Updated May 23
References in this notice to “your information” are also to personal information that you provide to us.
This Policy applies to our main publishing website, kit-magazine.co, and our practices associated therewith.
We may modify this Policy from time to time to reflect our current privacy practices. When we make changes to this Policy, we will revise its date. We encourage you to periodically review this Policy to be informed about how Santiago Media is protecting your information.
By providing personal information to us (including through the use of our website), you acknowledge you have read this Policy, and, to the extent your consent is necessary and valid under applicable law, you consent to the collection, use and disclosure of such personal information by Santiago Media and any third-party recipients in accordance with this Policy.
What is personal information?
Personal information is information about an identifiable individual, as defined by applicable law. By ‘personal information’ we mean names, addresses, email addresses, and any other personal information you voluntarily provide, for example by completing an online questionnaire.
We also collect some personal information automatically when you browse our websites, such as your IP address and details of the pages that you have visited.
Sensitive personal information
Sensitive personal information includes race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records. We ask that you do not provide sensitive personal information of this nature when using our websites.
If you choose to provide sensitive personal information to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local law, for us to collect and use that information in the ways described in this Policy or as described at the point where you choose to disclose this information.
In this Policy, we collectively refer to handling, collecting, protecting or storing your personal information as “processing” such personal information.
What personal information do we process
We may collect personal information from you in the course of our business, including through your use of our websites, when you contact or request information from us, or when you engage our services.
The personal information that we process includes:
• Basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
• Contact information, such as your email address
• Technical information, such as information from your visits to our websites or in relation to materials and communications we send to you electronically;
• Information you provide to us for the purposes of attending events
• Personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them
How we obtain personal data
Below are some examples of how you may provide to and we may obtain personal information from you:
• As part of our business processes including administration and marketing processes;
• Subscribing to or ordering newsletters and/or publications;
• Subscribing to third party contact databases;
• Registering for events and conferences;
• Contacting us for further information;
• Monitoring email communications sent to and from Santiago Media; and/or
• Providing us with business cards or other contact information.
How we use personal information
We may use your personal information to:
• process and respond to requests, inquiries or complaints received by you;
• provide services requested by you (including the performance of our contractual obligations to you);
• identify services you may be interested in;
• communicate with you about our services;
• invite you to events;
• monitor and analyse our business;
• form a view of you as an individual and to identify, develop or improve our services and/or products that may be of interest to you and to carry out market research;
• to understand how people use the features and functions of our websites in order to improve the user experience; and
• send you marketing materials.
By using any of our websites, you agree that we can place cookies on your device. If you want to restrict or block any of the above cookies, you should do this through the web browser settings for each browser you use and on each device you use to access the Internet.
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device, preferences and generally help to improve your online experience.
As you navigate through and interact with our websites, we may automatically collect certain information about your equipment, browsing actions and patterns, including:
• Details of your visits to our websites, including traffic data, location data and information about the resources that you access and use on our websites; and
• General non-personal statistical data about your operating system and browser type.
Collecting this data helps us to improve our websites and to deliver a better and more personalized service by enabling us to:
• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our websites according to your individual interests;
• Speed up your searches; and
• Recognize you when you return to any of our websites.
We use the following types of cookies:
• Strictly necessary cookies which are essential to enable you to use a website;
• Performance cookies which collect aggregated and anonymous information about how visitors a particular website;
• Functionality cookies which allow us to remember choices a user makes and provide enhanced, more personal features, such as storing personal data so that in the future forms on the websites can be auto-completed, saving the user time; and
• Cookies supplied by third parties which can be downloaded to your device. These third- party cookies are not under our control so you should check the websites and cookie policies of any third parties.
We will not keep any cookies placed on the device from which you access any of our websites longer than is necessary to fulfil the purposes mentioned above.
Legal grounds for processing
Your local law may require us to set out in this Policy the legal grounds on which we rely in order to process your personal information. In such cases, we rely on one or more of the following processing conditions:
• our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (provided these do not interfere with your rights);
• to satisfy any legal and regulatory obligations to which we are subject; or
• where no other condition for processing is available, if you have agreed to us processing your personal information for the relevant purpose.
Rights in respect of your personal information
The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for data subjects.
You may be entitled to:
• request a copy of personal information we hold about you and how we process it by way of a subject access request;
• ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete;
• ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information;
• object to our processing of your personal information, restrict our processing of that information, prevent unauthorised transfers of your personal information to a third party and, in some circumstances, require personal information relating to you transferred to another organisation; and/or
• withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).
We may require further information from you in order to verify your identity before disclosing any personal information to you and we may charge for a request to access your information, if permitted by applicable law.
You may also have the right to lodge a complaint in relation to our processing of your personal information with a local supervisory authority.
If you would like to exercise these rights, please contact us by sending an email to: email@example.com.
Most of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.
Where we are legally required to obtain your explicit consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so. We may send you further emails prompting you to refresh your consent from time to time.
You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in emails we send to you. If you select any preferences such as issues, topics, subjects or industries, you may receive email communications related to those self-selected topics.
You can also exercise the right to discontinue marketing communications to you. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again. If you have agreed to receive marketing but then later change your mind and no longer wish to receive marketing, please let us know so we can remove you from our distribution lists.
Please contact us on one of the email addresses below if you do not wish to receive communications from us.
If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
If you have other registrations with Santiago Media or have provided your information to us through other means (such as subscribing to newsletters), those registrations will be maintained unless you to take specific action to inform us to cease contacting you.
When we keep your personal information, we are responsible for keeping an accurate record of the information that you have submitted to us and verified. We do not assume responsibility for verifying the ongoing accuracy of your personal information.
Sharing your Personal Information
If and when we transfer personal information, we do so for the purposes for which the information has been submitted, for the purposes listed above, for the administration and maintenance of our websites and associated systems, and/or other internal or administrative purposes.
We may for example share personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
• Our professional advisers, auditors and insurers;
• IT service providers to Santiago Media (including identity management, website hosting and management, data analysis, data backup, security and storage services);
• Third parties involved in hosting or organizing events or seminars.
The third-party providers may use their own third party subcontractors that have access to personal data (sub-processors). We only use third party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information and to flow those same obligations down to their sub-processors.
We may be required to disclose your information to comply with legal or regulatory requirements; under those circumstances, we will use reasonable endeavors to notify you before we do this, unless we are legally restricted from doing so.
If in the future we re-organize or transfer all or part of our business, we may need to transfer your information to new Santiago Media entities or to third parties through which the business of Santiago Media will be carried out.
External Websites/Social Media
In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it or where you are viewing this website for the purposes set out in this Policy. This may entail a transfer of your information from a location outside the EEA to a location within the EEA.
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.
Where our third-party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, satisfying EU requirements for the transfer of personal data to data processors or data controllers outside the EEA.
We have implemented measures to ensure that we keep your personal information confidential and secure and only use it for the specified purposes about which we have informed you. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We use a variety of security, technical and organisational measures to help protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss with applicable data protection laws. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats.
The transmission of information via the internet is not completely secure. Although we will do our best to try and protect your information, we cannot guarantee the security of your information transmitted to our websites; any transmission is at your own risk.
We will retain your personal information for as long as is necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
Our retention periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.
We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list or newsletter, we may keep certain limited information about you so that we may honor your request.
If you have any questions in relation to this Policy please contact us at: firstname.lastname@example.org. Postal address: 407 State Street, Brooklyn, NY, 11217