LAST UPDATED: 24 May 2018
THE PERSONAL INFORMATION WE COLLECT, AND HOW WE COLLECT IT
“Personal Information” is information that identifies you, or by which you could be identifiable, or which relates to you as an individual.
We collect a set of Personal Information from you (or your employer or the organisation you work for) in order to provide the Services, including your name, company and email address. If you do not provide the information requested we may not be able to provide the Services to you. We may also collect further information in the course of providing the Services, some of it being Personal Information, in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that the Services function properly.
- Through your use of the Apps: When you download and use an App, we may track and collect App usage data, such as the date and time the App on your device accesses our servers, the pages you use and what information and files have been downloaded to the App based on your device number.
- Using cookies: Cookies are pieces of information stored directly on your computer. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to personalise your experience while using the Services and to recognise your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions about them. At this time, we do not respond to browser do-not-track signals.
- Using pixel tags and similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users (including email recipients) and compile statistics about use of the Services and response rates.
- IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your internet service provider. An IP address may be logged automatically in our server log files whenever you access the Services, along with the time of the visit and the pages visited. Collecting IP addresses is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
- From you (or your employer or the organisation you work for): We collect information such as your industry, job title/role, division and region when you (or your employer or the organisation you work for) provide it voluntarily.
- By aggregating information: Aggregated Personal Information does not personally identify you (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
We may collect any of the above information in order to, or in the course of, providing the Services to you.
Whether or not we provide Services to you, we may collect Personal Information about you to create a profile of you on the BoardEx database. All the information comprising BoardEx profiles is obtained by us or our affiliates from public sources.
We may also collect or create your relationship preferences by way of our relationship mapping services, which are the connections that you or we identify you as having with individuals listed within the Services (e.g. former colleagues, clients, or profiles on the BoardEx database). Your relationship preferences are visible only to you and other users of the Services within your organisation, subject to any controls set by your organisation. We do not use your relationship preferences other than to customise the Services for you and your colleagues within your organisation. We are data processors of the Personal Information you send to us, and the Personal Information we aggregate by way of relationship preferences, when we provide these relationship mapping services.
HOW WE USE PERSONAL INFORMATION
We use Personal Information to provide the Services, and that may include one or more of the following activities:
- To respond to your enquiries and fulfil your requests, such as to send you newsletters and alerts about the Services or to facilitate your participation in a webinar or other event.
- To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.
- To provide you with customer service.
- To personalise your experience on the Services by presenting products and offers tailored to you.
- To request your participation in surveys and to administer such surveys.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- At your request, to match your contacts when providing the relationship mapping services, solely to establish and notify you of any matches.
If we create a profile for you on the BoardEx database, our purpose is to make that profile available to subscribers of the Services to view.
We share Personal Information with our affiliates to perform the activities set forth above.
We must have a lawful basis on which to process your Personal Information. If you use the Services in a personal capacity, or as a sole trader or partner of an unincorporated organisation, we process your Personal Information where necessary to comply with our contract to provide the Services to you. In all other cases we process your Personal Information on the basis that it is in our legitimate interests, and in the legitimate interests of your employer or the organisation you work for, to process your Personal Information in order to provide the Services and to carry out the activities referred to above, including, if applicable, creating a profile on the BoardEx database.
We may in addition, and on occasion, be required to process your Personal Information in order to comply with a legal obligation, or on the lawful basis of protecting and enforcing our rights.
HOW PERSONAL INFORMATION IS DISCLOSED
Your Personal Information may be disclosed:
- To our affiliate businesses TheStreet, Inc., The Deal LLC, The Deal India Private Limited, and BoardEx, LLC for the purposes of inclusion of your profile in the BoardEx database, if appropriate, or for marketing purposes.
- To our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- To identify you to anyone to whom you send messages through the Services.
- To a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- BoardEx profile information may be disclosed to our third party partners with whom we have a sublicensing or content sharing arrangement in place.
We ensure that all third party service providers who process Personal Information on our behalf do not make any use of Personal Information except in the course of providing their services to us.
We also may use and disclose your Personal Information to supervisory and/or other authorities as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
TRANSFERS OF PERSONAL INFORMATION OUTSIDE THE EEA
We may transfer your Personal Information outside the EEA in the following circumstances:
- Where we share Personal Information with our group companies in the United States and elsewhere for the purposes described above.
- Where our third party data processors are based outside, or process data outside, the EEA.
- When subscribers to the Services based outside the EEA access profiles on the BoardEx database.
All transfers of Personal Information outside the EEA are carried out under contracts which contain appropriate restrictions and safeguards. In the case of our group companies which are themselves controllers of the Personal Information they share, because they make certain uses of the Personal Information as described in the section ‘How we use Personal Information’ above, we include the standard data protection clauses approved for this purpose by the European Commission in its decision 2004/915/EU, which may be accessed via this link: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915. In the case of third party data processors (including group companies) who process Personal Information under our complete control we include the standard data protection clauses approved for this purpose by the European Commission in its decision 2010/87/EU, which may be accessed via this link: http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087. If any US data processor is self certified under US/EU Privacy Shield (https://www.privacyshield.gov/welcome) we rely on that certification in place of the standard clauses.
THIRD PARTY SERVICES
In particular, we are not responsible for the information collection, use, disclosure or security policies or practices of other organisations, such as Facebook, Apple, Google, Microsoft, or any other app developer, social media platform, operating system or wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organisations through or in connection with the App.
We use appropriate organisational, technical and administrative measures designed to protect Personal Information within our organisation. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services. These service providers apply security measures that we consider adequate for the protection of information within their systems, taking into account the nature of the Personal Information they process.
If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
If at any time you no longer want to receive marketing-related emails from us, you may opt out by following the instructions contained in each such email or by contacting us at [email protected]. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing messages we may still send you important administrative messages concerning the Services.
You have the following rights under data protection legislation. If you have any questions about your rights, or you wish to exercise any rights, please email us at [email protected].
Information Access: You have the right to access and receive a copy of the Personal Information we hold about you, including details and purposes of the processing, those to whom your Personal Information is disclosed, and other information that we are obliged to give you about our processing. If you wish to access any of your Personal Information please contact us giving details of the information you require.
Information accuracy: We have an obligation to keep the Personal Information we hold accurate and up to date. We encourage you to notify us as soon as possible in the event of any change to your Personal Information. If you would like to correct and/or update the Personal Information we hold in relation to you as an account holder for the Services, you may do so by logging into your account, or contacting us at the email address above. If you would like to correct or update the information that we hold about you in our BoardEx database please contact us as above, making clear what Personal Information you would like to have changed. We will make any corrections or updates that come to our attention and which we have confirmed to be accurate.
Information Erasure: You have the right to ask that we erase your Personal Information (the ‘right to be forgotten’) in certain limited circumstances. We will let you know if any of those circumstances apply on request.
Restriction on processing: You have the right to restrict us from processing your Personal Information if:
- You believe the Personal Information we hold about you is inaccurate, while we investigate the inaccuracy; or
- Our processing is unlawful, or no longer necessary; or
- You object to our processing but we believe we continue to have the right to process, while the right is verified.
Information Portability: In certain limited cases you may have the right to require us to transfer the Personal Information we hold about you to a third party in machine-readable format. Please contact us to find out whether your right applies.
Right to object: If at any point we process your Personal Information on the basis of our legitimate interests, or on the basis that it is in the public interest, you have the right to object to that processing. In any event, you have the right to request that we do not use your Personal Information for any direct marketing purposes.
Automated decision-making: Finally, you have the right not to be subject to a decision based solely on automated decision-making that has significant prejudicial effect on you. We do not take any such decisions on this basis.
NO USE OF SERVICES BY MINORS
The Services are not provided for or directed to individuals under the age of eighteen (18). We do not knowingly collect Personal Information from such individuals, and we request that they do not provide Personal Information through the Services or otherwise.
We ask that you do not send us, and you do not disclose, any sensitive Personal Information (i.e. information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, sex life or sexual preferences, or trade union membership) on or through the Services or otherwise to us. We do not knowingly process any sensitive information unless that information has been clearly and demonstrably made public by you, in which case it may appear in a profile, if applicable, on the BoardEx database.
If you have any questions, please contact us by email at [email protected] or by phone at:
Because email communications are not always secure, please do not include credit card or other valuable information in your emails to us.