Field Gibson Media Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites as well as your privacy rights and how the law protects you. The websites covered by this privacy notice are as follows: www.environmental-finance.com, www.insuranceerm.com, www.insuranceassetrisk.com, www.corporatedisclosures.org, www.insuranceriskdata.com, www.fieldgibsonmedia.com and www.efdata.org ("Websites").
1. Important information and who we are
Controller
Field Gibson Media Limited of Pentagon House, 52-54 Southwark Street, London SE1 1UN, registration number ZA098022 is the controller and responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).
Contact details
If you have any questions about this privacy notice or how we protect or use your personal data, please contact our Data Protection Officer. The Data Protection Officer can be contacted as follows:
Email: [email protected]
Post: Data Privacy Officer, Field Gibson Media Limited, Pentagon House, 52-54 Southwark Street, London SE1 1UN
You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on 3 November 2020.
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.
Third-party links
The Websites may include links to third-party websites, 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 websites and are not responsible for their privacy statements. When you leave our Websites, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
"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:
- Identity Data includes title, first name, last name and username or similar identifier.
- Contact Data includes email address and telephone number.
- Financial Data includes payment card details (we comply with all requirements of the Payment Card Industry Data Security Standards (PCI DSS) with respect to the storage, processing and transmission of payment card data).
- Transaction Data includes details about payments from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Websites.
- Profile Data includes your username and password, purchases made by you, your interests, preferences and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to evaluate our "most read" articles. 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 policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms 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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our Websites;
- set up a trial subscription to our service or publications;
- subscribe to our service or publications;
- supply information for publication on our Websites;
- complete an enquiry form;
- request marketing to be sent to you;
- participate in surveys or research; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
- Publicly available information. We may collect your corporate contact details from publicly available sources such as the website of your company on the internet.
4. How we use your personal data
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:
- Performance of a contract: where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: where it is necessary for our legitimate interests (or those of a third party) e.g. in the interest of conducting and managing our business to give you the best service and the most secure experience. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Legal compliance: where we need to comply with a legal obligation.
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. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
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.
| Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you for a trial subscription or to register you as a new subscriber |
|
Performance of a contract with you |
To process and deliver your order including:
|
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|
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To manage our relationship with you which will include:
|
|
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| To administer and protect our business and the Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
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| To provide reports to our clients containing information about usage under corporate licenses |
|
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) |
| To publish information you have supplied to us on the Websites, where you have supplied information to us for such purposes |
|
Necessary for our legitimate interests (for running our business) |
| To enable us to deal with any complaints or queries raised by you |
|
Necessary for our legitimate interests (to improve our services) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
|
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Websites (e.g. by ensuring content is presented to you most effectively), services, marketing, customer relationships and experiences |
|
Necessary for our legitimate interests (to define types of customers for our services, to keep our Websites updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about services that may be of interest to you |
|
Necessary for our legitimate interests (to develop our services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can amend your marketing preferences at any time by contacting us.
You will receive marketing communications from us if you have requested information from us, registered for a trial subscription or purchased a subscription from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for general marketing purpose. When it comes to the management and organisation of events and conferences, we may share your personal data with our sponsors, partners and co-organisers if we deem it legitimate interest and beneficial to operating of the event in the virtual environment.
Opting out
You can ask us or third parties to stop sending you marketing messages about a particular event or certain news alerts at any time by following the opt-out links on the relevant marketing message sent to you. Alternatively you can unsubscribe from all marketing messages by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transaction.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Websites may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
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 us.
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.
5. Disclosures of your personal data
We may share your personal data with the persons set out below for the purposes set out in the table above.
- Lead sponsors at events where you are a delegate.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you provided that you have consented to such data sharing.
- Analytics and search engine providers that assist us in the improvement and optimisation of the Websites.
- Service providers who provide IT and system administration services based in Croatia.
- Payment processing service providers.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK.
- HM Revenue & Customs and other UK authorities or regulators whom require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
6. International transfers
Some of our service providers are based outside the European Economic Area ("EEA") so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has inside the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
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.
8. Data retention
How long will you use my personal data for?
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
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 (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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please contact us.
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 a 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 legitimate grounds to process your information 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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
Further information about your rights
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.