Privacy Policy For foreignpolicy.com

Foreignpolicy.com, (“FP”, “we” or “us,”) is committed to protecting the privacy of our subscribers and visitors to the website www.foreignpolicy.com (the “Site). Visitors to the Site may view certain limited content without providing any information.   Visitors who wish to view or subscribe to additional content may voluntarily register or subscribe as described on the Site and in this Privacy Policy.

This Privacy Policy applies to users of our Site (“users”), which includes any person who accesses our Site. Users may be referred to in this Policy as “user,” “you” or “your.” The Terms and Conditions for the use of our Site are posted at http://www.foreignpolicy.com/termsofuse.   The Site is sponsored by foreignpolicy.com, which is owned by Graham Holdings Company, “FP Companies.” This Privacy Policy applies to the use of information collected by us online, and offline if you subscribe offline, as described in this Policy.

This Privacy Policy was last updated on January 21, 2015.  We may change this Privacy Policy from time to time so please check back regularly to keep informed of updates.   If you do not agree to this Privacy Policy or any changes to this Privacy Policy please do not email us, register on the Site or subscribe to our content. Any information collected by us shall be used only in a manner consistent with this Privacy Policy.   By accessing our Site and by providing information to our Site, you expressly agree to the use of your Personal Data for such purposes. foreignpolicy.com follows recommendations of the US-EU and US-Swiss Safe Harbor frameworks.

Foreignpolicy.com uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible.

If you have questions or concerns regarding our Privacy Policy, you should first contact privacy@foreignpolicy.com.

Personal Data

Personal Data, or personally identifiable information, is information about you that you provide to us that is personally identifying, such as your name, address, email address, or telephone number, and that is not otherwise publicly available (“Personal Data”).   The definition of Personal Data or Personally Identifiable Information depends on your physical location and may include other types of information. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

Credit Card Information

Credit or debit card information and personal financial account information is considered “Sensitive Information.”   We do not collect credit card, debit card or personal financial account information when you register for the Site or subscribe to our content, because we use a third party vendor, Bank of America via our fulfillment vendor Cambey & West, to process our subscription billing.   When you provide payment information to subscribe to our content you provide it directly to Bank of America and not to foreignpolicy.com. Bank of America is a third party vendor and has its own privacy policy, which may be different from ours. This Privacy Policy does not cover bank of America and foreignpolicy.com is not covered by Bank of America’s privacy policy. To learn about Bank of America’s privacy practices, please read their privacy policy at http://bankofamerica.com/privacy.

100% Opt-In

Sending us emails, registering for the Site and subscribing to our content are completely voluntary and are by opt-in only.  You can opt-in by registering for the Site, subscribing to our content, or by emailing us for information.  When you opt-in, you will also be opting-in to receiving promotional emails from us and other FP companies.   If you do not opt-in you will not have access to certain content on the Site, you will not receive a subscription to certain content provided by foreignpolicy.com, and we will have no way of contacting you to respond to your inquiries or requests for information or to send you newsletters or other promotional information from FP companies.   By opting in you are providing your express consent to the collection, use, retention, processing, transfer, and disclosure, including cross-border disclosure, of your Personal Data as explained in this Privacy Policy.

Collection and Use of Personal Data

Registration: When you register for the Site we collect your first name, last name and email address in order to deliver requested items such as the FP e-Alert newsletter, purchased products, content or Forum access, or magazine subscriptions.   We also collect your username and password, so we may track your usage of the Site internally and make your experience more enjoyable and convenient.   We also collect non-personally identifying information such as your job title and industry in order for us to learn more about our customer base and to tailor our offerings.

Subscribing: When you subscribe to FP ALL ACCESS online, we collect your first name, last name, email address, phone number and postal address in order to deliver the requested items in our FP ALL ACCESS subscription and to manage your account.   We also collect non-personally identifying information such as your job title and company in order for us to learn more about our customer base and to tailor our offerings.

Subscribing by postal mail: We collect your first and last name, postal address, email address and telephone number when you subscribe by postal mail in order to process your subscription and manage your account. This information is added to our electronic database and is treated the same as information collected by us online once it is in our database.

When you email us: We collect your email address online if you email our website for information or to share your opinions or insights, so we may respond to you.

When you provide an email address through registering, subscribing, or emailing us, we place your email address on our distribution list to receive promotional information such as newsletters and press releases from our related FP COMPANIES and us. Canadian residents will not receive promotional emails without their express consent as defined under the Canadian Anti-Spam Law (CASL). You may opt out of receiving promotional emails at any time by clicking “unsubscribe” as indicated on the promotional emails you receive.  We retain your email address to continue sending promotional information as long as you do not opt out of receiving further emails.

When you register for the Site or subscribe to our content, we collect your IP address for analytic purposes. If you have access to the Site through a business or employer account, we use your IP address to identify you with the account so you may access the Site.

We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site if you connect to our Site through that site.

Our collection of Personal Data is limited to the collection of necessary and adequate information required to accomplish the purposes described above.

When you provide Personal Data, it is being provided directly by you to us, unless we receive it from publicly available sources such as a social media site.    When you provide Personal Data to us you agree to ensure that it is accurate, up to date, and correct.   In order to change or update your Personal Data, please see the “Contact Us” section below.  If all or part of the requested Personal Data is incorrect or is not provided, the information you requested may not be delivered to you.

If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

How do we Protect Your Information?

We implement a variety of security measures to maintain the safety of your information when you enter, submit, or access your information online. We implement technical and organizational measures to protect Personal Data against accidental or intentional destruction or loss, and unauthorized disclosure or access.

Product, content, and subscription purchases made on foreignpolicy.com are directed through a secure transaction server to protect your personal and financial information.

Choice and Consent

By emailing us or by registering or subscripting to our content, you expressly consent to the collection, use, retention, transfer and disclosure, including cross-border disclosure, of your information as described in this Privacy Policy and our Cookie Policy.  Each time you email us, or renew a registration or subscription, you are giving your express consent to the collection, use, retention, transfer and disclosure, including cross-border disclosure, of your information as described in this Privacy Policy and our Cookie Policy.

If you wish to opt out and withdraw your consent, you may do so at any time by clicking “unsubscribe” on any electronic communication or by writing to: privacy@foreignpolicy.com.   If you opt out and withdraw your consent you will no longer be able to view or receive certain content and we will not have any means by which to respond to your questions or comments that you email to the Site or to provide you with newsletters or other promotional information.   If you wish to disable cookies, please see our Cookie Policy.

International or Cross-Border Transfer of Your Personal Data and Your Express Agreement

Given that the Internet operates in a global environment and that transfer of your data is necessary to process your registration and subscription, to respond to your email requests and comments, and to send you promotional emails, using the Internet to collect and process Personal Data necessarily involves the transmission of data on an international, or cross-border, basis.  By registering or subscribing to our content and/or communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Data in this way.

The Personal Data of users who are located outside the U.S. will be transferred outside of each eligible country to the United States where our servers are located and where it will be processed and stored on servers owned and operated by our parent Graham Holdings Company. The U.S. does not provide an adequate level of protection according to EU data protection regulations. We will take steps reasonably necessary to ensure that users’ Personal Data is treated securely, but will not otherwise take steps to ensure compliance with applicable laws in each user’s country of residence. By registering or subscribing to the Site or by sending us emails, you expressly agree to such transfer and disclosure.

California Do Not Track Disclosures and Other Disclosures under CalOppa

We currently do not honor Do Not Track signals. Personal Data collected by us as described in this Privacy Policy is not maintained in personally identifiable form in combination with any identifier collected by cookies, web beacons, or other technologies.

Third Party Sites and Links

Our Site may contain links to or features of other websites that are independent, are not owned or operated by us and which may incorporate Third Party Information. This includes third party social media websites and their features such as Facebook, Twitter or Flickr. The collection of information by third party websites is not covered by this Privacy Policy and such third party websites may have their own have separate and independent privacy policies.  If you access other sites or features using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours.  We therefore have no responsibility or liability for the content and activities of other websites, even if they are linked to our Site.

Do we Use Cookies?

When you visit the Site, we use session “cookies” — a piece of information stored on your computer — to allow us to uniquely identify your browser while you are logged in and to enable us to process your online transactions. Session cookies also help us confirm your identity and are required in order to login into your account. Foreignpolicy.com uses persistent cookies that only we can read and use, to identify you as a FP customer and make it easier for you to log into your account. Users who disable their web browsers’ ability to accept cookies will be able to browse our Site, but they may not be able to access all or parts of our Site. For further information about disabling or blocking cookies, please see ‘Can I withdraw my consent?’ in our Cookie Policy.   The use of cookies by our partners is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners use session ID cookies to trace user movement on the site.

Advertisement Choices

Online advertising for foreignpolicy.com is delivered by the vendor DoubleClick. DoubleClick places cookies on your browser to facilitate serving particular ads – for instance, to help determine whether you have seen a particular advertisement before, to tailor ads to you if you have visited our Site before, and to avoid sending you duplicate advertisements. You can opt out of DoubleClick’s use of cookies for these purposes by visiting http://www.google.com/intl/en/privacy/.

In some cases, we and advertisers on foreignpolicy.com and other sites work with other third-party vendors to help deliver advertisements tailored to your interests. These vendors include ad networks and audience segment providers, and they place cookies on your browser to collect information about your online activity (e.g., the sites and pages you have visited) in order to help advertisers deliver particular ads on our Site and other sites that they believe you would find most relevant. You can opt out of those vendors’ use of cookies to tailor advertising to you by visiting http://www.aboutads.info/.

Often our advertisers contract with a third-party service to host their ads. In this case, an ad-serving vendor contacts the advertisers’ hosting service for a particular advertisement. In that case, an independent cookie may be used by the third-party service. We do not have a mechanism to allow visitors to opt-out of cookies from vendors with whom we do not have a contractual relationship.

Clear Gifs

We employ or our third party advertising partner employs a software technology called clear gifs (also known as “Web Beacons” or “Web Bugs”), that help us better manage content on our Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Website users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Website Log Files

As is true of most Websites, we and our third party utility-tracking partners gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and click stream data.

We use this information to analyze trends, to administer the Site, to track users’ movements around the Site and to gather demographic information about our user base as a whole.

Do We Disclose Personal Data to Third Parties?

Occasionally, FP makes portions of its online and magazine subscription mailing list available to reputable companies and organizations whose products or services we feel may be of interest to you. Many of our subscribers find this a valuable and timesaving service. If you would rather not receive these mailings, you may opt-out by sending an opt-out request to privacy@foreignpolicy.com and asking us not to release your name to third parties. Please allow 12 weeks for your request to take effect.   Canadian residents will not be included on this list unless they send an email requesting to opt-in to receive such information.

We do not otherwise sell, share or disclose your Personal Data to third parties other than those parties necessary to fulfill your registration or subscription (our “Subcontractors”). These include trusted third parties that provide services on our behalf, including Site development, maintenance and support, fulfillment, payment processing, and email distribution.

We may also release your information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect our or other’s rights, property, or safety. Because our servers, which store your information, are located in the U.S.A., your information may be available to U.S. government entities or agencies under a lawful court order in the U.S.

By accessing our Site, sending us email, or by registering or subscribing to our content, you provide your express consent to our disclosure of your Personal Data to our Subcontractors for the purposes described in this Privacy Policy.

Children’s Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), as we do not collect any information from anyone under 13 years of age.  The Site and its content are directed to people who are at least 13 years of age or older.

Access to Your Information

You have a right to access, review, change, update or delete your Personal Data at any time by contacting us at privacy@foreignpolicy.com or by postal mail at Foreign Policy, 11 Dupont Circle NW, Suite 600 Washington, DC 20036, USA (“Data Controller” and “Data Recipient”).

Foreignpolicy.com commits to resolving complaints about your privacy and our collection or use of your Personal Data. Users with a need to provide a Notice to us under this Policy or our Terms of Use, or users with inquiries or complaints regarding this Privacy Policy should contact us:

  • By post: Foreign Policy, 11 Dupont Circle NW, Suite 600 Washington, DC 20036, USA
  • By email: privacy@foreignpolicy.com

Terms of Use

Please also visit our Terms of Use section establishing the use, disclaimers, and limitations of liability governing the use of our website at http://www.foreignpolicy.com/termsofuse.