONAL INFORMATION RETENTION
We retain the majority of your personal information for as long as your account is active and therefore open; this allows you to continue accessing our content, products and services.
If you become inactive and are not a subscriber, we may delete elements of the information associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account.
Where we don’t need to keep all of your information in full, we will obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary.
A summary of how long your personal information is retained can be found below:
|Category of Data||Example||Retention Period||Reason|
|Billing Information||Masked details of most recently used payment method||7 years||For regulatory reasons we are required to retain accounting records for 7 years.|
|Business Intelligence||Web activity||36 months (then aggregated + non-personally identifiable)||To improve and maintain performance, personalise our services and to provide our product.|
|Customer Service Queries||Complaint about non-delivery of magazine or newsletter||7 years||To provide a case history to assist us to answer your queries.|
|Communication History||Email stating that your subscription is up for renewal||7 years||So that we have a record of what communications we have sent to you, to better assist your queries|
|Event Registration||Sign up information for our events||13 – 36 months||For event administration and, with your permission, to invite you to future events.|
|Market Research||Responses to surveys||13 months (then aggregated + non-personally identifiable)||To administer market research incentives, avoid duplicating research requests and to understand research responses against usage of our Sites.|
|Subscription Information||Account information relating to a subscription||7 years post-subscription||To enable us to fulfil your contract with us.|
It is sometimes necessary for us to keep your personal information for longer periods of time, for example:
i) If there is a statutory requirement to retain it;
ii) If we require the information for legal reasons or there is a legitimate business need for us to retain it;
iii) To ensure we do not contact you if you have asked us not to.
PERSONAL INFORMATION SECURITY
We have appropriate technical and administrative security measures in place to help ensure that our users’ information is protected against unauthorised or accidental access, use, alteration, or loss.
We operate a global business, so your personal information may be processed and stored outside the European Economic Area (EEA). For example, our external team need to access information about you in order to respond to your queries.
Under data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include:
1) The right to object to direct marketing – your preferences, including in relation to direct marketing, can be found in your account
2) The right to access the personal data that we process about you
3) The right to request the deletion of your personal data
4) The right to request the rectification of your personal data – you can manage some of this information in your account.
You can exercise these rights through your account or by contacting customer services.
You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO).
Personal information is collected by Private Equity Africa Limited on behalf of its group of companies and its trading entities.
Our Sites are not intended for children under 16 years of age. We do not intentionally collect or use any information from children.
If you have a query in regards to the processing of your personal information, please contact us at email@example.com
The Private Equity Africa Ltd
Registered Office: 20- 22 Wenlock Road, London, N1 7GU, United Kingdom
Registered Number: 08006014
This policy is effective from 24/05/2018.