Privacy & Cookie Policy
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LibertyRoad Limited (“LRL“) is committed to the privacy and confidentiality of the information provided by its users. In this Privacy & Cookie Policy, the term “Personal Data” refers to personally identifiable information about you, such as your name, date of birth, e-mail address or postal address, and also includes online identifiers such as your IP address and URLs.
SCOPE OF PRIVACY & COOKIE POLICY
This Privacy Notice & Cookie Policy describes LRL’s policies and practices with regard to Personal Data and sets out how LRL collects and shares your Personal Data. This Privacy Notice & Cookie Policy applies to current and former customers and suppliers, and third-party customers and suppliers where personal information is processed to enable LRL to provide its products and services – please read it carefully.
This Privacy & Cookie Policy applies to all websites and web applications which link to this policy and are published by LRL (“Sites“).
Please note that by submitting Personal Data manually or in electronic form to us and/or by allowing us to automatically collect your Personal Data by consenting to the use of cookies when using our website, you acknowledge that all Personal Data submitted on each occasion may be lawfully processed by, and/or shared by LRL with our affiliates and third-party suppliers, in the manner, for the purposes, and on the lawful bases described in this Privacy & Cookie Policy.
WHO WE ARE AND HOW TO CONTACT US
In this Privacy & Cookie Policy, references to “us” or “we” are to LRL.
We are a company registered office at Aleman, Cordero, Galindo & Lee Trust (BVI) Limited,
3rd Floor, Yamraj Building, Market Square,
P.O. Box 3175, Road Town, Tortola,
British Virgin Islands.
Tel: +33 6 78 63 10 62
Email: info@libertyroadcapital.com
If you have any questions about how we collect, store or use your personal information, or if you would like to update the Personal Data we hold about you, update your marketing preferences, or exercise any of your rights under the data protection legislation (as detailed in section 11 below), you can contact us at any time by writing to us at the address above or by contacting our Data Protection Officer at info@libertyroadcapital.com.
PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
This section details the Personal Data we may collect about you. We explain why, how and on what lawful bases we process it in later sections.
Account information
If you decide to create an account or enquire about one of our products or services, we’ll ask you to provide us with some Personal Data, including:
- basic personal details – such as name and title;
- employment information – such as job title, company name, company address, work email address and office phone number;
- personal contact details – such as email address and phone number;
- log in details – such as username and password; and
- payment details – such as your bank account and payment card information.
Personal Data we obtain from third-parties
In some circumstances, we collect Personal Data about you from our partners, from publicly available websites, from current and former customers and contacts (for instance as referees for our research), and third-party customers and suppliers, to help us expand and better understand our audience and enhance the relevance of our content. For example, in some cases we obtain the contact details of potential contributors to our events and publications from public websites.
LAWFUL BASIS FOR PROCESSING
We only process Personal Data where we have a lawful basis for doing so, including the following:
- User consent:this refers to where you have given us explicit permission to process personal information for a given purpose. For example, by using our website and consenting to our cookies you give consent that we may obtain certain Personal Data about you, including your IP address and certain user preferences (see section 12 below for more information).
- For our legitimate business purposes:this covers where we have a legitimate interest, as a business, to process Personal Data. For example, to manage inquiries and requests or to provide you with information about our business.
- For contractual necessity:this covers situations where we must process Personal Data 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.
- For compliance with a legal obligation:this covers situations where we must process Personal Data in order to comply with the law; we may share your information with third-parties such as regulatory authorities, or where we are under a legal obligation to disclose your information (for example where we are required to share information in accordance with legislation, to prevent fraud and other criminal offenses, or because of a court order). We may disclose your information in order to enforce our legal rights or to protect the legal rights of us or others.
HOW WE USE YOUR PERSONAL DATA
We collect Personal Data for the following reasons:
- to provide our service:we require some of your basic Personal Data so our services work as you would expect, for example so that we deliver our email briefings to your correct email address, provide you with access to our digital content, can send you hard copies of our products and notify you of any changes to our services and to enable us to deal with customer services queries. We will use the information you provide to us in order for us to provide you with a good service and to provide you with any information or assistance requested by you; we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In these circumstances, the legal basis for processing Personal Data is our legitimate interests in delivering a good service, providing you with information and retaining a record of this information;
- to produce our publications:we may use your Personal Data in order for us to produce our legal publications, such as ‘Who’s Who Legal’. Our legal basis for processing Personal Data here is our legitimate business interest in pursuing our business as an independent publisher;
- to improve and maintain performance: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 Data helps us understand how our readers use our websites. Our legal basis for processing Personal Data here is our legitimate interest in making improvements to our current products and developing new products;
- to bill our customers:we, along with our authorised payments processors, securely process your payment information to take payments, give refunds and to detect and prevent fraudulent activity. Our legal basis for processing Personal Data here is to fulfil our contractual obligations in accordance with our contracts with our customers and our legitimate business interest in ensuring we are paid for the products and services we provide;
- to monitor compliance with our terms and conditions:we monitor for breaches of our terms and conditions and copyright policies. For example, we reserve the right to monitor use to restrict unauthorised access to our Sites and to detect and prevent invalid or fraudulent traffic. Our legal bases for processing Personal Data here are the performance of our contracts with our customers and pursuing our legitimate business interest in preventing fraud;
- to personalise our products and services:we improve your experience of our products and services by personalising parts of our websites and apps with the information you give us and what we learn about you. Our legal basis for processing Personal Data here is our legitimate interest in providing an effective and personalised service provision to our customers; and
- to communicate product changes and offers:we want you to benefit from our new and existing products and services, including our content, events and newsletters. We will contact you with carefully-curated and relevant offers and promotions, exclusive event invitations and feature announcements. In these circumstances, the legal basis for processing Personal Data is our legitimate interest in providing you with information and retaining a record of this information. Please see section 9 below for more information on marketing. You are able to change your preferences at any time by contacting us via the contact details in section 2 above.
Where we intend to process your Personal Data for a purpose other than that for which it was originally collected, we will provide you with information on that other purpose and any relevant further information prior to such processing. Please note that we do not use Personal Data in automated decision-making processes.
HOW WE KEEP YOUR PERSONAL DATA SECURE
We have security measures in place to restrict access to Personal Data, to guard against unauthorised or unlawful processing of Personal Data and against damage to, accidental loss or destruction of, your Personal Data.
The security measures applied include storing your Personal Data on secure servers, encrypting transfers of Personal Data to or from our servers, and only granting access to your Personal Data where necessary.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA
We only keep your Personal Data for as long as necessary in relation to the purpose for which we are processing that information. 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 requirements.
We keep your Personal Data in accordance with our data retention policy. Where your personal information is no longer required we will ensure it is securely deleted.
DISCLOSURE TO THIRD-PARTIES
We will only share your Personal Data with third-party suppliers with whom we contract in order to pursue our legitimate interest in providing services to you, and to ensure the quality of the services we provide. This includes, but is not limited to, payment processors, email service providers, IT service providers, mailing houses, shipping agents and CRM providers. We will not release, rent or sell your Personal Data to third-parties for their own use, other than as part of a sale of the whole or a substantial part of the assets of LRL. We will take reasonable steps, such as the inclusion of contractual clauses in our contracts with such third-parties, to ensure that any third-parties who do receive and handle such Personal Data are bound by the same obligations as us and do not use such Personal Data for any other purpose.
We may disclose your Personal Data to third-parties if we buy or sell any business assets, in which case we may disclose your Personal Data to a prospective buyer or seller of such assets. If our company is bought by another company, the Personal Data we hold about you and our other registered users and customers will be one of the assets transferred when the company is sold.
We may also disclose your Personal Data if we are required by law to do so, for example, to the Police.
The Personal Data that we collect from you may be transferred to, and processed by, a processor based in a destination outside of the European Economic Area (“EEA“). If this happens we will take steps, such as the inclusion of contractual clauses into our contracts with such processors, to ensure that your Personal Data is safe and treated securely and in accordance with this Privacy & Cookie Policy.
You can contact us at any time via the contact details in section 2 above for details of specific disclosures made in respect of your Personal Data.
MARKETING
We would like to send you information about products and services of our and other associated companies which may be of interest to you. If you have opted-in to receive marketing information, you may opt-out at a later date.
You have a right at any time to stop us or any associated companies from contacting you for marketing purposes – if you no longer wish to be contacted for marketing purposes please contact us via the contact details in section 2 above or click on the ‘unsubscribe’ link at the bottom of any marketing email received from us.
YOUR RIGHTS
Under data protection legislation, as an individual you have rights in relation to the Personal Data we process which relates to you. These rights include:
- the right to access the Personal Data that we process about you;
- where our processing of your Personal Data is based on your consent, the right to withdraw your consent to such processing at any time;
- the right to object to direct marketing – your preferences, including in relation to direct marketing, can be amended by contacting us via the contact details in section 2 above or visiting our brand preference centres (please see section 9 above for more information on marketing);
- the right to restriction of processing or to object to the processing of your Personal Data;
- the right to request for us to transfer your Personal Data to a third-party in a standardised machine-readable format;
- the right to request the deletion of your Personal Data;
- the right to request the rectification of your Personal Data (you can also manage some of this information in the brand preference centres); and/li>
- the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO).
You can exercise these rights through the preference centres or by contacting our Data Protection Officer using the contact details above.
Our Sites are not intended for children under 16 years of age. We do not intentionally collect or use any information from children.
PERSONAL DATA WE OBTAIN THROUGH COOKIES AND SIMILAR TOOLS
Our Sites use cookies. Cookies are small text files placed on your device to collect standard internet log information and visitor behaviour information. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via e.g. the IP address) or the user. Cookies may contain information such as registration data and user preferences. This information is used to track visitor use of the website and to compile statistical reports activity. The cookies obtain generic information on your access to the website (not to its content) in order to provide us subsequently with aggregated information of such access for statistical purposes.
When a server receives a request from a device which stores a cookie from a website, the server is able to use the information stored in the cookie in combination with the information stored on the server to allow the website to respond to you as an individual and to tailor their operations to your needs, likes and dislikes by gathering and remembering information about your preferences. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files.
We may offer cookies to you and if you do not wish to receive them you should ensure that your web browser is set up to not accept cookies. Please note that if you disable cookies, some services or website functionality may not be available. We use the following cookies:
- Essential cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, and to use online forms.
- Analytical cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Marketing cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website, the advertising displayed on it and communications sent more relevant to your interests.
By continuing to use our Sites, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests and further help us to improve our Sites.
The information stored in the cookies from our Sites is used exclusively by us, except for those identified below as “third-party cookies”** (i.e. sometimes we embed video clips or similar content within articles from a third-party and this may mean third-parties place cookies on your device). These third-party cookies are used and managed by external entities to provide services requested by us to improve our services and your browsing experience. The main services for which these third-party cookies are used are to obtain access statistics and to guarantee the payment transactions that are carried out. The placing of third-party cookies is outside of our control, and you should consult the relevant third-party website for details of their own cookie policy.
This website uses the following cookies:
Cookie List
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Functional Cookies
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
For further information visit www.allaboutcookies.org.
CHANGES TO OUR PRIVACY & COOKIES POLICY
We may change the content of our website without notice to improve, add new functionality and features to this website and improve and add to our existing products, services and promotions. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices and consequently our Privacy Notice & Cookie Policy will change from time to time. If and when our data practices change, we will post the changes on our website to notify you. We therefore encourage you to review our Privacy Notice & Cookie Policy when you visit the website from time to time to stay informed of how we are using your Personal Data.
If you have any questions about this Privacy & Cookie Policy, the practices of LRL or your dealings with us, please contact us via the contact details in section 2 above.