Compliance with the European Union General Data Protection Regulation Directive
Who we are and what this policy covers
Proxy Insight Ltd is a UK-registered business which provides financial information predominantly to businesses in the financial services industry, worldwide. We are committed as an organisation to ensuring that our collecting, processing, and storing of personal data is done so in compliance with the guidelines set forth in the European Union General Data Protection Regulation (GDPR) directive, effective May 25, 2018.
This policy describes the personal data we may collect, process, and store, the legal bases for our doing so, and the steps we have taken to ensure the privacy of individuals in the European Union and beyond.
Personal data we may collect
Personal data are defined as any information that may be used to identify an individual. We may collect, process, and store any of the following:
Public LinkedIn profile addresses
We do not collect sensitive personal information. Credit card and banking information are not stored.
Why we collect personal data and how we use it
We may collect, process, and store personal data predominantly on the following legal bases:
Consent and contracts
Individuals are required to provide personal information to Proxy Insight Ltd to receive our weekly newsletters and obtain access to our paid subscriber-only online suite of information products as trialists or full members. In doing so, they consent to Proxy Insight Ltd using their personal data for the purposes of delivering the aforementioned content and ensuring compliance with the terms and conditions of our subscription agreements.
Proxy Insight Ltd may use personal information to improve our products and services for the benefit of existing, previous, and prospective subscribers.
Proxy Insight Ltd may provide through its subscriber-only online suite of information products the publicly available business contact information of professional investors, advisors, directors, and corporate executives. This information is intentionally not provided in bulk format to minimise the possibility of the information being used by our subscribers in a mass marketing capacity. In providing this information, Proxy Insight Ltd expects that the information is used by our subscribers for informational purposes and any subsequent contact between our professional subscriber base and professional business contacts would be deemed appropriate and potentially beneficial to both parties. The provision of this personal information is a valuable facet of our service and ensures Proxy Insight Ltd remains competitive with other leading financial information providers.
Proxy Insight Ltd may collect, process, and store personal information for the purposes of the business-to-business marketing of our products and services, where deemed relevant to the recipient, provided the recipient has not previously opted out of receiving such communication. We may also market our products and services, where deemed relevant to the recipient, to those consumers who have opted in to receive such communication.
We will not sell, distribute, or lease your personal information to third parties unless we have your permission to do so, or are required by law to do so.
Accountability & Governance
Employees of Proxy Insight Ltd have access only to the amount and type of personal information required for the completion of their job responsibilities, and no more.
Managing Director Nick Dawson is Proxy Insight Ltd’s acting Data Protection Officer (DPO) and all members of the Proxy Insight Ltd management team have been made aware of our responsibilities as a data processor.
Personal data protection is a key consideration for all processes undertaken by Proxy Insight Ltd and data minimisation and pseudonymisation are used where possible to maximise privacy. Personal data are stored only for as long as is necessary to reasonably process them in line with the above rationale. Data are regularly checked to ensure accuracy.
Right to be informed
Individuals have the right to be informed about the collection and use of their personal data.
Proxy Insight Ltd will regularly review, and where necessary, update its privacy information, to ensure compliance with GDPR.
Right of access
Individuals have the right to access their personal data (subject access). Individuals can make a subject access request verbally or in writing. Proxy Insight Ltd has one calendar month to respond to such requests. No fee will apply to deal with a request in most circumstances.
Individuals have the right to obtain from Proxy Insight Ltd (a) confirmation that we are processing their personal data; (b) a copy of their personal data; and (c) other supplementary information.
Right to rectification
Individuals have the right to have inaccurate personal data rectified or completed if incomplete.
An individual can make a request for rectification verbally or in writing. Proxy Insight Ltd has one calendar month to respond to such requests.
Right to erasure
Individuals may have the right to have personal data erased. Individuals can make a request for erasure verbally or in writing. Proxy Insight Ltd has one calendar month to respond to such requests.
This right is not absolute and applies only in certain circumstances.
Right to restrict processing
Individuals have the right to request the restriction or suppression of their personal data. An individual can make a request for restriction verbally or in writing. Proxy Insight Ltd has one calendar month to respond to such requests.
This is not an absolute right and applies only in certain circumstances.
Right to data portability
The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.
The right to data portability applies only when the lawful basis for processing this information is consent or for the performance of a contract, and the processing is carried out by automated means, and may include history of website usage or search activities, and traffic and location data.
Right to object
Individuals have the right to object to the processing of their personal data in certain circumstances.
An individual can make an objection verbally or in writing. Proxy Insight Ltd has one calendar month to respond to an objection.
The right to object applies only in certain circumstances. Individuals have an absolute right to stop their data being used for direct marketing.
Rights related to automatic decision making, including profiling
Proxy Insight Ltd may only conduct automatic decision making where the decision is (a) necessary for the entry into or performance of a contract, (b) authorised by Union or Member state law applicable to the controller, or (c) based on the individual’s explicit consent.
Data Security and Breaches
Proxy Insight Ltd has taken several precautions in order the minimise the possibility of data breaches. Including, but not restricted to: Virtual Private Network access, identifiable logins and encryption available at all levels.
Subscriber passwords are encrypted between server and browser and not available to any of our staff, while our internal administrative system exhibits variable user permission levels to ensure personal data are visible only to those employees who require the information for the completion of their job responsibilities. The administrative system exhibits a lockout system which locks the user account defined by the username until a logged-in administrative superuser unlocks the account manually.
Proxy Insight Ltd reviews the flow of data out of its database and logs users who access its server.
In the unlikely event of a data breach, Proxy Insight Ltd would promptly notify all relevant authorities.
Links to Other Websites
Our website may contain links to other websites of relevance or interest. However, once you have used these links to leave our site, you should note that we do not have any control over that website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are therefore not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Cookies are small text files which a website may place on a computer or mobile device when the site or page is first visited. The cookie helps the website, or another website, to recognize a device the next time it visits. Web beacons or other similar files can also do the same thing. We use the term ‘cookies’ in this policy to refer to all files that collect information in this way. Cookies serve many functions. For example, they can help us to remember a subscriber’s username and preferences, analyse how well our website is performing, and even allow us to recommend content we believe will be most relevant to our visitors and subscribers. Certain cookies contain personal information – for example, if a subscriber selects ‘remember me’ when logging in, a cookie will store their username. Most cookies won’t collect information that identifies a visitor and will instead collect more general information such as how visitors arrive at and use our websites, or a visitor’s general location.
Types of cookies used by Proxy Insight Ltd
Some cookies are essential for the operation of our website. For example, some cookies allow us to identify subscribers and ensure they can access our subscription-only pages. If a subscriber opts to disable these cookies, the user will not be able to access all the content that a subscription entitles them to.
We utilize cookies to analyse how visitors use our website and to monitor website performance. This allows us to provide a high-quality experience by customising our offering and quickly identifying and fixing any issues that may arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to our subscribers based on their usage of our website.
We use functionality cookies to allow us to remember our subscribers’ preferences. For example, cookies save them the trouble of typing in their usernames every time they access the site, and recall their customization preferences, such as which regional edition of the website they want to see when they log in.
May a visitor to our website block cookies?
Cookies do enable visitors to get the most out of our website. However, if they do wish to disable our cookies then they may do so.
Do we track whether recipients open our emails?
Our emails may contain a single, campaign-unique ‘web beacon pixel’ to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to recipients, and to query whether recipients who do not open our emails wish to continue receiving them. The pixel will be deleted when the recipient deletes the email. If recipients of our emails do not wish the pixel to be downloaded to their devices, they should request to receive emails from us in plain text rather than HTML.
More detail on cookies is available at www.aboutcookies.org.