Privacy Policy
Last updated: 25/05/2018
We know that your personal information is important to you and we are committed to ensuring it is kept secure and used carefully. Below you will find a short summary of how and why we collect your data, who we share it with, and what we’re doing to make sure your data is safe and secure. You will also find details of your privacy rights.
This is the privacy policy of Southbank Investment Research Limited (“Southbank”). If we change our privacy policy, we will notify you of those changes here.
Our Website (https://www.southbankresearch.com) may include hyperlinks to other websites that are not operated or controlled by us. This privacy policy only applies to our Website and we are not responsible for the content or the privacy practices of third party websites.
If you want to skip to a particular section of this policy please click on the relevant link below.
What personal information does Southbank collect and why?
Who does Southbank share my personal information with?
Legal basis for processing personal information
How does Southbank keep my personal information secure?
Updates to this privacy policy
What does Southbank do?
Southbank is a privately owned publishing company based in London. We publish newsletters which provide insight and advice on investing. We are part of a larger media group, The Agora, headquartered in Baltimore, Maryland, and with offices in more than 20 countries around the world. You can learn more about The Agora here [link to http://theagora.com/] and about Southbank in the “About Us” section of our Website.
What personal information does Southbank collect and why?
We collect information in order to allow us to provide the publications you have subscribed to, and to personalise and improve your experience of our services, Website, and communications with you. All such information is held on secure servers.
We only use personal data you have given us or that we have collected from you when you visit our Website [and order forms]. We do not obtain personal information from or sell it to third parties. We sometimes share your personal information with third parties, but only to provide your subscriptions to you or to personalise and improve your experience with us. We never release your personal information to others for their mailing or marketing purposes.
The personal information that we may collect about you broadly falls into two categories:
- Information that you provide
We may ask you to provide personal information in order to provide our services to you. This includes asking you to provide your contact details to deliver subscriptions to you or to register an account with us so you can access the subscriber-only areas of our Website. It also includes asking you to provide payment information so you can pay for subscriptions or use a one-click order process.
The personal information you are asked to provide, and the reasons why you are being asked to provide it, will be made clear to you at the point you are asked to provide it.
- Information that we collect automatically
When you visit our Website and order forms, we may collect certain information automatically from your device.
The data we collect may include information like your IP address, device type, unique device identification numbers, browser-type, and other technical information. We may also collect information about how your device has interacted with our Website or order form, including the pages accessed and links clicked.
We collect this information so we can better understand the visitors who come to our Website [and look at our order forms] and what content may be of interest to them. Using the information allows us to improve the quality and relevance of our Website and services.
Some of this information may be collected using cookies and similar technology. This is explained in more detail in our Cookie Policy.
Who does Southbank share my personal information with?
We may disclose your personal information to the following categories of recipients:
- to our group companies who provide data processing services to us, for example, enhancing the security of our Website, or who process personal information for the purposes described in this privacy policy or notified to you when we collect your personal information. Publishing Services LLC (based in Baltimore, Maryland) provides the majority of the data processing services we use including hosting our customer database on their servers, and Emerald Contact Centre Limited and Mount Vernon Consulting LLC (respectively based in Waterford, Ireland and Baltimore, Maryland), which provide customer and telesales services.
- to reputable third party service providers who provide additional data processing services, for example, analysing data, providing marketing assistance, and assisting with the processing of credit card and direct debit payments. They have access to personal information needed to perform their functions, but may not use it for other purposes. In addition, they must process the personal information in accordance with this privacy notice and as permitted by applicable data protection laws. A list of these providers along with a short summary of the services they provide can be found here [Either link to new page or list your 3rd party services providers];
- to any competent law enforcement body, regulatory, government agency, or similar other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, or (ii) to exercise, establish or defend our legal rights; and
- to any other person with your consent.
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the information concerned and the context in which we collect it.
We will normally collect personal information from you where:
- we need the personal information to perform a contract with you (for example, your email address when you subscribe to a free or paid service);
- the processing is in our legitimate interests and not overridden by your rights;
- we have your consent to do so (for example, to receive marketing emails from us about another publisher’s publications or services which we think might be of interest to you); or
- We need the personal information to comply with our legal obligations (for example, our tax and audit requirements and other regulatory obligations)
We fund our free daily editorial emails, Capital & Conflict and Exponential Investor, by advertising our services and those of other group companies (very occasionally we may carry advertising for a third party service). There are two small ads in each editorial email, and two or three times a week we send separate promotional emails. By subscribing to the free emails, you are consenting to receive these promotions (we cannot send a free email alone without the promotional emails). There is an unsubscribe link in each of these emails and you can unsubscribe at any time.
If we collect and use your personal information in reliance on our legitimate interests, this will normally be to operate and improve our services, Website, and communications. It would also include responding to your queries, undertaking marketing, or detecting or preventing illegal activities. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
How does Southbank keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Where we share data with third parties, we ensure that your data will be kept secure and will not be provided or sold to another party.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, group companies and third party service providers operate in the United States and elsewhere around the world. This means that when we collect your personal information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this privacy policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the European Economic Area in accordance with European Union data protection law. We have implemented similar appropriate safeguards with our third party service providers.
Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below. We may not be able to delete your personal information if we have to retain it in order to comply with our legal obligations, to perform a task carried out in the public interest, to establish, exercise or defend any legal claims or to exercise our right of freedom of expression and information.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact the Information Commissioner’s Office (“ICO”).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this privacy policy
We may update this privacy policy from time to time in response to changing legal, technical or business developments. When we update our privacy policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material privacy policy changes if and where this is required by applicable data protection laws.
You can see when this privacy policy was last updated by checking the “last updated” date displayed at the top of this privacy policy.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us by clicking here.
The data controller of your personal information is Southbank Investment Research Limited.