1. PURPOSE OF OUR POLICY

The Market Mogul Limited (Company Number 09367922) of 79-81 Borough Road, London, SE1 1DN (hereinafter “we”, “us” or “our” in this Privacy Policy) provides the products and services offered on the Mogul News desktop and mobile application versions of the website mogul.news (hereinafter the “Site”).

We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you (hereinafter “Privacy Policy”).

In this Privacy Policy the term Data Protection Legislation means unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then any successor legislation to the GDPR or the Data Protection Act 1998.

For the purposes of the Data Protection Legislation, The Market Mogul Limited is the controller and responsible for your personal data.

We have adopted this Privacy Policy to ensure that we have standards in place to protect the data that we collect about individuals that is necessary and incidental to:

(a)            Providing the products and services that The Market Mogul offers; and

(b)            The normal day-to-day operations of our business.

By publishing this Privacy Policy we aim to make it easy for our users, customers and the public to understand what data we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their data in our possession.

 

2. WHO AND WHAT THIS POLICY APPLIES TO

We handle data in our own right and also for and on behalf of our customers and users.

Our Privacy Policy does not apply to information we collect about businesses or companies; however, it does apply to information about the people in those businesses or companies which we store.

The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.

If, at any time, an individual provides data or other information about someone other than himself or herself, the individual warrants that they have that person’s consent to provide such information for the purpose specified.

The Site is not intended for children (persons under the age of 18 years) and we do not knowingly collect data relating to children.

 

3. THE INFORMATION WE COLLECT

In the course of business, it is necessary for us to collect personal data. This information allows us to identify who an individual is for the purposes of our business, share data when asked of us, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the type of information we may collect is:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, job title, employer name, photograph, social media handles, biography, date of birth and gender.

Contact Data includes address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

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 and other technology on the devices you use to access the Site.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

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

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 feature on the Site. 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 Policy.

We do not collect any Special Categories of Personal Data (as defined by the Data Protection Legislation) about you (this includes 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.

 

4. HOW INFORMATION IS COLLECTED

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

Direct interactions. You may give us your Identity, Contact, Transaction, and Financial Data, or by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • create an account on the Site;
  • register to use our services;
  • submit content for publication;
  • provide information that we need to deliver our services;
  • subscribe to our newsletters, updates or publications;
  • request marketing to be sent to you;
  • enter a promotion or survey; or
  • give us some feedback.

Automated technologies or interactions. As you interact with the 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.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

  • analytics providers;
  • advertising networks; and
  • search information
  • Contact, Financial and Transaction Data from providers of technical, and payment services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly availably sources.

 

5. HOW DATA IS STORED

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.

By submitting your personal data, you agree to this transfer, storing or processing.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or

Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

 

6. WHEN DATA IS USED AND DISCLOSED

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:

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

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.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications, or surveys on behalf of third parties, sent to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us as outlined below.

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.

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.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new subscriber and create your account.(a) Identity(b) ContactPerformance of a contract with you
To manage and administer 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

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

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 the Site (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, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Site content, newsletters, briefings, push notifications, and marketing to you and measure or understand the effectiveness of the marketing we serve to you(a) Identity(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(a) Performance of a contract with you

(b)Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To publish articles and other content submitted by you.(a) Identity(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(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 use data analytics to improve the Site, products/services, marketing, customer relationships and experiences(a) Technical(b) UsageNecessary for our legitimate interests (to define types of customers for our products and services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or 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 products/services and grow our business)
To send third-party direct marketing communications, or surveys or polls on behalf of third parties to you via email or text message.(a) Identity(b) Contact

(c) Technical

(d) Usage

(e) Profile

Consent obtained by you.
To process and manage payments.(a) Identity(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

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

External third parties such as:

Service providers acting as processors based in the United Kingdom, or the United States (please see the clause 5) who provide IT and system administration services;

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services;

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; and

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.

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.

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.

 

7. THIRD PARTY ACCOUNTS

We may link your account with a third party (such as LinkedIn or Facebook) to our services to enable certain functionality, which allows us to obtain information from those accounts (including your profile picture, friends or contacts).

The information we may obtain from those services often depends on your settings or their privacy policies.

 

8. COOKIE POLICY

Our Site uses cookies to distinguish you from other users of our platform. This helps us to provide you with a good experience when you browse our platform and also allows us to improve our Site. By continuing to browse the site, you are agreeing to our use of cookies.

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.  You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

 

9. OPTING “IN” OR “OUT”

You can ask us or third parties to stop sending you marketing messages at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in order to receive service from us.

THE SAFETY & SECURITY OF DATA

We will take all reasonable precautions to protect an individual’s data from unauthorised access.  This includes appropriately securing our physical facilities and electronic networks.

The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed.  Each individual that provides information to us via the internet or by post does so at their own risk.  We cannot accept responsibility for misuse or loss of, or unauthorised access to, data where the security of information is not within our control.

We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s data to in accordance with this policy or any applicable laws).  The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.

If an individual suspects any misuse or loss of, or unauthorised access to, their data, they should let us know immediately.

We are not liable for any loss, damage or claim arising out of another person’s use of the data where we were authorised to provide that person with the data.

RETENTION OF DATA

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.

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.

Details of retention periods for different aspects of your personal data are available on request.

YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

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.

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.

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.

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.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.

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.

If you wish to exercise any rights set out above, please contact us directly using the following email: [email protected]

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

 

COMPLAINTS AND DISPUTES

If an individual has a complaint about our handling of their data, they should address their complaint in writing to the details below.

If we have a dispute regarding an individual’s data, we both must first attempt to resolve the issue directly between us.

If we become aware of any unauthorised access to an individual’s data we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

ADDITIONS TO THIS POLICY

If we decide to change this Privacy Policy, we will post the changes on the Site at www.themarketmogul.com/privacy. It is your responsibility to refer back to this Privacy Policy to review any amendments.

We may do things in addition to what is stated in this Privacy Policy to comply with the Data Protection Legislation and nothing in this Privacy Policy shall deem us to have not complied with the Data Protection Legislation.

 

CONTACTING US

All correspondence with regards to Privacy Policy should be addressed to:

The Data Controller: The Market Mogul Limited

Email: [email protected]

Correspondence address: 79-81 Borough Road, London, SE1 1DN

You may contact us by email in the first instance.