Effective date: May 14, 2018
Foreign Policy, 11 Dupont Circle NW, Suite 600 Washington, DC 20036, USA
Purposes of Processing
FP processes personal information to:(i) process your registration or subscription and enter into a contract, (ii) when you provide your explicit consent, (iii) for our legitimate business interests such securing and protecting the integrity of this Site, and for Site and product development; and as permitted to meet by applicable legal requirements.
The minimum information we need to register you to our Site is name, email address, login ID, password, country, job title, and job industry. Registering for the Site and subscribing to our content are completely voluntary. If you do not provide the required information, we may not be able to process your registration or subscription. During the registration process, you will have the ability of choosing to opt-in to receiving promotional emails, e-newsletters, and to access certain content on the Site. At any point in time, you can choose to unsubscribe to these email communications by contacting us at the location in the Contact Information section.
How We Collect, and Use Your Personal Information
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.
When you provide personal information, it is being provided directly by you to us, unless we receive it from publicly available sources such as a social media site.
If we are involved in a reorganization, merger, acquisition, bankruptcy or sale of our assets, your personal information may be transferred as part of that transaction. 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.
You may receive marketing emails from us, only if you agree to do so. Before sending any marketing communications we will make it clear to you during the registration or subscription process to check boxes or otherwise to “opt in” to receiving marketing emails and providing you the ability to change your preferences if you no longer want to receive them. We also may email you occasionally with information or questions about your registration or your subscription account with reminders, warnings, or other types of requests. We will collect and use individual user details if we have your permission or we have a legitimate interest for doing so, for example, collecting enough information to manage your subscription.
How do we Protect Your Personal 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 reasonable technical and organizational measures designed to protect your personal information 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.
International Transfers of Personal Information
Please be aware that the personal information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store personal data in the United States. Foreign Policy has executed standard contractual clauses to legitimize these data transfers.
Data Storage and Retention
Your personal information is stored on our servers and on the servers of database management service providers that we have engaged which are located in the United States. We retain data for the duration of the relationship you have with us.
Third Party Sites and Links
- For statistical purposes. For example, we track how many users we have and how often they visit the Site and which pages are the most frequently visited.
- We sometimes use other organizations to collect anonymous user information through cookies and web beacons (information embedded in images which allow them to analyze how the website is being used and the number of visitors).
- Placing cookies on your computer so we can show you advertisements you might be interested in, allowing us to control the number of times you see them and measure how effective the advertising campaign has been.
- Using cookies to suggest and deliver content which we believe may interest you.
We currently use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit http://www.google.com/policies/privacy/partners/.
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.
Sharing of Your Personal Information
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 firstname.lastname@example.org and asking us not to release your name to third parties.
We do not otherwise sell, share or disclose your personal information to third parties other than those parties necessary to fulfill your registration or subscription. These include trusted third parties that provide services on our behalf, including Site development, maintenance and support, fulfillment, payment processing, and email distribution.
Children under the age of 16
Your California privacy rights
While we do not provide your personal information to third parties for their marketing use, under California law, California residents may opt-out of disclosing their personal information to third parties for their marketing purposes.
Accuracy of personal information
While we take various steps to ensure the accuracy and completeness of your personal information, we rely upon you to provide accurate and complete Information when interacting with us.
Your Rights in Connection with Your Personal Information
Under certain circumstances, and as required by applicable law you have the right to:
- Request access to your personal information. This enables you to receive a copy of the personal information we hold about you.
- Request correction of any incomplete or inaccurate personal information that we hold about you.
- Request erasure of your personal information when there is no need for us continuing to process it or you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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.
- Request the restriction of processing of your personal information to suspend the processing, for example if you want us to verify its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to exercise any of these rights, please contact the Data Protection Officer in writing per the ‘Where to turn with questions’ section of this Policy. Valid requests will be honored within 30 calendar days of request. This 30-day period may be extended for another 2 months for complex requests with notification of the reasons for the extension to you. Any such requests should be submitted using the information listed in the Contact Information section.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. In addition, there may be requests that we are unable to process because of other EU legal requirements. If a request is denied, we will notify you of the reason.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you are located in the EU, you have the right to lodge a complaint with an EU Supervisory Authority. However, if you have a complaint regarding the processing of your personal information we request that you first contact us and we will reply on timely basis.
As it pertains to users of this Site located in the EU, the controller of your personal information is Foreign Policy.
Contact information for our EEA GDPR Representative:
Kaplan U.K. Limited
Attn: EEA GDPR Representative
Warwick Building, Kensington Village
London, England, W14 8HQ