PRIVACY AND COOKIES POLICY
Updated: November 12, 2020
This Privacy and Cookies Policy aims to give you information on how we collect and processes your personal data through your use of the Site.
The Site is not intended for children or under age individuals (as they are defined in the laws of applicable jurisdictions) and we do not knowingly collect data relating to children. By accepting this Privacy and Cookies Policy you acknowledge that you are of the age of majority in your domicile jurisdiction.
It is important that you read this Privacy and Cookies Policy together with any other privacy and cookies policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
We have appointed a data privacy officer who is responsible for overseeing questions in relation to this Privacy and Cookies Policy. If you have any questions about this Privacy and Cookies Policy, including any requests to exerciseYour Legal Rights, please contact the data privacy officer by email at firstname.lastname@example.org.
The Site may include links to third-party sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Sites and we are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy and cookies policies of every site you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not and cannot not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookies Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms and conditions of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to Subscriber only content).
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new Subscriber
Performance of a contract with you
To enable you to join the Chat
Performance of a contract with you
To enable you to browse and access the content on the Site
Necessary for our legitimate interests (to make the Site to browsers)
To enable you to browse and access the Subscriber only the content on the Site
Necessary for our legitimate interests (to make the information on the Site available to users and Subscribers)
To send you marketing emails about our content, services and offers
Marketing and Communications
With your consent
To make suggestions and recommendations to you about information or services that may be of interest to you
Marketing and Communications
Necessary for our legitimate interests (to develop our content/services and to provide more relevant information to you)
To manage our relationship with you which will include:
· Asking you to leave a review or take a survey
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how our Site users use our content/services)
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Necessary for our legitimate interests (for running our organization, provision of administration and IT services, network security, to prevent fraud and for use in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with our legal obligations
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Marketing and Communications
Necessary for our legitimate interests (to study how users’ and Subscribers’ use our content/services, to grow our content and expand our services, to grow our organization, and to inform our marketing strategy)
To use data analytics to improve our Site, products/services, marketing, user relationships and experiences
Necessary for our legitimate interests (to define types of users for our content and services, to keep our Site updated and relevant, to develop our organization and to inform our marketing strategy)
To enable us to monitor your browsing habits by placing cookies onto your device
With your consent
To enable us to provide you with access to our social media channels such as Facebook, Instagram, Slack, LinkedIn or Twitter
Necessary for our legitimate interests (to develop our content/services and grow our organization)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Additionally, you can review and revise your marketing and communication preferences by contacting us at email@example.com or following the opt-out links on any marketing message sent to you.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a browsing the Site or other transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties and for the purposes set out below:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our Subscribers (including Contact, Identity) for six years after they cease being Subscribers.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data, including your Aggregated Data, (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Certain cookies and identifiers are conveyed and controlled by us directly. We collect and process your personal data by means of these cookies and identifiers. To the contrary, other cookies and identifiers are conveyed and controlled by third parties, over which we have no control. We hereby invite you to read such cookies policies of the third parties carefully.
The cookies are small text files that Sites visited by a user send directly to its terminal (usually, to the browser), where they are memorised to be transmitted to the same Sites at the following visit of the same by the same user (the so called proprium first party cookies). During the surfing of a Site, a user may receive on its terminal also cookies of other Sites or of other web servers (the so called third parties cookies); this happens because there may be elements on the visited Site, such as images, maps, sounds, links to specific web pages of other domains that are on servers other than the server on which the requested page is placed. In other words, such cookies are set up on a Site other than the one that is currently visited.
The cookies may have a duration limited to a single session of navigation on the browser (called session cookies), and, in such event, they deactivate automatically once the browser is closed by the user; or may have a predetermined duration and, in such event, they will remain memorised and active on your hard disk until the expiry date, thus continuing collecting information during different sessions of navigation on the browser (the so called permanent cookies).
The cookies are used for several purposes. Certain cookies are necessary in order to allow you to surf the Site and benefit of its functionalities (the so called technical cookies). Other cookies are used in order to obtain statistical information, whether in aggregate or not, about the number of users accessing the Site and how the Site is used (called monitoring cookies or analytics). To the end, other cookies are used in order to track your Subscribers account and allow you to view advertisements that may be of interest to you (called profiling cookies).
You can find more information about the individual cookies we use on the Site and the purposes for which we use them in the table below:
This cookie is essential for the Site to operate. It allows us to synchronise your login status between the forum section of the Site and the other sections of the Site.
This cookie is essential for the Site to operate. It allows us to remember your details during your current visit to the Site. Most of the cookies we use are known as session cookies. These cookies expire whenever you close your browser or shut down your computer.
This cookie is a functionality cookie which automatically logs users in if their “session” cookie has expired. This allows you to navigate away from the Site and then return to the Site in the same browsing session.
This cookie is a functionality cookie which records the time at which you were last active on the forum section of the Site. This is used to update your public profile on the forum.
This cookie is a functionality cookie which records the time of your last visit to the Site. This allows us to bring updates which you may have missed to your attention.
This cookie is a functionality cookie which remembers your password in order to automatically log you into the forum sections of our Site if you have already logged into your account.
This cookie is a functionality cookie which remembers your user ID in order to automatically log you into the forum sections of our Site if you have already logged into your account.
This is an analytical / performance cookie. The Site uses Google Analytics to help analyse how users use the Site, collecting standard internet log information and visitor behaviour information in an anonymised form from which no user is identifiable. This information is transmitted to Google and processed to compile statistical reports on activity on the Site. These reports allow us to optimise our user experience. Google provide a browser add-on for users who wish to prevent their data from being used by Google Analytics. Further information is available at https://tools.google.com/dlpage/gaoptout/.
You can manage, disable and remove the cookies. To do so, please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies.
Please be careful in making your choice. By blocking the receipt of all the cookies indiscriminately, including the technical ones, without providing a specific exception for the Site, you may no longer able to surf the Site or to benefit, in whole or in part, from its functionalities. Furthermore, removing the technical cookies could remove the preferences set up by using the Site.
In order to disable the third parties cookies or identifiers, please see the privacy policies of those third parties.
You have rights under data protection laws in relation to your personal data. In particular, you have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on our legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling lawful grounds to process your personal data which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of Your Legal Rights, please contact our data privacy officer at email@example.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to the Privacy and Cookies Policy and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We keep our Privacy and Cookies Policy under regular review.