Euromoney Institutional Investor PLC - Privacy Notice

Who We AreOur Approach to Your PrivacyWhat Personal Data We Collect & WhyInternational TransfersRetention PeriodsPrivacy PreferencesYour RightsProtecting Your DataThird Party Sites

INTRODUCTION – WHO WE ARE

The Foex.fi website is operated by Foex Indexes Ltd. (“FOEX”) and provides audited pulp, paper, recovered paper, wood and wood-based bioenergy price indices on a subscription basis. FOEX is part of Euromoney Institutional Investor Plc, an international business-information group covering asset management, price discovery, data and market intelligence, and banking and finance (“Euromoney”). The Euromoney group also runs an extensive portfolio of events for the telecoms, financial and commodities markets. FOEX also works with RISI, Inc. (“RISI”), the leading information provider for the global forest products industry. RISI is the exclusive re-seller of FOEX data subscription products and in this capacity is responsible for managing data collected through the FOEX website.

RISI is the data controller of personal data collected through this website and/or as described in the section entitled “What Personal Data We Collect”. If you have provided consent to being contacted by our other Euromoney group companies, including FOEX, they will also be controllers of the personal data you have agreed to share. This means that they are responsible for how your personal data is used, just as we are.

You can get in touch with us at the following address, or by calling or sending an email:

RISI, Inc.
Bedford, MA
01730, USA

Or by email: dpo@risi.com

This Privacy Notice was updated on July 17, 2018

OUR APPROACH TO YOUR PRIVACY

This Privacy Notice outlines the information we may collect about you in relation to your use of our products and services (“personal data”). We also explain the legal rights that you have in relation to your data and how you may exercise these rights.

Some of our group companies may collect and use personal data for different purposes; those companies have their own websites. We do not share your personal data with our other group companies unless you have provided your consent. Whenever possible, we rely on your consent to use your data for the purposes described in this Privacy Notice. We also process personal data to fulfil our contractual obligations to you, such as: when you register for any of our services, subscribe to a publication, sign up for an event or purchase a product from us, we will be required to process some of your personal data to deliver on our commitments.

We may determine that processing your personal data serves both of our legitimate interests. This is the case in relation to many of our research, customer survey, marketing and advertising activities described in this Privacy Notice. These activities allow us to better understand your requirements, which in turn enables us to provide you with a better service.

We review the bases for our processing decisions carefully and you can object to these activities at any time (see the “Your Rights” section of this Privacy Notice).

WHAT PERSONAL DATA WE COLLECT & WHY

Our primary goal in collecting personal data from you is to give you a relevant customized experience of our products while allowing us to provide services and features adapted to your needs.

Registration, Free Trials & Subscriptions

When you register with our website and/or sign up for a free trial of our products, we may ask you to provide your name, address, email address and telephone number, and details relevant to your occupation or employer.

If you subscribe to one of our products or services, we will also ask for payment details. Credit/debit card payments are processed using a third supplier and we do not retain credit card data (see the Third Party Sites of this Privacy Notice). Address details may be shared with third party service providers engaged by us for order fulfilment, delivery and payment collection. This personal data is used by us to complete subscription requests.

Your personal data is also used to record your interests, so we can send you content your have requested and for the advertising and marketing purposes described in this Privacy Notice.

Events & Conferences

If you have registered for an event through a group website we may collect personal data including: name, job title, company, address, telephone number and email.

This information is necessary so that we can complete your registration for the event and provide you with relevant event materials.

We may also provide delegate details (name, email) to event sponsors who, subject to your consent, may contact you for their own advertising and marketing purposes.

Advertising & Marketing

We use the personal data you provide us and which we collect from you to inform you about similar products and services which we provide, or which are offered by our third party partners. If you have consented to receive information from other Euromoney group companies, we may share your personal data with these companies so that they can fulfil your request to receive marketing materials in accordance with your preferences. We will not share your personal data with any third parties for their own marketing purposes unless you have provided your consent and you can always opt-out of receiving of our partner marketing emails.

Each of the Euromoney group companies that may contact you is a data controller in relation to the personal data that you have agreed to share with them. If you have any questions or concerns, you may contact the individual company, or us – using the contact details set out in the “Who We Are” section.

You can opt out from receiving such materials at any time.

The personal data we may use for advertising and marketing purposes includes your name, email address, job title, phone number, company name/employer, geo location, postal address and data collected using cookies and other similar technology (please read our separate Cookies Policy to find out more about which cookies we use, how they work and how you can control your cookie options).

Marketing materials are sent electronically, by post and we may occasionally call you.

Online Engagement

We monitor your engagement with our websites – and the actions taken across those sites – to better tailor our content and services, and to engage in marketing activities that meet your requirements. The data we gather using your email address, cookies and other website monitoring technologies (see our full Cookie Policy, here) enable us to: ensure you have access to the content to which you have subscribed; for trend analysis; for our internal security log and to monitor compliance with our Terms and Conditions, and; improve the relevance of our marketing initiatives.

Online Targeted Advertising

We use targeted advertising on our websites to display advertisements that are relevant to what we believe are your interests. In order to deliver relevant advertisements, we use third parties to deliver cookies that collect information about your IP address and how you interact with our sites (e.g. browsing information, which articles you have read). This data is used by the third parties to create interest categories and to determine which advertisements will be delivered to you based on the projected interest categories.

We may also share your personal data with third parties to deliver targeted advertising to you on other websites (e.g. Twitter Tailored Audiences or Facebook Custom Audiences). This could include your email address, cookie data, and information obtained from third parties. Third party cookies may also be used to enable us to target advertisements to you on other websites that you visit. Please read our separate Cookies Policy to find out more about which cookies we use, how they work and how you can control your cookie options.

Lead Generation and Scoring

We occasionally use the services of trusted third parties in order to ensure that the personal data we use for advertising and marketing purposes is accurate and up-to-date. To do this, we transfer personal data of individual leads (name, email, job title, location and phone number) to these third parties who conduct research to verify the data – primarily against public information.

We also use algorithmic software technology to help us improve the quality and relevance of marketing activities. The personal data analysed by the software includes email address, phone number, job title, address, purchase history and account information. This allows us to provide meaningful offers that are relevant to your specific profile.

Surveys, Market Research & Customer Feedback

We want to understand the needs of our readers and customers. We may therefore use the information you provide us – including your name and contact details – to contact you to request your feedback, or to participate in our customer and market research. Your participation is valuable and very much appreciated.

Public forums, message boards and blogs

Some of the pages on our group websites may include message boards, blogs or other facilities for generating content from users. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to post any personal data. User generated content is also subject to our site Terms and Conditions.

Business or Asset Sale

If we or Euromoney sell a business or assets we may need to disclose your personal data to the prospective buyer of such business or assets.

If Foex, Euromoney, or any of our group companies is sold or sells our assets or is acquired by a third party, then personal data about our customers will be acquired by that third party. A transfer of your personal data in these circumstances would be necessary so that the services you have contracted for can still be delivered, or so that you can continue to enjoy the benefits of our free products and services. You will of course receive notice if a new controller assumes responsibility for your personal data.

Additional Third Party Disclosures

We may disclose your personal data to third parties in the following situations:

  • To third party partners who help us by providing data storage and disaster recovery services. These third parties only receive encrypted data may only process personal data to help us in limited emergency situations
  • In response to court orders, law enforcement measures or in the context of other mandatory legal processes. In each case we will seek to minimise the amount of data that is disclosed.
  • If required to protect other users and/or to defend the legal rights, interests and security of Foex, Euromoney and its affiliates (including our employees, agents and contractors), or as otherwise disclosed in our Terms of Service. This may include exchanging information with other companies and organisations for the purposes of fraud protection.

Email Tracking

We may include small pixel tags (small image files) within the emails we send you in order to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. We may also collect browser, location and the device used to engage with our email communications. This information allows us to better understand whether we are meeting our users’ needs and how we can improve our communications. No other information is collected. You can opt out of receiving our direct marketing emails either by following the instructions in each email, or by contacting us (see the “Who We Are” section of this Privacy Notice).

INTERNATIONAL TRANSFERS

Some of the Euromoney group companies are based outside the European Economic Area (EEA). If you have consented to being contacted by our group companies, then the transfer of your personal data will be made according to the terms of an international data sharing agreement that contains obligations approved by European data protection regulators. Any of our group companies that receive your personal data will be co-controllers of that data, which means they may determine how they process your personal data – although they may only use it for the purposes for which it was shared, unless you are informed of new or additional processing activities.

We may also transfer personal data to third party service providers as described in this Privacy Notice, located outside the EEA. Where we conduct these transfers, we take all steps necessary to ensure that your data is treated securely and in accordance with applicable privacy legislation, either by only sending your personal data to jurisdictions that provide an adequate degree of legal protection for your data or by imposing approved contractual terms on these third parties.

RETENTION PERIODS

We have a data retention policy that ensures we don’t use or store your personal data for longer than necessary. We consider the following issues to determine retention periods:

  • Guidance from the UK Information Commissioner or other regulatory agency, or industry best practice recommendations;
  • The business rationale for collection and expiry of the purpose for which personal data was collected;
  • Our ongoing ability to ensure the accuracy of the data; and
  • Legal and regulatory requirements.

We may occasionally need to keep personal data for either shorter or longer periods than specified in our retention policy. In such circumstances, application of the retention period to the data will be temporarily suspended. The suspension of an applicable retention period will be carried out in a manner that respects the rights and interests of all persons concerned.

HOW YOU CAN SET YOUR DATA & PRIVACY PREFERENCES

You can use our Preference Centre to select the industries and topics that are of interest to you so that we can send you publications and information about our products and events that are especially relevant to you. You can also choose the channels we use to contact you (email, phone, post, etc.) and can also opt-out of receiving marketing communications.

YOUR RIGHTS

You have certain rights in relation to your personal data which include the following:

Access & Portability

You may request access to any personal data of yours for which we or Euromoney is responsible as controller. Subject to any overriding legal interests, we will confirm whether we process any of your personal data and if we do, we will provide you with the following information: the purposes of the processing, the categories of personal data, any recipients of your personal data, the applicable retention period and the data source. Copies of your personal data will be made available to you in a structured, machine-readable format.

You may also request that we transfer the personal data that you have submitted to us, to another controller, where it is technically feasible for us to do so.

If you have consented to our processing of your personal data, or if we are processing your personal data in order to fulfil our contractual obligations to you, then you can submit a request that we transfer your personal data to another data controller.

Rectification, Restriction, Objection

You have the right to request that Foex rectify any errors in the personal data that we process. In some circumstances, you may also be able to obtain the erasure of personal data, and/or request that the processing of your personal data be restricted. You may also object to the processing of your personal data for direct marketing purposes, or where your personal data is processed for your or our legitimate interests.

How to Exercise Your Rights

To exercise any of these rights, please contact us by post or email at the following addresses:

RISI, Inc. 4 Alfred Circle Bedford, MA 01730, USA

Or by email: dpo@risi.com

Web form: Please click here

We may need to verify your identity prior to processing a request.

Foex will do its best to respond to any questions and address any of your concerns. You are also able to register any complaints regarding the processing of your personal data directly with the Finnish Data Protection Ombudsman.

PROTECTING YOUR DATA

Foex, RISI and Euromoney are committed to keeping your personal data secure and we will take appropriate technical and organisational measures to protect your personal data from loss, unauthorised use, disclosure or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk. We have therefore implemented information security policies and rules, staff training on information security, and technical measures to ensure the integrity of data that we have under our control.

All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.

THIRD PARTY SITES

Our site may contain links to other websites – including, for example, providers of payment processing services. We are not responsible for the privacy and data collection practices of third party sites and we therefore recommend that you review the privacy policies and terms of service of each site you visit.