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ISI EMERGING MARKETS GROUP: PRIVACY POLICY

1. OVERVIEW

This Policy is ISI Emerging Markets Group’s (“the Company”) Privacy Policy. The purpose of this Policy is to set out how the Company uses and protects your personal data through your use of our websites, including any data you provide when you register with us or sign up to our newsletters, or purchase a product or service.

2. WHO WE ARE

ISI Emerging Markets Group (“ISI”, “We”, “Us”, or “Our”) is an international business-information group company with more than 500 employees worldwide.

Our group consists of three brands that have forged a reputation for providing the highest quality of information about emerging market and are as follows:

  • CEIC: A leading provider of macroeconomic and sector data
  • EMIS: A leading provider of company and industry analysis, data and news
  • REDD: A leading provider of analysis , research and news on corporate and sovereign debt in emerging markets.
  • EPFR: A leading provider of investor and fund manager sentiment across global markets.

ISI and its group companies are committed to respecting the privacy of every person who visits, registers with or subscribes to our websites, publications and/or events. ISI is the primary data controller of personal data collected through this website and/or as described in the section entitled “What Personal Data We Collect”.

3. WHAT PERSONAL DATA WE COLLECT & WHY

Our primary goal in collecting personal data from you is to give you an enjoyable customised experience of our products whilst allowing us to provide services and features that will be most adapted to your needs.

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. Identity Data includes your first name, last name, any previous names, username or similar identifiers.
2. Contact Data includes your address, email address and telephone numbers.
3. Financial Data includes bank account and payment card details.
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
5. 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, device ID and other technology on the devices you use to access this website.
6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
7. Usage Data includes information about how you interact with and use our website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Legal Basis For Processing Your Personal Data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Personal Data Collection & Use Cases

  • Registration, Free Trials & Subscriptions
    When you register with our website and/or sign up for a free trial of our products, you provide your name, address, email address and telephone number, and details relevant to your occupation or employer.
  • If you have subscribed to one of our products, we will also ask for payment details. Credit/debit card payments are processed using a third supplier and we do not retain this 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 and delivery. This personal data is used by us to complete subscription requests and, subject to your consent or legitimate interests, for advertising and marketing purposes as described in this Privacy Notice.
  • Your personal data is also used to record your interests, send you the content you have requested and for the advertising and marketing purposes described in this Privacy Notice.
  • Advertising & Marketing
    We use the personal data you provide us and which we collect from you to inform you about our similar products and services. If you have consented to receive information from other ISI Emerging Market Group companies, we will share your personal data with these companies so that they can fulfil your request to receive marketing materials in accordance with your preferences.
    Each of the ISI Emerging Markets 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 “Contact Us” section. You can opt out from receiving such materials at any time.
    The personal data we use for advertising and marketing purposes includes your name, email address, job title, phone number, company name/employer, and data collected using cookies and other similar technology. Marketing materials are sent by email, and we may occasionally call you.
  • 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 ads, we use third parties to deliver cookies that collect information about your computer, 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 accomplish 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 determine whether someone is appropriate to sell to, and this enables us to improve the quality and pertinence of marketing activities. The personal data analysed by the software includes email address, phone number, job title, address, purchase history and account information.
  • 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 incredibly valuable and very much appreciated – but you can opt out of receiving such requests at any time.
  • Sales & Other Business Operations
    If you have purchased a subscription or some other product or service from us, or registered for an event, then we will need to process certain information in order to collect payment from you, including your name, address, email and telephone number. If individual accounts are outstanding, we may pass account details (including personal data such as name, phone number and address) to third parties who are responsible for collecting payment. We use a third-party supplier to process payment card details (see section on “Third Party Links”).

4. ADDITIONAL THIRD-PARTY DISCLOSURE

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.
  • We may be required to disclose personal data about our users 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 ISI and its affiliates (including our employees, agents and contractors).

5. EMAIL TRACKING

We may include small pixel tags (small image files) within the emails we send you to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. 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 “Contact Us” section of this Policy).

6. INTERNATIONAL TRANSFERS

ISI Emerging Markets Group is a Global Company which operates within multiple regions such as Europe, Middle East and Africa (EMEA), Asia and Americas . If you have consented to being contacted by a legal entity within our Group of 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 the applicable data protection regulators.

We may also transfer personal data to third party service providers as described in this Privacy Policy. 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.

7. DATA RETENTION

We adhere to a strict data retention policy that ensures we only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. To determine the appropriate period for personal data we apply the following criteria:

  • 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;
  • Whether there is a specific law or regulation that imposes a mandatory retention period;

There may be limited circumstances in which it will be necessary for documents and associated personal data to be kept 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.

8. DATA SECURITY

ISI is committed to keeping your personal data secure and has put in place appropriate technical and organisational 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.

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 to ensure the integrity of data that we have under our control.

9. YOUR LEGAL RIGHTS

ISI Emerging Markets Group does its utmost to ensure we respect your privacy and your rights in relation to your data. You have a number of rights under data protection laws in relation to your personal data and they include the right to:

  • Right of Access
    Request access to your personal data (commonly known as a "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.
  • Right to Rectification
    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.
  • Right to Erasure
    Request erasure of your personal data in certain circumstances. 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.
  • Right to Object
    Object to processing of your personal data where we are relying on a legitimate interest as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
    You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
  • Right to Data Portability
    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.
  • Right to Restriction of Processing
    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10. CONTACT US

If you wish to exercise any of the rights set out above, please contact us by post or email at the following addresses:

Postal Address

ISI Emerging Markets Group
10th Floor 30 Crown Place
London
EC2A 4EB
United Kingdom

Email Address: dataprotectionofficer@isimarkets.com

We may need to verify your identity prior to processing a request. ISI will do its utmost 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 UK Information Commissioner.

11. THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins and applications, for example, providers of payment processing services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for the privacy and data collection practices of those third-party websites. When you leave our website, we would recommend that you encourage read the privacy policy of every website you visit.

Policy Last Updated : May 2024