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Euromoney Information Management Network LLC - Cookie Policy



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Cookies are pieces of information which include a unique reference code that a
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Some of the cookies used by our sites are set by us, and some are set by third
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*User Communication. To the extent permitted while using DirectConnect, you can
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You are solely responsible for your interactions with other users. IMN may limit
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or otherwise limit your use of the Services.

If you violate this Agreement while posting, that content may be removed without
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*Privacy. Any submissions, including private personal information, like names,
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any compensation of any kind from IMN under any circumstances.

*Content by Becoming a User of DirectConnect: As part of obtaining registration
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intentionally made available either by their public display on the Web Site or
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the website, data, materials, information, computer systems or networks
connected to any server, through hacking, password mining or any other method.

*No Linkage. You expressly agree not to link or attempt to link to this website
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*Third Party Information. Some of the information you access here is the
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*Copyright and Trademarks. The layout of the website pages, graphics and
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without limitation, reasonable legal and accounting fees) brought or made
against the Indemnified by any person arising in connection with your use of the
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Terms and Conditions of Use or this Agreement or any other activity in which you
engage on or through, and from and against any damage, loss(whether personal or
property, and whether direct or consequential, including without limitation
consequential financial loss), cost or expense suffered or incurred by any
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*Changes in Terms and Conditions. IMN may at any time revise the terms and
conditions by which you may access the website or use IMN products or services.
By using this website and IMN products and services, you agree to be bound by
any such revisions and should therefore periodically visit this page to
determine the then current version of this document.

*Limitation of Liability. Neither we, nor any of our suppliers, officers,
employees, partners, affiliates, subsidiaries, successors and assigns, agents or
representatives (our "Representatives") will be liable to you for:

(a) any incidental, punitive, indirect, special or consequential damage, loss or
expenses, including but not limited to any loss of business, contracts, revenue,
or profits, any business interruption, security breach, loss of data, loss of
goodwill or reputation or other pecuniary loss suffered by you, even if we or
any of our Representatives have been advised of their possible existence; nor?
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profits, loss of anticipated profits or loss of savings.

*Termination. You may terminate this Agreement, for any or no reason, at any
time, when IMN receives notice from you. IMN may terminate the Agreement and
your account for any reason or no reason, at any time, with or without notice.
This cancellation shall be effective immediately or as may be specified in the
notice and may include disabling your current and future access to
DirectConnect. IMN may also suspend or terminate this Agreement if you invite
other users with whom you do not know to connect; abuse the any DirectConnect
messaging services; creating multiple or false profiles; infringe on any
intellectual property rights, violating any provisions in this Agreement,
disparage IMN or its executives, Board members, affiliates, staff or other
related entities or persons, or exhibit any other behavior that IMN, in its sole
discretion, deems contrary to the purpose of the website.

*No Waiver. Failure by either party to exercise any right or remedy under these
Terms does not constitute a waiver of that right or remedy.

*Entire Agreement. These terms (including any terms incorporated by reference in
these terms), constitute the entire agreement between you and us with respect to
your access to and use of the website or receipt of any service and supersede
all prior agreements, negotiations and discussions between you and us relating
to the same.

*Law and Jurisdiction. Where you visit, register and/or subscribe to a this site
or related service (as indicated on this website or otherwise notified to you),
these terms (and any dispute or claim arising out of or in connection with these
terms, including non-contractual disputes or claims), to the maximum extent
permissible under the law of the territory that you are located in, will be
governed by the laws of the State of New York. Any action to enforce these terms
shall be brought in a federal court or a state court located in the state of New
York, county of New York, and you agree to submit yourself to the personal
jurisdiction of those courts in any such action.

*Force Majeure. We shall not be deemed to be in breach of these Terms by reason
of any delay in performing, or any failure to perform any service or our
obligations in relation to these Terms, if the delay or failure was due to any
cause beyond our reasonable control, including but not limited to acts of God,
explosions, floods, fire or accident, war or threat of war, terrorism or threat
of terrorism, sabotage, civil disturbance, epidemics, prohibitions or measures
of any kind on the part of any governmental, parliamentary or local authority,
import or export regulations or embargoes, or industrial actions or trade
disputes (whether involving our employees or of third parties).

*Severability. If any provision of these Terms is found to be wholly or
partially invalid, void or unenforceable by any court having competent
jurisdiction or by virtue of any legislation or any other reason, that provision
shall be invalid, void or unenforceable to that extent only and no further and
the validity and enforceability of the remaining provisions of these Terms shall
not be affected.

*Notices. Any notice given pursuant to these Terms shall be made by email or
first class post, in the case of you, to the address provided on your
registration form and, in the case of us, to the address posted on the website
or otherwise notified to you in relation to any relevant service. Any such
notice shall be deemed to have arrived if sent by post within three (3) days of
posting and if sent by email at the time of transmission.
Information Management Network - Privacy Notice


Introduction - Who we are

Euromoney Institutional Investor PLC (“Euromoney”, “we”, “us” or “our”) is an
international business-information group covering asset management, price
discovery, data and market intelligence, and banking and finance. The group also
runs an extensive portfolio of events for the telecoms, financial and
commodities markets.

For a full list of our brands and group companies, please click on this link.
Euromoney and its group companies are committed to respecting the privacy of
every person who visits, registers with or subscribes to our websites,
publications, events and other products or services.

Euromoney is the primary data controller of personal data collected through this
website or that we may collect in different ways as described in this Privacy
Notice. If you are contacted by our other group companies, they will also be
controllers of your personal data. This means that they are responsible for how
your personal data is used, just as we are. You may contact any of these
companies directly, or you can contact Euromoney by emailing
dataprotectionofficer@euromoneyplc.com or writing to the Data Protection Officer
at Euromoney Institutional Investor PLC, 8 Bouverie Street, London EC4Y 8AX,
United Kingdom.

This Privacy Notice was updated on 23 May 2018

Our Approach to Your Privacy

This Privacy Notice outlines the information we may collect about you in
relation to your use of our products and services (“personal data”). It also
explains the legal rights that you have in relation to your data and how you may
exercise these rights.

Some of our group companies may collect and use personal data for different
purposes; those companies have their own websites and privacy notices.

We will process your data for the following lawful purposes: with your consent;
to fulfil our obligations to you; and where there is a legitimate interest to do
so.

When possible, we rely on your consent to use your data for the purposes
described in this Privacy Notice. We also process personal data to fulfil our
contractual obligations to you, for example, when you register for any of our
services, subscribe to a publication, sign-up for an event or purchase a product
from us, we will need to process some of your personal data. This will also
include details of the person/people responsible for payment (if different).

We may determine that processing your personal data serves both of our
legitimate interests. This is the case in relation to many of our research,
customer survey, sales, marketing and advertising activities described in this
Privacy Notice. These activities allow us to better understand your
requirements, which in turn enables us to provide you with a better service. We
review the bases for our processing decisions carefully and you can object to
these activities at any time (see the “Your Rights” section of this Privacy
Notice).

What Personal Data We Collect & Why

Our primary goal in collecting personal data from you is to give you a relevant
customised experience of our products and services.

 * REGISTRATION, FREE TRIALS & SUBSCRIPTIONS
   
   When you register with our website and/or sign up for a free trial of our
   products or services, we may ask you to provide your name, address, email
   address and telephone number, and details relevant to your occupation or
   employer.
   
   If you subscribe to one of our products or services, we will also ask for
   payment details. Credit/debit card payments are processed using a third party
   supplier and we do not retain the credit card data (see the Third Party Sites
   of this Privacy Notice). Address details may be shared with third party
   service providers engaged by us for order fulfilment, delivery and payment
   collection. This personal data is used by us to complete subscription
   requests.

 * EVENTS & CONFERENCES
   
   If you have registered for an event through a group website we may collect
   personal data including: name, job title, company, address, telephone number
   and email.
   
   This information is necessary so that we can complete your registration for
   the event and provide you with relevant event materials.
   
   We may also provide delegate details (e.g. name, email) to event sponsors
   who, subject to your consent, may contact you for their own advertising and
   marketing purposes.

 * ADVERTISING & MARKETING
   
   We use the personal data you provide us and which we collect from you to
   inform you about similar products and services which we provide. We may send
   you marketing communications that are sponsored by our partners and which are
   targeted to your interests based on information you have provided us such as
   job title, employer and/or industry. If you have consented to receive
   information from other Euromoney group companies, we may share your personal
   data with these companies so that they can fulfil your request to receive
   marketing materials in accordance with your preferences. We will not share
   your personal data with any third parties for their own marketing purposes
   unless you have provided your consent.
   
   Each of the Euromoney group companies that may contact you is a data
   controller in relation to the personal data that you have agreed to share
   with them. If you have any questions or concerns, you may contact the
   individual company, or us – using the contact details set out in the “Who We
   Are” section.
   
   You can opt out from receiving such materials at any time.
   
   The personal data we may use for advertising and marketing purposes includes
   your name, email address, job title, phone number, company name/employer, geo
   location, postal address and data collected using cookies and other similar
   technology (Please read our separate Cookies Policy to find out more about
   which cookies we use, how they work and how you can control your cookie
   options).
   
   Marketing materials are sent electronically, by post and we may occasionally
   call you.

 * ONLINE TARGETED ADVERTISING
   
   We use targeted advertising on our websites to display advertisements that
   are relevant to what we believe are your interests. In order to deliver
   relevant advertisements, we use third parties to deliver cookies that collect
   information about your IP address and how you interact with our sites (e.g.
   browsing information, which articles you have read etc.). This data is used
   by the third parties to determine which advertisements may be of interest to
   you.
   
   We may also share your personal data with third parties to deliver targeted
   advertising to you on other websites (e.g. Twitter Tailored Audiences or
   Facebook Custom Audiences). This could include your email address, cookie
   data, and information obtained from third parties. Third party cookies may
   also be used to enable us to target advertisements to you on other websites
   that you visit.

 * LEAD GENERATION AND SCORING
   
   We occasionally use the services of trusted third parties in order to ensure
   that the personal data we use for advertising and marketing purposes is
   accurate and up-to-date. To do this, we transfer personal data of individual
   leads (such as name, email, job title, location and phone number) to these
   third parties who conduct research to verify the data – primarily against
   public information.
   
   We also use algorithmic software technology to help us improve the quality
   and relevance of marketing activities. The personal data analysed by the
   software includes email address, phone number, job title, address, purchase
   history and account information. This allows us to provide meaningful offers
   that are relevant to your specific profile.

 * SURVEYS, MARKET RESEARCH & CUSTOMER FEEDBACK
   
   We want to understand the needs of our readers and customers. We may
   therefore use the information you provide us – including your name and
   contact details – to contact you to request your feedback, or to participate
   in our customer and market research.

 * PUBLIC FORUMS, MESSAGE BOARDS AND BLOGS
   
   Some of the pages on our group websites may include message boards, blogs or
   other facilities for generating content from users. Any information that is
   disclosed in these areas becomes public information and you should always be
   careful when deciding to post any personal data. User generated content is
   also subject to our site Terms & Conditions.

 * BUSINESS OR ASSET SALE
   
   If we sell a business or assets we may need to disclose your personal data to
   the prospective buyer of such business or assets.
   
   If Euromoney, or any of our group companies is sold or sells our assets or is
   acquired by a third party, then personal data about our customers will be
   acquired by that third party. A transfer of your personal data in these
   circumstances would be necessary so that the services you have contracted for
   can still be delivered, or so that you can continue to enjoy the benefits of
   our free products and services. You will receive notice if a new controller
   assumes responsibility for your personal data.

 * ADDITIONAL THIRD PARTY DISCLOSURES
   
   We may disclose your personal data to other third parties in the following
   situations:
   
   * To third party partners who help us by providing services such as
     technology, marketing, advisory or other services. These third parties only
     receive encrypted data and may only process personal data to provide those
     services to us.
   * Where we are required by law or regulation to do so. In each case we will
     seek, where practicable, to minimise the amount of data that is disclosed.
   * If required to protect the rights and interests of other users and/or
     Euromoney and its affiliates (including our employees, agents and
     contractors), or as otherwise set out in our Terms & Conditions. This may
     include exchanging information with other companies and organisations for
     the purposes of fraud protection.

 * EMAIL TRACKING
   
   We may include small pixel tags (small image files) within the emails we send
   you in order to determine whether our emails are opened and/or whether the
   hyperlinks inside our emails are clicked through. We may also collect
   browser, location and the device used to engage with our email
   communications. This information allows us to better understand whether we
   are meeting our users’ needs and how we can improve our communications. No
   other information is collected. You can opt out of receiving our direct
   marketing emails either by following the instructions in each email, or by
   contacting us (see the “Who We Are” section of this Privacy Notice).

International Transfers

Some of the Euromoney group companies are based outside the European Economic
Area (EEA). If you have consented to being contacted by our group companies,
then the transfer of your personal data will be made according to the terms of
an international data sharing agreement that contains obligations approved by
European data protection regulators. Any of our group companies that receive
your personal data will be co-controllers of that data, which means they may
determine how they process your personal data – although they may only use it
for the purposes for which it was shared, unless you are informed of new or
additional processing activities.

We may also transfer personal data to third party service providers as described
in this Privacy Notice which are located outside the EEA. Where we conduct these
transfers, we take all steps necessary to ensure that your data is treated
securely and in accordance with applicable privacy legislation, either by only
sending your personal data to jurisdictions that provide an adequate degree of
legal protection for your data or by imposing approved contractual terms on
these third parties.

Retention Periods

We have a data retention policy that ensures we don’t use or store your personal
data for longer than necessary. We consider the following issues to determine
retention periods:

 * Guidance from the UK Information Commissioner or other regulatory agency, or
   industry best practice recommendations;
 * The business rationale for collection and expiry of the purpose for which
   personal data was collected;
 * Our ongoing ability to ensure the accuracy of the data; and
 * Legal and regulatory requirements.

We may occasionally need to keep personal data for either shorter or longer
periods than specified in our retention policy. In such circumstances,
application of the retention period to the data will be temporarily suspended.
The suspension of an applicable retention period will be carried out in a manner
that respects the rights and interests of all persons concerned.

How You Can Set Your Data & Privacy Preferences

You can use our Preference Centre to select the topics that are of interest to
you so that we can send you publications and information about our products and
services that are especially relevant to you. You can also choose the channels
we use to contact you (email, phone, post, etc.) and can also opt-out of
receiving marketing communications.

Your Rights

You have certain rights in relation to your personal data which include the
following:

 * ACCESS & PORTABILITY
   
   You may request access to any personal data of yours for which Euromoney is
   responsible as controller. Unless there are legal or regulatory reasons for
   not doing so, we will confirm whether we process any of your personal data
   and if we do, we will provide you with the following information: the
   purposes of the processing, the categories of personal data, any recipients
   of your personal data, the applicable retention period and the data source.
   Copies of your personal data will be made available to you in a structured,
   machine-readable format.
   
   You may also request that we transfer the personal data that you have
   submitted to us, to another controller, where it is technically feasible for
   us to do so.
   
   If you have consented to our processing of your personal data, or if we are
   processing your personal data in order to fulfil our contractual obligations
   to you, then you can submit a request that we transfer your personal data to
   another data controller.

 * RECTIFICATION, RESTRICTION, OBJECTION
   
   You have the right to request that Euromoney rectify any errors in the
   personal data that we process. In some circumstances, you may also be able to
   ask for the erasure of personal data, and/or request that the processing of
   your personal data be restricted. You may also object to the processing of
   your personal data for sales or marketing purposes.

 * HOW TO EXERCISE YOUR RIGHTS
   
   To exercise any of these rights, please contact us by post or email at the
   following addresses:
   
   Euromoney Institutional Investor PLC
   8 Bouverie Street
   London, EC4Y 8AX
   United Kingdom
   
   Email: dataprotectionofficer@euromoneyplc.com
   
   Web form: Complete Subject Data Request Form
   
   We may need to check your identity prior to processing a request.
   
   Euromoney will do our best to respond to any questions and address any of
   your concerns. You are also able to register any complaints regarding the
   processing of your personal data directly with the UK Information
   Commissioner.

Protecting Your Data

Euromoney is committed to keeping your personal data secure and we will take
appropriate technical and organisational measures to protect your personal data
from loss, unauthorised use, disclosure or destruction. Although we do our best
to protect your personal data, we cannot guarantee that any transmission of data
is without risk. We have therefore implemented information security policies and
rules, staff training on information security, and technical measures to ensure
the integrity of data that we have under our control.

All our employees, contractors and data processors (i.e. those third parties
that process personal data on our behalf) are required to keep such data
confidential and not to use it for any purpose other than the performance of
services we have requested.

Third Party Sites

Our site may contain links to other websites – including, for example, providers
of payment processing services. Euromoney is not responsible for the privacy and
data collection practices of third party sites and we therefore recommend that
you review the privacy policies and terms of service of each site you visit.

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