Euromonitor International Ltd Privacy Policy

Updated: May 2018

Euromonitor International Ltd takes privacy seriously. This privacy policy aims to give you information on how Euromonitor International Ltd collects processes and stores your personal data when you use our services, website, application, product or software. Data is processed only for the purpose(s) for which it was collected for.

1. Controller

A controller determines the purposes and means of processing your personal data. Euromonitor International Ltd is the controller of your personal data and is responsible for your personal data.

Our Data Protection Officer is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests related to your personal data, please contact our Data Protection Officer using this email address: DataProtection@euromonitor.com.

2. Types of personal data we collect about you

Euromonitor International Ltd collects personal data from you, if you purchase or use our services, request information, register for an event, sign up to an e-alert-service, request customer support or register with us as a candidate for employment or associate.

The personal information that we collect and process includes:

Basic information, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact information, such as billing address, delivery address, email address and telephone numbers.

Financial information, such as payment related information.

Transaction information includes details about payments to and from you and other details of products and services you have purchased from us.

Technical information, such as internet protocol (IP) address, your login data, browser type and version, location, operating system and platform and other technology on the devices you use to access this website and our other web-based products.

Profile information, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage information, such as information about how you use our website, products and services. Our technologies automatically collect and log certain information to help us administer, protect, and improve our services, analyse usage and improve user experience.

Marketing and Communications information, such as your preferences in receiving marketing from us and our third parties and your communication preferences.

Other information relating to you which you may provide to us.

We may hold information about you that has not come directly from yourself. It may, for example, come from your employer, other organisations, such as educational institutions, to which you belong, if they use our Services and products. We also collect personal information from third parties such as our partners and associates, and publicly available websites, to help us maintain data accuracy and provide and enhance our services and products.

We share personal information with others only as described in this Statement, or when we believe that the law permits or requires it.

Euromonitor International Ltd may request sensitive personal information as part of the recruitment and employment process or as anonymised input into our services and products. This includes and is not limited to anonymised consumer surveys conducted via online panel as well as regular surveys sent to our employees and clients.

3. How does Euromonitor International collect personal data?

We use different methods to collect personal data from and about you such as:

• Direct contact with you during the course of business. You may give us your contact details, payment details for invoice purposes, by placing an order online, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

o subscribe to our products or publications

o create an account on our website

o request marketing information to be sent to you

o respond to our surveys

o provide us with some feedback on our products or services

o provide us with your contact details for us to assist you with using our products

• Automated interactions with our website where we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy here for further details.

• Using third parties or publicly available sources, where we may receive personal data about you from:

o Analytics providers such as Google based outside the EU

o Survey and Marketing companies based inside and outside the EU

o Contact, financial and transaction data from providers of technical, payment and delivery services who hosts our data inside and outside of the EU.

o Identity and contact data from publicly availably sources such as Companies House based inside the EU.

4. How does Euromonitor International use personal data?

• On our HR Systems: We use personal information of our employees as part of our HR process. This data is stored on our HR System as well as in hard copy files which are locked. We use the data to process our payroll as well as manage and report on employees.

• On our Finance Systems: We use personal information to enable us to make payments to contractors and freelancers who provide services to us.

We process personal information for these Service and business-related purposes:

Account setup and administration: We use personal information such as your name, email and domain address, phone number, and information to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.

Personalisation: We use personal information to deliver and suggest tailored content to personalise your experience with our services.

Marketing and events: We use personal information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference for our services for you to manage your information and marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.

Research and development: We use personal information for internal research and development purposes and to improve our services.

Chat rooms, messaging, community and event forums: When you use our chat rooms, messaging, community and event forums we may collect details of visits made including, but not limited to the number of visits, logs, IP address which are only used for in-house analysis. Personal data and other user information collected by our chat rooms and forums are used in order to complete your registration and at the same time to ensure access to our Services and products. Any personal data provided in connection with the correspondence between you and Euromonitor International Ltd, for example to report a problem with our products or raise a query or comment shall be used strictly to reply to you.

Hosted services: Some of our services provide data and document storage as an integral part of the product or solution offering. Documents and data stored by our customers may contain personal information or information classified as “confidential” by the organisation you work for or are affiliated with. Any information stored by or on behalf of our customers is controlled and managed by and only made accessible to those customers or others our customers may authorise from time to time. Our access to this information is limited to Euromonitor International Ltd personnel with a critical business reason.

Legal obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise 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, or those of other persons.

5. When do we share personal data?

Euromonitor International Ltd only shares or discloses personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We may occasionally share non-personal, anonymised, and statistical data with third parties, including survey findings from our online consumer panels, employees and clients. Below are the parties with whom we may share personal information and why.

Within Euromonitor International Ltd: Our businesses around the world are supported by a variety of teams and functions, and personal information will be made available to them if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information. Please click here to see a list of Euromonitor International Ltd locations where we may process personal data.

Our business partners: We occasionally partner with other organisations, provide content, or host events. As part of these arrangements, you may be a customer of both Euromonitor International Ltd and our partners, and we and our partners may collect and share information about you. We will handle personal information in accordance with this Statement.

Our third-party service providers: We are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, such as software, system, and platform support; direct marketing services; cloud hosting services; and providers of our employee benefits schemes. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.

If you would like to see a list of our third party service providers, please contact our Data Protection Officer (DataProtection@euromonitor.com).

• When we transfer personal information from the European Economic Area to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. In other words, your rights and protections remain with your data. For example, we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your personal information protect it. If you would like to know more about our data transfer practices, please contact our Data Protection Officer (DataProtection@euromonitor.com).

Third parties for legal reasons: We will share personal information only when we believe it is required, such as:

o To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence.

o To protect our rights, users, systems, and Services.

E-recruitment partners: If you register as a user of our e-recruitment Services in order to apply for employment, your personal information, including any sensitive personal information you provide, will be made available to the organisation to which you have applied. In order to consider an application fully, your personal information may be forwarded to one of our global offices.

6. Where and how does Euromonitor International Ltd store your data?

Euromonitor International Ltd is a global organisation, and your personal information may be stored and processed outside of your home country. We take steps to ensure that the information we collect is processed according to this Privacy Statement and the requirements of applicable law wherever the data is located.

Euromonitor International Ltd has networks, databases, servers, systems, and support located throughout our offices globally, please click here to see a list of Euromonitor International Ltd locations. We collaborate with third parties such as cloud hosting services, located around the world to serve the needs of our business, workforce, and customers. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. As a global organisation, we may need to transfer your personal information within Euromonitor International Ltd or to third party cloud hosting provider, outside of your home country. See clause 5 above for “when do we share personal data”.

7. Securing your personal information

Euromonitor International Ltd uses appropriate technologies, policies, processes and procedures to protect personal information. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed and updated regularly to reflect changes in legislation and in business needs.

Examples of our technologies, policies, processes and procedures:

o We have measures in place to protect against accidental loss and unauthorised access, use, destruction, or disclosure of data

o We have a Business Continuity and Disaster Recovery strategy that is designed to safeguard the continuity of our service to our clients and to protect our people and assets

o We place appropriate restrictions on access to personal information

o We implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely

o Security awareness training for employees and contractors

o We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions

o We require, through the use of contracts and security reviews, our third-party vendors, providers and their sub-contractors to protect any personal information with which they are entrusted in accordance with our security policies and procedures

8. How long do we keep your data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

The data retention periods used take into consideration local laws, contractual obligations, and the expectations and requirements of our customers.

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.

When we no longer need personal information, we securely delete or destroy it.

9. Your right regarding your personal data

The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for data subjects.

Euromonitor International Ltd respects your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information. Please remember, that on occasions your personal data may have been shared with you by your employer or by other organisations, such as educational institutions, to which you belong, if they use our Services and products.

Access to personal information: If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. UK employees are entitled to request details of their personal records through a Subject Data Access Request. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.

Request correction: In some jurisdictions, you have the right to correct or amend your personal information if it is inaccurate or requires updating.

Request deletion: You may also have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by using the “Contact Us” option within the relevant Service.

Object to processing: If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect your choice in accordance with our legal obligations. In relation to Marketing preferences: You can opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or visit the applicable email preference center. For other marketing preferences, you can use the “Contact Us” option within the relevant Service. Information related to controlling cookies can be found here .

Restriction of processing: You can ask us to suspend the processing of your personal data if you want us to establish the accuracy of the data; 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; and you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request personal data transfer: 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, but 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.

Filing a complaint: If you are not satisfied with how Euromonitor International Ltd manages your personal data, you have the right to make a complaint to a data protection regulator. A list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Please contact our Data Protection Officer (DataProtection@euromonitor.com) with any requests related to your personal information.

10. Links to third party websites

Our Sites contain links to third party websites that are not subject to this Privacy Policy. Euromonitor International Ltd strongly recommends that you read the privacy policy of any such websites that you visit.

11. Policy changes

Euromonitor International Ltd may change this Privacy Policy at any time by sending you an e-mail with the modified Privacy Policy or by posting a copy of them on the Site. Any changes will take effect seven (7) days after the date of our e-mail or the date on which Euromonitor posts the modified Privacy Policy on the Site, whichever is the earlier. Your continued use of the Site after that period expires means that you agree to be bound by the modified Privacy Policy.