+44 207 183 3221  ·  info@etindex.com   

Level 39, One Canada Square, Canary Wharf, London E14 5AB

Engaged Tracking (ET) Index Ltd (trading as 'Engaged Tracking') ©2019. Company registration number: 08876852.

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LEGAL

PRIVACY POLICY
 

This privacy policy sets out how Engaged Tracking (ET) Index Ltd uses and protects any information that you give Engaged Tracking (ET) Index Ltd when you use this website.

 

Engaged Tracking (ET) Index Ltd protects the confidentiality and security of client information. We implement robust security procedures to ensure the ongoing protection of all client data.

 

We are committed to protecting the privacy and the confidentiality of your personal information. Access to personal information is limited to Engaged Tracking (ET) Index Ltd personnel and those authorized third parties who may host your data on our behalf (such as our third-party CRM provider, in our case HubSpot and Google) or may assist in providing the products and services you requested. Engaged Tracking (ET) Index Ltd maintains physical, electronic and procedural safeguards that aim to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.

 

Your Information Safe In Our Hands

When you contact us, provide us with your personal information or use our electronic services, you consent to Engaged Tracking (ET) Index Ltd processing the information, including but not limited to your name, company name, contact information, job role and preference information. This information is used by us and/or authorized third parties to support your interaction with us, to deliver our products and services and to contact you again about other services and products we offer. By submitting your personal information to Engaged Tracking (ET) Index Ltd you acknowledge and consent to Engaged Tracking (ET) Index Ltd processing your personal information accordingly.

 

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified (see details below).

Consent is required for  Engaged Tracking (ET) Index Ltd to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

 

You may withdraw consent at any time by filling out the Setting Your Preferences form. You can either revoke your consent to certain types of communications or ask for your removal from our database. Any changes you apply will be applied with immediate effect and you will receive an email confirming the changes.

 

Changes To Policy

This policy provides a general statement of the ways in which Engaged Tracking (ET) Index Ltd aims to protect your personal information. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our website.

This version of the policy is effective May 2018.

 

Full Privacy Policy 

  1. What is personal data?

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

 

  1. What personal data do we collect?

We only collect, process and store the minimum necessary personal data. We may collect the following information:

    1. name and job title,

    2. country of operations,

    3. contact information including email address, and phone number

 

We are not collecting sensitive personal data; such as ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences.

 

  1. Why are we collecting this data?

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

    1. to be able to perform our services

    2. for detailed service provision (see Preferences)

    3. to be able to disseminate our research output and webinar (event) invites

    4. for correspondence purposes (see Preferences)

    5. to periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided

In any event, we are committed to ensuring that the information we collect and use is appropriate for the above purposes, and does not constitute an invasion of your privacy. Furthermore, your information will only be used for the purposes you give your consent to in the Set Your Preferences section.

In terms of being contacted for marketing purposes Engaged Tracking (ET) Ltd would contact you for additional and specific consent.

 

  1. How is your data used by us?

In order for us to provide you with our services, we need to collect personal data. In essence, we use Personal data in Operations, Product improvements and Communications. We use your (personal) data to:

    1. manage our website’s traffic and for internal record keeping

    2. manage  subscriptions,

    3. process complaints,

    4. we may use the information to improve our products and services. We may contact you by email, phone, fax or mail,

    5. keep your email and marketing preferences up-to-date and the content of our communications relevant to you,

    6. we may also use your information to contact you for market research purposes.

    7. we do not use your data to make automated decisions – such as credit scoring, loan screening, profiling users or making employment decision

    8. We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting only if you tell us that you wish this to happen.

 

  1. How do we collect our data?

We collect Personal Data in a fair manner. We process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR).

    1. Personal data is collected from, either

      1. public sources (company annual reports, CSR reports, websites)

      2. events (event attendee guestlist, business cards)

      3. professional networking sites (where being contacted with relevant material is expected and implied; e.g. LinkedIn InMail)

      4. website registry/subscription (granular communications consent given by you)

 

  1. What are the legal bases of processing the data?

We process data only for business-to-business (B2B) communications.Our legal bases for processing for the personal data:

    1. Consent given by subject

      1. The data is processed for the specific purpose(s) the data subject identifies.

      2. The data subject is free to change the communications preferences at any time.

      3. Consent can be revoked at any time.

    2. Contractual obligation

      1. Processing of data is necessary in order to be able to fulfill our contractual obligations.

    3. Legitimate interest

      1. We collect contact details (e.g. phone numbers) for communication purposes with minimal privacy impact.

      2. We only collect personal data on subject who can reasonably expect the kind of communications (i.e. certain job titles, such as Responsible Investment Officer fall into this category).

      3. We might contact subjects via various third-party professional network channels (e.g. LinkedIn InMail, Bloomberg Terminal Email Platform) as the subjects by agreeing to the T&Cs of such networks imply interest in professional communications.

 

  1. How do you access the Rankings’ pages? (providing your data is mandatory)

In order to access the full Rankings database you are required to provide us with personal data, this enables us to create a user account to log into.

    1. In most cases you are allowed to visit our site without telling us who you are. However, to access the Rankings service’s pages we require you to provide us with your Personal data. If you choose to withhold any Personal data requested by us it may not be possible for you to gain access to certain parts of the site.

    2. Personal Data provided for accessing the public facing Rankings database will only be used to maintain records of the site’s users and we will not contact you with insights, communications or marketing materials, unless you specify it otherwise in your Setting Your Preferences.

 

  1. For how long are we keeping the personal data?

    1. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.  

    2. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices.

    3. We hold on to your Personal Data for the minimum amount of time necessary, usually for 6-12 months (as it is deemed acceptable and in-line with the industry we work in), or until you require us to remove your data.

 

  1. Who gets to see your data?

In short, only us and our contracted third-party data-processors (HubSpot and Google analytics) get to see your data.

    1. We may pass your personal data on to third-party service providers contracted to Engaged Tracking (ET) Index Ltd in the course of dealing with you.

    2. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf

    3. When they no longer need your data to fulfil this service, they will dispose of the details in line with Engaged Tracking (ET) Index Ltd’s procedures.

    4. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

    5. We distinguish two types of information we share with the above third parties; namely:

      1. Personally identifiable information

        1. we may share such information with HubSpot (our CRM service provider) for data storage and management purposes

        2. we may store such information in locations outside our direct control. E.g. servers where some of our storage capacity is hosted, such as Google Drive (cloud storage).

        3. under no circumstances such information is rented or sold to others by Engaged Tracking (ET) Index Ltd

      2. Non-personally identifiable information  

        1. we may share anonymous usage data, referring/exit pages, URLs with Google analytics

        2.  Google and its wholly owned subsidiaries may retain and use information collected during Your use of our Website. Google will not share Your Data with any third parties unless Google

          1. has Your consent;

          2. concludes that it is required by law or to protect the rights, property or safety of Google, its users or the public.

 

  1. When are you going to be contacted by Engaged Tracking (ET) Index Ltd?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

We will only communicate the kind of information you are interested in (e.g. research output, webinar invite, etc.) via the channels you choose (e.g. phone, email). See Setting Your Preferences.

 

  1. How do we store and process your data?

We store, process and maintain our databases using a third-party CRM software, HubSpot and our cloud based servers, hosted by Google (Google Drive).

We only collect and store the minimum necessary data, we do not retain data for longer than necessary, and we do not execute highly personalised e-marketing campaigns (our processing is simple, we assign you to lists, according to the preferences you set).

    1. Your information may be stored and processed in Europe (in the EU and in non-EU countries as well), or any other country in which Engaged Tracking (ET) Index Ltd or its service providers maintain facilities.

    2. Engaged Tracking (ET) Index Ltd may transfer your personal information to third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union, please note that we will only transfer personal information to a country and jurisdiction if they meet the same data protection laws as your jurisdiction.

    3. Our CRM provider, HubSpot, has a robust privacy program that is designed to align with many regions’ data hosting needs. HubSpot offers a Data Processing Agreement for EU-based customers.

    4. Similarly, Google has robust physical, software and personnel safeguards in place to protect our and your data (Google Cloud security).

 

  1. How do we ensure your data is secure?

Engaged Tracking (ET) Index Ltd is concerned with protecting your privacy and data, however, no method of transmission over the Internet or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Your information.

 

    • When you enter sensitive information (such as login credentials) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). 

    • HubSpot’s service is Privacy Shield certified. HubSpot is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.

    • The cloud storage of Google Drive is considered safe because, among other safeguards, before your data leaves our devices, it is encrypted before the data is stored, which prevents the possible leakage of unencrypted data on their drives. Metadata is also encrypted while stored and data is encrypted when moved between Google’s own data centers.

    • Our staff is trained with regards to data security. We use two-factor authentication when accessing our accounts on Google Drive. We only use cloud stored Google sheets to compile contact lists (if we must handle data outside HubSpot) and never extract them as Excel files. Our staff never transfer contact details or contact lists neither via Skype nor other unencrypted means, nor on portable (USB) devices. We do not print hard copies of contact lists.

For more details, please read our Security Policy.

 

  1. How do we treat cookies?

    1. We only use cookies to ensure improved user experience not for marketing campaign personalisation purposes.

    2. Please see our Cookies Policy for further details.

 

  1. Are we transferring personal data outside the EU?

    1. Yes, to the US as the products of our CRM service provider, HubSpot, are currently hosted in U.S.-based data centers. HubSpot is considered GDPR compliant.

    2. Moreover, your information may be stored in our Google drive (encrypted cloud storage); Google has its data centre facilities in the US, Chile, Singapore and in Taiwan outside the EU. Google services are considered GDPR compliant.

    3. Currently we do not have any overseas operation, that is, we do not transfer your data to outside the EU for processing. If we expand and opt-for overseas operations, the current policy will be revised and updated and the overseas office will be set up according to the EU GDPR regulations and all the mandatory data controller/processor and data transfer contracts will be implemented and enforced to make sure adequate level of protection is established.

 

  1. Who is the DPO/GDPR Owner?

    1. The Data Protection Officer will ensure that documentation to demonstrate compliance with the GDPR such as policies and procedures are kept up to date.

    2. Furthermore, the Data Protection Officer will plan and schedule data processing audits regularly, monitoring core activities to ensure they comply with the EU GDPR.

    3. The Data Protection Officer is the main contact point for employees and will liaise with all members of staff on matters of data protection.

    4. DPO contact details: Greg Fonai; greg.fonai@etindex.com

 

  1. Who is the Data controller?

    1. Us, Engaged Tracking (ET) Index Ltd. as we determine the purposes and means of the processing of personal data.

    2. Please contact us with your queries via info@etindex.com

 

  1. What are your rights as a data subject?

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

    1. Right of access – you have the right to request a copy of the information that we hold about you.

    2. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

    3. Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

    4. Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

    5. Right of portability – you have the right to have the data we hold about you transferred to another organisation.

    6. Right to object – you have the right to object to certain types of processing such as direct marketing.

    7. Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

    8. Right to judicial review – in the event that Engaged Tracking (ET) Index Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

 

  1. Controlling your information – How can you find out the personal data that we hold about you?

Engaged Tracking (ET) Index Ltd at your request, can confirm what information we hold about you and how it is processed. You can put your request for information through our Data Request for; such requests are processed and responded to within 30 days after the request is submitted.

 

If Engaged Tracking (ET) Index Ltd does hold personal data about you, you can request the following information:

 

    1. Identity and the contact details of the person or organisation that has determined how and why to process your data.

    2. Contact details of the data protection officer (DPO), where applicable.

    3. The purpose of the processing as well as the legal basis for processing.

    4. If the processing is based on the legitimate interests of Engaged Tracking (ET) Index Ltd or a third party, information about those interests.

    5. The categories of personal data collected, stored and processed.

    6. Recipient(s) or categories of recipients that the data is/will be disclosed to.

    7. If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.

    8. How long the data will be stored.

    9. Details of your rights to correct, erase, restrict or object to such processing.

    10. Information about your right to withdraw consent at any time.

    11. How to lodge a complaint with the supervisory authority.

    12. Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

    13. The source of personal data if it wasn’t collected directly from you.

    14. Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

 

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at [info@etindex.com] or contact our DPO directly (see contact details above) or alternatively you can request an information review and correction using the relevant form (Data Request & Correction Form). We will promptly correct any information found to be incorrect.

 

  1. Controlling your information – How can you change your preferences?

You may choose to restrict the collection or use of your personal information in the following ways:

    1. whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes

    2. if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind and reset your preferences any time on the Setting Your Preferences section of our website.

    3. at any point you can change your preferences, i.e. you can give and revoke your consent to various communications

 

  1. How can you handle complaints?

    1. In the event that you wish to make a complaint about how your personal data is being processed by Engaged Tracking (ET) Index Ltd (or third parties as described above), or how your data request or correction request has been handled, you have the right to lodge a complaint directly with the supervisory authority and Engaged Tracking (ET) Index Ltd’s data protection representatives Data Protection Officer.

    2. The details for each of these contacts are:

      1. DPO: Greg Fonai; email: greg.fonai@etindex.com   

      2. Supervisory Authority: Information Commissioner’s Office (ICO), contact details: https://ico.org.uk/concerns/

 

  1. What is the rule for links to other websites?

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.