Introduction
Welcome to Ibex Publishing's privacy policy.
Ibex Publishing respects your privacy and is committed to protecting your personal data. This privacy
policy will inform you as to how we look after your personal data when you visit our website (regardless
of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a text format for your reference. Please also use the Glossary to
understand the meaning of some of the terms used in this privacy policy. Should you wish a physical
copy, please write to us by first class mail to make a request. All reasonable requests will be respected. Our mailing address is:
Ibex Publishing Limited, International House, 50 Essex Street, London, United Kingdom, WC2R 3JF
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Ibex Publishing collects and processes your
personal data through your use of this website, including any data you may provide through this
website when you sign up to our newsletter or purchase a product or service or take part in a
competition or = contribute to our bulletin board and/or comments section.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting or processing personal
data about you so that you are fully aware of how and why we are using your data. This privacy policy
supplements other notices and privacy policies and is not intended to override them.
Controller
Ibex Publishing Limited is the controller and responsible for your personal data (collectively referred to
as "Ibex Publishing", "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to
this privacy policy.
If you have any questions about this privacy policy, including any requests to
exercise your legal rights, please contact the data privacy manage using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data
privacy manager in the following ways:
Full name of legal entity: Ibex Publishing Limited
Email address: hello@ibexpub.media
Postal address: Ibex Publishing Limited, International House, 50 Essex Street, London, United Kingdom, WC2R 3JF
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the
UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to
deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy statements. When you
leave our website, we encourage you to read the privacy policy of every website you visit.
Without prejudice to the above paragraph or any other section of this notice, please note that we may,
from time to time, include links to third-party websites, plug-ins and applications created by the
following parties throughout our website. This list is not exhaustive and is provided out of good faith
for indicative purposes only.
• Automattic
• Stripe
• Sendinblue
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
data).
We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone
numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of
products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and
version, time zone setting and location, browser plug-in types and versions, operating
system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing
from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as
this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage
Data to calculate the percentage of users accessing a specific website feature. However, if we combine
or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we
treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health, and genetic and biometric data). Nor do we collect
any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in
forms or by corresponding with us by post, phone, email or otherwise. This includes personal
data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• give us feedback; or
• contact us.
• Automated technologies or interactions. As you interact with our website, we will
automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you visit other websites
employing our cookies. Please see our cookie policy (see our website’s policy page) for
further details.
• Third parties or publicly available sources. We will receive personal data about you from
various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google based inside or outside the UK;
(b) advertising networks such as Google Display Network based inside or outside the UK;
and
(c) search information providers such as Microsoft Bing based inside or outside the UK;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery
services such as Stipe based inside or outside the UK.
• Identity and Contact Data from data brokers or aggregators such as Databroker based inside
or outside the UK.
• Identity and Contact Data from publicly available sources such as Companies House and the
Electoral Register based inside the UK.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with
you.
• Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
See Glossary: Lawful basis to find out more about the types of lawful basis that we will rely on to
process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will
get your consent before sending third party direct marketing communications to you via email or text
message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data,
and which of the legal bases we rely on to do so. We have also identified what our legitimate interests
are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the
specific purpose for which we are using your data. Please contact us if you need details about the
specific legal ground we are relying on to process your personal data where more than one ground has
been set out in the table below.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.
Third-party marketing
We may share your contact details and registration data, including the information you provide at the time of registration, with event sponsors or partners where this is necessary for the organisation and delivery of the event, including access management and participant coordination. This processing is carried out on the basis of our legitimate interests in ensuring the proper functioning of the event.
Where you have provided your explicit consent, we may also share your contact details with selected event sponsors or partners so that they may contact you directly for marketing purposes related to the event and their services. Such contact may be made by email or other electronic means. You may withdraw your consent at any time.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a
change happens to our business, then the new owners may use your personal data in the
same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within the Ibex Publishing Group. This may involve transferring your data
outside the UK.
Many of our external third parties are based outside the UK so their processing of your personal data
will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is implemented:
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who have
a business need to know. They will only process your personal data on our instructions and they are
subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or
reporting requirements. We may retain your personal data for a longer period in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with
you.
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, regulatory, tax, accounting or other
requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial
and Transaction Data) for six years after they cease being customers for regulatory, financial, and/or
tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further
information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes, in which case we may use this information indefinitely
without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal
data.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies wholly or jointly owned by Ibex Publishing acting as joint controllers or processors and who are based in France.
External Third Parties
• Service providers acting as processors based in Canada, the USA, France, Germany, the
Netherlands, or otherwise throughout the European Union and/or EAA and/or Switzerland
who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in Canada, the
USA, France, Germany, the Netherlands, or otherwise throughout the European Union and/or
EAA and/or Switzerland who provide consultancy, banking, legal, insurance and accounting
services.
• Commercial or Editorial partners, sponsors, and advertisers based in the EU, EAA, or the United Kingdom.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who
require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. 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. However, 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.
