Adam Smith International Ltd

Extractives Hub

www.extractiveshub.org

Privacy and Cookies Policy

1. Introduction

1.1 This is the Privacy and Cookies Policy of Adam Smith International Ltd referred to as "We", "Us" or "Our" below.

1.2 We respect your privacy and are committed to protecting your personal data.

1.3 This Privacy and Cookies Policy applies to www.extractiveshub.org ("Our Site") regardless of where you visit it from and tells you about your privacy rights and how the law protects you.

2. Purpose of this Privacy and Cookies Policy

2.1 This Privacy and Cookies Policy provides information on how We collect and process your personal data through your use of Our Site, including any data you may provide through Our Site when you sign up to Our newsletter.

2.2 Our Site is not intended for children and we do not knowingly collect data relating to children.

2.3 It is important that you read this Privacy and Cookies Policy together with any other privacy notice or fair processing notice 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.

3. Controller

3.1 Adam Smith International Ltd is the controller and responsible for Our Site and your personal data.

3.2 If you have any questions about this Privacy and Cookies Policy, including any requests, please contact Us using the details set out below.

3.3 Our full details are:

Adam Smith International Ltd
240 Blackfriars Road, London, SE1 8NW
enquiries@extractiveshub.org

3.4 You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Us in the first instance.

4. Changes to the Privacy and Cookies Policy and your personal data

4.1 This version of the Privacy and Cookies Policy was last updated on 24 May 2018.

4.2 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.

5. Third-Party Links

5.1 Our Site 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 Site, We encourage you to read the Privacy and Cookies Policy of every website you visit.

6. The data We collect about you

6.1 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 identifying properties of the data have been removed.

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

6.2.1 Identity Data includes your first name, last name, country, organisation, position, areas of interest and specialty.

6.2.2 Contact Data includes your email address and telephone number.

6.2.3 Technical Data includes your 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 Our Site.

6.2.4 Profile Data includes your password, interests, preferences and feedback.

6.2.5 Usage Data includes information about how you use Our Site, products and services.

6.2.6 Marketing and Communications Data includes your preferences in receiving marketing from Us and Our third parties and your communication preferences.

6.3 We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 and Cookies Policy.

6.4 We do not collect any Special Categories of Personal Data about you (this would include 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.

7. If you fail to provide personal data

7.1 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 provide you with services from Our Site and We will notify you if this is the case at the time.

8. How is your personal data collected?

8.1 We use different methods to collect data from and about you including through:

8.1.1 Direct interactions. You may give Us your Identity and Contact Data by filling in forms or by corresponding with Us by email or otherwise. This includes; personal data you provide when you create an account on Our Site, subscribe to Our newsletter, request information be sent to you or give Us some feedback.

8.1.2 Automated technologies or interactions. As you interact with Our Site, We may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see Our cookie policy for further details.

8.1.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

9. How We use your personal data

9.1 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:

9.2 Where We need to perform the contract We are about to enter into or have entered into with you.

9.3 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.

9.4 Where We need to comply with a legal or regulatory obligation.

9.5 Generally We do not rely on consent as a legal basis for processing your personal data other than in relation to sending our newsletter to you via email. You have the right to withdraw consent to marketing at any time by contacting Us.

10. Purposes for which We will use your Personal Data

10.1 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.

10.2 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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new user (a) Identity
(b) Contact
Performance of a contract with you as a user of Our Site
To manage Our relationship with you which will include:
(a) Notifying you about changes to Our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you as a User of Our Site
(b) Necessary to comply with a legal obligation
(c) Necessary for Our legitimate interests (to keep Our records updated and to understand how Our services are used)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them and grow Our business)
To administer and protect Our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for Our legitimate interests (for running Our business, provision of administration and IT services, network security)
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the advertising We serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for Our legitimate interests (to study how Our services are used and to develop them)
To use data analytics to improve Our Site, services, marketing and user experiences (a) Technical
(b) Usage
Necessary for Our legitimate interests (to define types of users for Our services, to keep Our Site updated and relevant, to develop Our business and to inform Our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for Our legitimate interests (to develop Our services)

11. Opting Out

11.1 You can ask Us to stop sending you messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your account preferences or by following the opt-out links on any marketing message sent to you or by contacting Us at any time.

12. Cookies

12.1 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

12.2 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

12.3 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for collection of usage statistics. These Cookies are not integral to the functioning of Our Site.

12.4 All Cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law.

12.5 Before Cookies are placed on your computer or device, you will be shown a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies but this may result in certain features of Our Site not functioning as intended.

12.6 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be "strictly necessary". These Cookies are shown below. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser's settings, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

12.7 The following first party Cookies may be placed on your computer or device:

Name of Cookie Purpose Strictly necessary
Cfid Used to provide transaction support across multiple page requests commonly called a session. This is persistent (until a user deletes it) and contains a random generated number. Yes
Cftoken Used to provide transaction support across multiple page requests commonly called a session. This is persistent (until a user deletes it) and contains a random generated alpha-numeric piece of text Yes

12.8 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

12.9 The analytics service used by Our Site uses Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below.

12.10 The analytics services used by this Website uses the following Cookies:

Name of Cookie First/Third Party Provider Purpose
_utma (unique visitor cookie) Third Google Analytics This cookie is used to identify unique visitors. It expires after 2 years from the date it was last refreshed. Every time a new hit is sent to google analytics, the cookie is refreshed.
_utmb (session cookie) Third Google Analytics This cookie is used to identify a web session and to store information about the session. Google Analytics end the web session when this cookie has expired. When your visitor loads a web page, the Google analytics tracking code check for _utmb cookie on the visitor's hard disk. If this cookie is missing then Google Analytics treats the session as a new session and creates a new _utmb cookie. If the cookie is already present than Google Analytics update the cookie to expire in 30 minutes.
_utmc (session cookie) Third Google Analytics The _utmc cookie is not used by ga.js any more but is still set on a user's hard disk for interoperability with urchin.js. Historically this cookie worked along with _utmb cookie to identify a web session. The _utmc cookie expires as soon as you close the browser window.
_utmt Third Google Analytics The _utmt cookie is used to throttle the request rate and it expires after 10 minutes.
_utmv (visitor segmentation cookie) Third Google Analytics This is a visitor segmentation cookie which is used by Google Analytics to identify a visitor as male, female, member, non member, signed in or signed out visitors, pro-member, pro++ member, employee, nonemployee etc. This cookie expires after 2 years from the date it was last refreshed. Every time a new hit is sent to google analytics, the cookie is refreshed.
Facebook Pixel Third Facebook This Cookie is placed by Facebook. It enables the Extractives Hub to measure, optimise and build audiences for advertising campaigns served on Facebook. For further information about the Facebook Pixel please see: https://en-gb.facebook.com/business/help/651294705016616

12.11 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

12.12 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

12.13 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

13 Change of purpose

13.1 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.

13.2 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.

13.3 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.

14. Disclosures of your personal data

14.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in clause 10 above.

14.1.2 We share your personal data with Skotkonung Ltd, who, acting as a data processor provide IT and system administration services to Adam Smith International Ltd, which is based within the European Economic Area.

14.1.3 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the European Union who provide consultancy, banking, legal, insurance and accounting services.

14.1.4 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

14.1.5 Third parties to whom We may choose to transfer Our assets.

14.1.6 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.

15. International Transfers

15.1 We do not transfer your personal data outside the European Economic Area.

16. Data Security

16.1 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.

16.2 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.

17. Data Retention

17.1 We will only retain your personal data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

17.2 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 requirements.

17.3 In some circumstances you can ask Us to delete your data see clause 19.1.3 below for further information.

17.4 In some circumstances We may 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.

18. Your Legal Rights

18.1 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 below please contact Us.

18.2 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 may refuse to comply with your request in these circumstances.

18.3 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.

18.4 We try to respond to all legitimate requests within one month. Occasionally it may 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.

19. Your Rights

19.1 You have the right to:

19.1.1 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.

19.1.2 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.

19.1.3 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.

19.1.4 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.

19.1.5 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:

19.1.5.1 If you want Us to establish the data's accuracy.

19.1.5.2 Where Our use of the data is unlawful but you do not want Us to erase it.

19.1.5.3 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.

19.1.5.4 You have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to use it.

19.1.6 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.

19.1.7 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.