Privacy Policy

Privacy Policy

ETF Stream Limited (we, us), are committed to protecting the data that we hold and use about you and to respecting your privacy.

We are confident that you will find the information that you need set out in this policy, but if you need to know more about the data that we hold or the ways that we use it, you can contact us by email at legal@etfstream.com or by post at Legal Team, ETF Stream Limited, 33 Eastcheap, London, EC3M 1DT.

This policy covers:

  1. About this policy

  2. The way that we use your personal data

    1. What personal data do we collect?

    2. How do we collect personal data?

    3. How do we use personal data?

    4. How do we share your personal data?

  3. Security and retention of your personal data

  4. Your rights and how to contact us

  5. Changes to this privacy policy

  1. About this policy

This policy (together with our website site terms of use and any other documents that we may refer to within this policy) describes the personal data that we collect from you or about you during the course of our business, and the ways that we use it. Please read the policy carefully as it will help you to understand the way that we use your data and our reasons for doing so.

The “data controller” of your personal data (in other words, the organisation that determines how your data is used) is ETF Stream Limited (company number 10800516) with registered address: 33 Eastcheap, London, EC3M 1DT.

  1. The way that we use your personal data

  1. What personal data do we collect?

“Personal data” is any information that could be used to identify you in some way. The personal data that we collect from or about you may (depending on our relationship with you) include the following:

  • name;

  • address;

  • e-mail address;

  • phone number;

  • your website;

  • the company you work for, your job title and your job category;

  • your business’ VAT number (only in instances where we need to issue you with a tax invoice);

  • professional demographic information;

  • your social media handle (in instances where you interact with us on social media such as on Twitter or LinkedIn);

  • any personal data you give to us in our general communications with you (for example when you make an enquiry via email, interact with us on social media, place a comment or publish an article or other content on our website, participate in one of our polls, or speak to someone from the team over the phone);

  • information about your computer and about your visits to and use of our website (including information about how and when you came to visit our website, how you interacted with the website (page response times, download errors, length of visit to certain pages, page interaction information such as scrolling, click, and mouse-overs) and where you went next (including full URLs and methods used to browse away from the site); and

  • technical information about the way you access our website including your IP address, geographical location, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and device information.

Where you are attending one of our events we may ask you to provide us with your dietary requirements. Where we process this information about you we will only do this with your explicit consent or as otherwise permitted under relevant data protection laws.

  1. How do we collect personal data?

We collect personal data in a variety of ways including:

  • directly from you: when you voluntarily provide this information to us (for example when you contact us, interact with us on social media, publish content or a comment on an article on our website, or book a place at one of our events);

  • from other publically available sources: from time to time, we access and store information which is available from public sources including some personal data (for example, we may collect publicly available information about the company or business your work for where we interact with you in a professional capacity);

 

  • from third party service providers: we engage with third parties to provide services to us for specific functions and in certain instances they will share personal data you provide to them with us. For example, we use Eventbrite to help us manage our events. You can find out more about the ways Eventbrite uses your personal data on their privacy policy which you can find here. For more information about the service providers we work with please see section D below;

 

  • otherwise through your browser or device or through our servers: certain information is collected by most browsers or automatically through your device, and we also collect your IP address or other device identifier (this enables us to recognise your computer or device when you use the site) via our server log files.

 

  • through cookies: Our site uses cookies to recognise you when you visit and use the website. This helps us to provide you with a good experience when you browse our website and also allows us to make any adjustments or improvements. For more information on the cookies we use, the purposes for which we use them and ways to limit the use of cookies and similar technologies in relation to your browsers or devices, please see our Cookie Policy;

We do not currently collect data about you from any other sources, but if this changes we will update this privacy policy.

  1. How do we use personal data, and what is our justification for doing so?

We use your personal data for a variety of purposes related to the day to day running of our business, producing great content and running relevant events. From a legal perspective, there are various reasons and justifications for doing so and we have set out an explanation of these below.

In order to run our events successfully and ensure the provision of the products and services we offer to you:

    • to ensure our events run smoothly and successfully, so that we know you are coming and reserve a space for you, so that we can communicate with you in relation to the event, and can meet any dietary requirements you have (where relevant);

    • to provide you with the information, products and services on our website or that you otherwise request and communicate with you regarding these products and services or respond to your questions and comments;

We use your personal data in this way either because we have a contract with you (for example, if you have bought a ticket to attend an event we will need to process your data to ensure we reserve a space for you) or because it is in our legitimate interests to do so (for example, it is in our interests to ensure that we meet the needs of all our event delegates and ensure everyone has a positive experience at the event) but we will always ensure that your rights are protected.

In order to provide you with your copy of “Beyond Beta”:

    • we will use your personal data to ensure you receive a copy of each new edition our quarterly publication, “Beyond Beta” once it is available;

Depending on our relationship with you we will either rely on your consent to contact you directly in relation to “Beyond Beta” or we will rely on our legitimate interests as a business. We will always ensure that your rights are protected. You can inform us at any time if you no longer wish to receive this publication.

For marketing purposes, including to measure how effective our marketing it:

    • to send you our newsletter or other marketing communications relating to our business and our productions which we think may be of interest to you by post, or where you have agreed to it, by email or similar technology;

    • to measure the effectiveness of our marketing campaigns and our advertising;

We rely on your consent to contact you directly by email about our business and any events we are running. In other scenarios, we will rely on our legitimate interests as a business, always ensuring that your rights are protected. You can inform us at any time if you no longer wish to receive marketing communications.

For administrative and internal business purposes:

    • to ensure that content on our website is presented in the best and clearest manner for you and for your device;

    • to administer our website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

    • for our internal business purposes, such as analysing and managing our businesses, audits, enhancing our offering including on our website, and identifying trends. For these purposes, personal data will be aggregated and looked at on a statistical basis;

    • for information about how we use our cookies, please see our Cookie Policy;

It is in our legitimate interests as a business to use your data in this way. For example, we have a clear interest in ensuring that our site works properly and that our content, events, products and services are high quality and efficient. We will always ensure that your rights are protected.

For security and legal and compliance purposes:

    • for taxation purposes such as to comply with tax laws;

    • as part of our efforts to keep our website safe and secure;

    • to detect or prevent fraud or other illegal activity;

    • as we believe to be necessary or appropriate in each case in order to comply with laws or legal process (including laws or legal process in other countries); and

    • to protect our rights or property (or the rights or property of others) and to enforce our rights and pursue available remedies.

In some cases, we will need to use your personal data to fulfil a legal obligation (for example, if we receive a legitimate request from law enforcement agencies), and in other cases (such as the detection of fraud or ensuring the security of the site) we will rely on our legitimate interests as a business to use your data in this way. We will always ensure that your rights are protected.

  1. How do we share your personal data?

We will never sell your personal data or give it to anyone else for them to use for their own purposes without making that clear to you, however, we do sometimes still need to share your personal data in various ways, as set out below:

(i) Sharing with organisations providing services to us:

We engage various third parties to provide services to us for specific functions, and this will often mean that we need to share your personal data with them (it is in our legitimate interests to do so, since we may not have the capabilities to provide these services ourselves).

For example here are a few of the third parties we work with:

  • we use a third party provider to help us efficiently print and distribute our printed publications;

  • we use the website analytics provider, Google Analytics, to help us understand how our website is used (this information is aggregated and looked at on a statistical basis only). For more information about Google Analytics please read Google’s analytics notice which is available here;

  • we use Eventbrite to help us manage our events. You can find out more about the ways Eventbrite uses your personal data in their privacy policy which you can find here; and

  • we use MailChimp to help us manage our email communications. You can find out more about how MailChimp uses personal data in their privacy policy which you can find here.

In every case, we will ensure that these third parties are only allowed to use your personal data in order to provide the relevant services to us. We will always make sure that we use organisations that we trust to look after your personal data appropriately and as required by applicable laws.

In rare circumstances we may need to share some data, including personal data with our insurers. We will only pass information to the insurer that it needs to provide adequate insurance for a particular production and will always make sure we use insurers we trust to keep your personal data in the strictest confidence and as required by the law.

[Note to ETF: We didn’t discuss in the call but do you foresee any instances where you would need to share personal data with an insurer?]

(ii) Sharing data in connection with changes to our group structure or the ownership of our business:

If we sell or propose to sell our business or part of it, we may need to disclose your personal data to prospective buyers. Similarly, if our ownership structure changes, we may need to disclose your personal data to the new owners or operators of our website as part of that process.

(iii) Sharing data to comply with laws:

There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime.

(iv) Sharing data within our group:

We are a part of a group of companies. In rare circumstances we may share your personal data with a member of our group in order to fulfil our contractual obligations to you, or because it is in our legitimate interests to do so. We will always ensure that your rights are protected.

[Note to ETF: We discussed that there was very little data sharing (perhaps none at all!) between members of your group. I have inserted this paragraph to try and cover any low level ad-hoc sharing which might occur, however, if this becomes strategically more important you would need to revisit this section of the policy. Please let us know if you would like support with this.]

International transfers of personal data

Some of the processes involved in our use of your personal data (or the services our third party suppliers provide involving use of your personal data) may require your data to be stored or processed in countries outside of the European Economic Area (the “EEA”) [or outside of the United Kingdom] [Note to ETF: We have inserted this wording as a precaution in case of a no-deal Brexit. Please note there will be a number of other considerations concerning sharing personal with EEA entities in a no-deal scenario. We can support you with this if required]. When this occurs we will make sure that we take steps necessary to protect your data as required by applicable laws, for example by implementing appropriate safeguards including by agreeing appropriate contract terms with the recipient of the data or by relying on recognised certifications such as the EU-US privacy shield.

  1. Security and retention of your personal data

(i) Security of your personal data:

We will ensure that appropriate technical and organisational measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data and we have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction.

(ii) Retention of your personal data:

We will only retain your personal data for as long as is necessary for the purposes described in this privacy policy. This means that the retention periods will vary according to the type of the data and the reason that we have the data in the first place. For example, we will store some information such as VAT numbers to comply with finance and tax related obligations whereas other personal data such as data processed for a particular event may be retained for a shorter period pf time. [Note to ETF: We discussed in the call that it is important that ETF Stream considers the personal data it holds, why it is holding the data and what the appropriate retention period is for each data set (and to document this). I have inserted the wording above for now – please let me know if you would like to make any changes].

  1. Your rights and how to contact us

The law gives you a number of rights in relation to your personal data and our use of it. You have the right:

      1. to ask us not to use your personal data for direct marketing purposes;

      2. to ask to see what personal data we hold about you and to find out about the way that we process the data (and in some circumstances, you can ask us to provide a copy to a third party);

      3. to ask us to correct or update any personal data which is inaccurate;

      4. to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to process it;

      5. to ask us to temporarily stop using your data if you don’t believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it; and

      6. not to be subject to decisions made solely on the basis of ‘automated processing’ (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.

If you would like to exercise any of the rights listed above, or if you have any queries or concerns about the way that we use your personal data (or any questions about this privacy policy), you can contact us by email at legal@etfstream.com or by post Legal Team, ETF Stream Limited, 33 Eastcheap, London, EC3M 1DT.

You also have the right to complain about our use of your personal data. You can contact the Information Commissioner’s Office via their website: https://ico.org.uk/concerns/ or by calling 0303 123 1113.

  1. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this site. We may also email you with any changes if we have your email address. Please check back frequently to see any updates or changes to our privacy policy.