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About this Policy

Thank you for visiting our website. We highly value your interest in our products and services and your privacy is equally important to us. We would like you to feel at ease with how we use and share your personal information. This policy outlines how the ultimate parent company of Reachers Online handle your personal information. This includes when and why it is collected, used and disclosed, and how it is protected. If you have any questions you will find our contact details at the end of this policy. Details on how to update or access your personal information, or how to make a complaint, are also included. This policy may be liable to change. Please check this page from time to time to ensure that you are informed of any changes. For information about when we might make changes to this policy and how we would tell you about them, please see Section 11 below. This policy contains details of the enhanced rights data subjects (living individuals in respect of whom personal information is processed) granted by the General Data Protection Regulation (EU 2016/679).

Who we are

Reachers Online comprises of one company in the India. For further details, please view section 13. Whenever you deal with Reachers Online, the controller of your personal information will be Reachers Online. A ‘controller’ is a company that manages and decides why and how your personal information is processed. Where this policy refers to “we”, “our” or “us” below, unless stated otherwise, it refers to the particular company that is the controller of your personal information.

How and what Personal Information we Collect

We may collect and process the following personal information about you Personal information you give to us: This is information about you that you have provided by entering information via our websites, our social media pages or when corresponding with us via phone, email or otherwise. The information is provided voluntarily. The information that you give us and why we process that information includes the following: Subscription information: Information about you which relates to your account with us. This information may include your name, your email address and your telephone and/or mobile number. We will process this data to maintain your subscription with us, to provide our services to you, to communicate with you and to back up our database. The reason we process this data is to ensure the proper administration of your subscription and our business and, where you have entered into a contract with us, for the purposes of fulfilling our contract with you. Registration Information: Information you provide when you register to use our website, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number. We will process this data so we can deal with your registration, or other communications or applications, or to address your query or concern. The reason we process this data is to ensure the proper administration of your registration and our business. Transaction Data: If you purchase products and/or services from us through our website, you will need to provide certain information to us so that we can supply those products / services to you. The information you supply to us may include your name, your contact details, your card details and other information relevant to your transaction We will process that data in order to perform our contract with you and to fulfil the transaction. This is also our reason for processing the data (our legitimate interest). Communication Data: If you communicate with us, we may process the information contained in your communication. This information may include your name and contact information, the content of your communication and any metadata our website generates where you communicate with us using the contact form available on our website. We will process that information so we can correspond with you and keep records of such correspondence. The reason we are processing this data is to ensure the proper administration of our business (our legitimate interest). Notification Data: Where you have purchased products/services from us, or where you subscribe to receive our email notifications and/or newsletters, we will process your data so that we can send such products / services /email notifications and/or newsletters to you. If you prefer not to receive such communications please click here to unsubscribe. The legal basis for us processing this data is that you have consented to such processing Regulatory Data: We may process your data if we need to do so in order to comply with our legal and/or regulatory obligations, so that we can protect the vital interests of you or another natural person. The reason we will process such data is to protect the vital interests of you or another natural person. Personal information we collect about you: We may automatically collect the following personal information: our web servers collect and store as standard details of your browser and operating system, the website from which you visit our website, the pages that you browse on our website, and the date of your visit. For security reasons (to identify attacks on our website) the Internet protocol (IP) address that is assigned to you by your internet service is also collected. Some of this information is collected using cookies – please see Cookies in Section 9.2 for further information. We may also collect other personal information that you allow to be shared as part of your public profile on a third party social network. Personal information we may receive from other sources: We may obtain certain personal information about you from sources outside of our business. These may include Reachers Online group companies (Section 13) or other third party companies; the personal information that is received is listed in the paragraphs above. For information about Withdrawing your consent please see Section 8.3 for further details. Please view How we use your personal information in Section 4 for details about the purposes for which we use the personal information that is obtained from these sources, and the legal basis on which we rely to process the information. The additional provisions of this policy also apply to any personal information that is obtained from these sources.

How we use your Personal Information

There are various reasons why we use your personal information. These are as follows:

4.1 Where you have provided CONSENT

We may use and process your personal information where you have permitted us to do so for the following purposes:

• To advise you about Reachers Online content and subscription offers;
• To supply Reachers Online magazine and other material that you have specifically requested from us;
• To contact you via email, SMS, post or telephone with marketing information about Reachers Online and other products and services (see Marketing section below for more details);
• To share your personal information with our authorised joint processors or our recommended third party partners for us to contact you on their behalf with marketing information about their products and services. Please view the Marketing section below in this policy for further details.

You may withdraw your consent for us to use your personal information in any way at any time. Please view Withdrawing your consent in Section 8.3 for more details. You can also visit our marketing preferences page here.

4.2 Where required to perform a CONTRACT with you

We may use and process your personal information where necessary for the performance of a contract with you, or in order to take action at your request before entering into a contract with you for the following purposes:

• To exchange information for registration and subscription services
• To allow for the provision of fulfilment
• To engage in a live event

4.3 Where it is in your VITAL INTEREST

We may use your personal information in order to contact you in any urgent communication such as the cancellation of a live event due to safety reasons.

4.4 Where required to comply with our LEGAL OBLIGATIONS

To comply with our legal obligations we may use your personal information as follows: (i) to liaise with a public authority or criminal investigation body; (ii) to identify you when you contact us; (iii) to verify the veracity of the personal data that we hold about you.

4.5 Where there is a LEGITIMATE INTEREST

We may use and process your personal information where necessary in order for us to pursue our legitimate interests as a business for the following purposes:

• for profiling and analysis to inform our marketing strategy, and to enhance and customise your personal customer or visitor experience;
• for market research in order to continually improve and enhance the quality of products and services that we and our authorised partners deliver to you;
• to administer our websites and for internal operations, including troubleshooting, testing assessment and statistical purposes;
• for marketing activities (not including where we rely on your consent) e.g. to personalise marketing communications;
• for the prevention of fraud and criminal activities;
• to undertake finance credit checks;
• to correspond and communicate with you;
• to establish a better understanding of you as a valued customer or visitor;
• for network and information security in order for us to take required steps to protect your information against loss, damage or theft or unauthorised access to your Reachers Online Account.
• to comply with all requests from you in connection with the exercise of your rights (e.g. if you have asked us not to contact you for marketing purposes we will keep a record of this on our suppression lists, so that we can comply with your request);
• for the purposes of corporate redeployment or reorganisation, or for the sale of our business or assets;
• for the efficiency, accuracy, productivity or further improvements of our databases and systems e.g. when combining systems or consolidating any records that we or our group companies hold about you;
• to enforce or protect our contractual or other legal rights, or to bring or defend legal proceedings; and
• for general administration including managing your queries, complaints, or claims, and to send you any service messages.

Others who May Receive or Have Access to Your Personal Information

5.1 Group companies

We may disclose your information to Reachers Online for the purpose of processing. Reachers Online and its group companies share the infrastructure, systems and technology, and work together to understand how users interact with the products and services as well as share insights to improve them. Reachers Online is part of the Daily Mail and General Trust plc Group (“DMGT”). Members of DMGT may, use and share, within that group, the information you provide and other information held about you for the purposes set out in this Policy. The legal basis for processing your data is legitimate interest. For more information about the DMGT group please see the DMGT website and the DMGT Privacy Policy.

5.2 Our suppliers and service providers

We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purpose of providing products and/or services to us or directly to you on our behalf. These third parties may include cloud services providers (for hosting and email management), advertising agencies, administrative services or supplementary third parties that provide additional services to us. When we use third party service providers, we only disclose personal information that is necessary for them to provide their service. We have a contract in place that requires them to protect your information and not to use it other than in accordance with our specific instructions and requests.

5.3 Third parties

We may also disclose your personal information to third parties in the following circumstances:

• If we sell or buy any business or assets, in which case we may need to disclose certain personal data to the prospective seller or buyer of such business or assets.
• If all or most of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any legal agreement we have with you; or to protect our rights or property, or the safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Reachers Online collects information from you in two ways: directly from your input and automatically from your use.

Information you provide

The types of personal information that Reachers Online collects directly from you may include:

• Contact details, such as your name, email address, postal address and telephone number;
• Usernames and passwords;
• Job details and other professional background information;
• Comments, feedback and other information that you submit to Reachers Online; and
• Interests and communications preferences.

We may, with your consent, tell you about products and services supplied by other group companies or third parties. In these cases, your personal data is never disclosed. We will send you information about a product and/or service on behalf of a partner., Our partners never receive any information about you, unless you choose to correspond with them directly after you have received the communication from Reachers Online.

Where we Store your Personal Information

Due to the global nature of the products and services we offer, it may be necessary for the information that you provide us to be reassigned to countries outside of the European Economic Area (EEA). This may happen where any of our group companies are incorporated in a country outside of the EEA, or if any of our servers or our third party service providers are situated in a country outside of the EEA. If we do transfer your information outside of the EEA, we will always take necessary steps to ensure that appropriate security measures are taken so that your privacy rights continue to be protected, as detailed in this policy. These steps include imposing contractual obligations on the recipient of your personal data and ensuring that recipients are subscribed to recognised ‘international frameworks’ that ensure the same protection. If you use our services whilst you are outside the EEA, your personal data may be transferred outside the EEA, in order for us to provide you with the services.

How Long we Keep your Personal Information For

The duration of time that we retain your collected personal data is determined by us, in a reasonable manner, based on a number of factors. These include the purpose for which we use the information and our obligations under other laws. We only preserve personal data in an identifiable format for the period of time that is necessary. Your personal information may be required to establish, bring or defend legal claims. In this case, we retain your personal data for 7 years after the last occasion on which we used the information in one of the ways that is specified in How we use your personal information in Section 4. The only exceptions to this are where:

• the law requires us to retain your personal data for a longer period, or to delete it sooner;
• you exercise your right to have the information deleted (where it applies) and we do not need to retain it in connection with any of the reasons permitted in this section 7;
• we may need to retain your personal data where this is necessary to comply with our legal or regulatory obligations, or to protect the vital interests of another natural person.

Your Rights

Your ‘data subject’ rights: Under data protection law, you have a number of rights in relation to your personal information. If you wish to exercise any of your rights, we may ask you for information to confirm your identity.

8.1 Accessing your personal information

You have the right to request a copy of the personal information that we hold about you. To make a request, please email or write to us at the address at the end of this policy. Alternatively you can use our online form to make a request to access your information. You do not have to pay us a fee to access your personal information unless we believe your access request is unfounded, repetitive or excessive. In this case we may charge you a reasonable fee to access your personal information or we may decide not to comply with your request. We will notify you if this is the case.

8.2 Correcting and updating your personal information

The accuracy of your information is important to us and we are continually developing ways in which to make it easier for you to review and amend the personal information that we retain. In the meantime, if you change your name or address/email address, or you find that any of the information that we hold about you is incorrect or out of date, please let us know by contacting us via the means described at the end of this policy.

8.3 Withdrawing your consent

You may withdraw your consent as the legal basis for processing your personal information at any time. To do this, please contact us via the details provided at the end of this policy. You can use our unsubscribe tool to withdraw your consent to receiving any direct marketing that you previously opted-in for. You can also update your preferences by clicking here. If you withdraw your consent, our use of your personal data prior to your withdrawal remains lawful.

8.4 Objecting to our use of your personal information and automated decisions made about you.

You may object to us using your personal data for these purposes by contacting us in writing by any of the means stated at the end of this policy. We will temporarily stop processing your personal information in line with your objection request until we have investigated the matter further, except for the purposes for which we are sure we can continue to process your personal information. If we agree that your objection is justified, in accordance with your rights under the data protection laws, we will permanently cease using your information for those purposes. If we do not agree, we will provide you with our justification as to why we are under obligation to continue using your data. We will automatically comply with your request if you object to us using your personal data for direct marketing purposes. Please use our unsubscribe tool if you would like to do so. To contest any decision that is made about you based on automated processing, please contact the data protection department using the details at the end of this policy.

8.5 Erasing your personal information or restricting its processing

You have the right to ask for your personal information to be removed from our systems. You can do this by emailing or writing to us at the address stated at the end of this policy. You can also use our online form to make a request to delete your personal information. You may also ask us to stop or limit the processing your personal data in the following situations:

• where you believe we are unlawfully using your personal data,
• you have objected to our use of your personal data and have a pending investigation, or you require us to retain your data in connection with legal proceedings.

8.6 Transferring your personal information in a useable format

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, you may request a copy of that information in a useable format. This means providing your personal information electronically in a structured, commonly used computer format, such as a Microsoft Excel File or XML. You may request that your personal information is directly sent to another service provider. We will do so if it is technically feasible. If your personal information concerns other individuals, or we have another lawful reason to withhold that information, we may not provide you with a copy of your personal information in a useable format.

8.7 Complaining to the India data protection regulator

You have the right to complain to the Information Commissioners Office (ICO) if you have any concerns about the manner in which we have processed your personal information. Please visit the ICO’s website for further details.

Security / Cookies / Links / Social Plugins

9.1 Security measures we put in place to protect your personal information Reachers Online and its group companies (see section 5.1) use technical and organisational security measures to protect all personal information that is supplied by you and managed by us against manipulation, loss, destruction, and access by any third party. We are continually improving our security measures in line with advancements in technological developments. The transmission of information via the internet is unfortunately not completely secure. Although we will do our best to safeguard and protect your personal data, we cannot guarantee the security of your information whilst it is in transit to our website, and all transmission is at your own risk. Where you have chosen a password that enables you to access an account, you are solely responsible for keeping this password private and confidential. We request that you not to share your password with anyone.

9.2 Use of ‘cookies’

‘Cookies’ are small files of information that are directly sent to your device and are stored on its hard drive to allow our websites to recognise you whenever you visit. Further information on the cookies that we use and their features can be found in our Cookie Policy.

9.3 Links to other websites

Our website may contain links to other websites and applications (Apps) that are operated by other organisations that we do not control. This policy does not apply to those other websites and Apps. We strongly advise you to read their privacy terms and statements. We are not responsible for the privacy policies and practices of other websites and Apps, even if you access them using the links that we have provided. The links to these websites are solely provided for your information and convenience. We disclaim all liability and responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or diligence. All disclosure of personal information to third party websites is at your own risk. Additionally, if you have linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website. We recommend that you check the policy of the third party website.

9.4 Social plugins

We use the social plugins (buttons) of popular social networks like Facebook, Google+ and Twitter. When you visit our websites these buttons are deactivated by default. This means that you do not need to intervene in order to stop your personal data being sent to the respective social networks. To use these buttons you must activate them by clicking on them. They will remain active until you deactivate them or you delete your cookies. Please view Cookies in Section 9.2 for further information regarding our use of cookies. After activation, the server of the respective social network establishes a direct link. The contents of the social plugins button are then transmitted from the social network directly to your browser, and are then incorporated in our website. Following activation, the social network can retrieve data independently of whether you interact with the button or not. A social network cannot assign a visit to any websites that are operated by our other group companies unless, and until, you activate the respective button. If you are a member of a social network and you do not wish it to combine the data that has been retrieved from your visit to our websites with your personal membership data of that social network, you must log out from the social network before activating the buttons. We have no influence over the range of data that is collected by the social networks via their buttons. The information on the purpose and extent of the collected data can be found in the data use policies of the relevant social networks.

Marketing

In order to send you marketing information directly from us via email/SMS (where applicable), we will collect your marketing preferences We will only send you marketing information and communications if you have consented to receive such information directly from us. With your consent, We may contact you with targeted advertising delivered online through social media and platforms that are operated by other companies, by using your personal data. Unless you object, we may use your personal information to customise and improve the relevance of direct marketing to you. We will only share your personal information with other group companies or selected third parties, so that they can contact you with product and service marketing information, where you have consented to us doing this. Please use our marketing preferences page to find out more about these group companies and third parties and to update your consent preferences. If your personal information is shared, the relevant group company’s or third party’s privacy policy will apply to their processing of your personal data, not ours. You can opt-out of receiving marketing from a group company or third party, at any time by directly contacting the relevant group company or third party. If you opt-in to receiving marketing from our other group companies or selected third parties you will receive marketing from the group companies or third parties listed in the table below via your preferred communication method: Occasionally, we may request that you refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

Changes to this Policy

From time to time, we may review this policy. You will be notified of any changes via email, or via the posting of an updated version on our website. All changes take effect 7 days after the date of our email, or the date on which we posted the modified terms on our website. We recommend that you regularly check for changes and that you review this policy when visiting our website. If you do not agree with any aspect of the updated policy, you must notify us promptly and cease using our services.

Contact us

If you have any questions, comments or requests about the processing of your personal information, or you wish to contact us to amend or update your marketing preferences, please contact the Reachers Online Data Protection Co-ordinator using the following details. Reachers Online s Data Protection, Noida India Email: contact@reachersonline.com