Mondaq Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Notice (“Notice”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us when you use our website at www.mondaq.com (“Website”) or any of our services, or where we enter into any other business relationship with you. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Mondaq Limited.
We collect and process some or all of the following types of information from you in the course of your use of the Website, our provision of our services, or otherwise conducting any business relationship with you:
The provision of name, email address, place of work, position, country and telephone number is required from you to register to use the Website. Your name and email address are required from you to register for news alerts. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
We use public sources such as LinkedIn to obtain the contact details of individuals who we reasonably believe may have an interest in our products and services.
Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.
Mondaq has a “free to view” business model. Our services are paid for by content contributors (“Contributors”) in exchange for Mondaq providing them with access to information about who reads their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.
Details of each Contributor to which your personal data will be transferred is clearly stated within the summary of the content that you are able to view before you access the applicable Content. Contributors may be located within or outside the EEA – their location will also be clearly indicated. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.
We have always been completely transparent about the provision of users’ personal data to our Contributors, and until 24th May 2018 have relied on legitimate interest to collect and process our users’ information in this way. As a courtesy to our users, we have in the past provided the right to opt-out from this use of their personal information.
From 24th May 2018 although we believe that we continue to have a legitimate interest in providing your information to the Contributors whose content you access, and that the Contributors continue to have a legitimate interest in receiving this personal data, we have decided to give you more control by asking for your express consent to this processing when you register. Users who register after 24th May 2018 will therefore be required to opt in or out of this use. Users who registered prior to 24th May 2018 will not be asked to expressly consent to the use, but may opt out at any time by amending the settings in their profile or by contacting Us at the contact details set out below.
We use information held about you in accordance with the following “legal bases” and for the following purposes:
We may use information held about you to promote our products and services that may be of interest to you. We rely on a number of legal bases for this type of processing, as follows:
In any case, if you would prefer that we do not use your data to market or promote our products and services to you, please either (i) tick the relevant box on the form through which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) contact Us at the contact details set out below.
We routinely disclose your personal data to third parties as follows:
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
If your personal details change you may update them by accessing the relevant page of the Website, or by contacting Us at EditorialAdvisor@mondaq.com. If you have any questions about how We use data collected which relates to you, please contact Us by emailing email@example.com.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
All information We hold about you is stored on our secure servers within the EEA.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that [such countries] provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a [provide details of the appropriate or suitable relevant safeguards eg European Commission approved contract] (as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact Us, or our Data Protection Officer (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they aply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We reserve the right to modify this Notice at any time. Any changes We may make to our Notice in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied Privacy Notice.
We may collect information about your mobile phone, computer or other device from which you access the Website including where available [your IP address, operating system and browser type], for systems administration [and to report aggregate information to third parties affiliates]. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
The cookies We use include:
All questions, comments and requests [except where specified above] regarding this Privacy and Cookies Notice should be addressed to firstname.lastname@example.org write to Us at Mondaq Ltd, The Old Church, Quicks Road, Wimbledon, London SW19 1EX