Privacy Policy
This privacy policy sets out how we collect, process and use the personal data of our users, contributors, customers, event attendees and website visitors in connection with our products and services. Treating personal data with respect, keeping it secure and processing it in accordance with the law is of the utmost importance to With Intelligence.
Our websites, products and services are not intended for children, and we do not knowingly collect data relating to children.
| Subscribers | Current or former subscribers to any With Intelligence product or service |
| Event attendees | Current and former attendees or registrants to any With Intelligence events or webinars or award entrants |
| Contributors | Representatives of entities listed in our subscription services or products who provide business contact information for those entities |
| Applicants | Those who have applied to work for With Intelligence |
| Asset Management Individuals | Those working in the alternative or traditional asset management industry |
| Website visitors | Anyone visiting any With Intelligence site |
| Potential customers | Potential customers of our subscription products or services, events or webinars |
A data subject may belong to more than one category.
What personal data we process, how we collect it and what we use it for
Subscribers.
What personal data do we process
Salutation, name, job title, email address, telephone number, usernames and passwords, company/firm name, business address, social media account details, topic preferences, cookie preferences, networking activities, bank account details and payment card details , purchase and payment history, marketing and communications preferences, IP addresses, 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 used to access websites or services or products, feedback and survey responses and usage data.
How do we collect it
Data is collected as part of the subscription process, including when potential subscribers submit website forms or contact us to request information.
What we use it for
a) To fulfil our contract. this includes setting up clients and users, processing payments, providing updates relating to our products, processing user IDs, passwords and contact details and delivering content. Any such use will be on the basis that it is necessary to pursue our legitimate interest of carrying on our business.
b) After the contract has ended. we will keep full records about the contract for a limited period in case you want to reactive your account. Such processing would be carried out on the basis that it is necessary for the purposes of our legitimate interest in conducting our business to pursue our legitimate interest of protecting our business.
c) Record keeping: we retain details of transactions for a period of up to 6 years for our internal records and for the purpose of tax and regulatory compliance. Any further use of the retained information will only be to comply with regulatory requirements or in the event of a dispute between the recipient and us. Such processing would be carried out on the basis that it is necessary to pursue our legitimate interest of protecting our business and to comply with the law.
d) Monitoring use. we use software services and tools to monitor the use of our websites, products and services access using your account details, to identify and manage potential security issues and to keep your account safe. Any usage data will be processed to the extent necessary for our legitimate interest of ensuring our products, websites and services are secure. We will retain usage data for a period of up to 6 years. Any further use of the retained information will only be to comply with regulatory requirements or in the event of a dispute between you and us – in which case such processing would be carried out on the basis that it is necessary to pursue our legitimate interest of protecting our business.
e) Printing and logistics. in fulfilling our contract with you, we may need to have certain materials printed and despatched to you. In these circumstances your personal data may be sent to a third-party provider in accordance with the terms of this privacy policy. Any such use will be on the basis that it is necessary to pursue our legitimate interest of carrying on our business.
f) Interests and preferences. We may also request and collect information about your relevant interests and preferences. We will use this information to help us make decisions about the kind of events, webinars and any services or products you might be interested in hearing about from us and will use this information for marketing purposes. See “Marketing” section below for more detail.
g) Troubleshooting and technical support. in certain circumstances when performing our contract with you (or otherwise providing requested services to you where no contract exists), a need may arise for us to transfer your data to a third-party technical support or technology development agency. Any such use and transfer will be on the basis that the processing is necessary to perform the agreement that we may have with you and in order to pursue our legitimate interest in developing and improving the stability and security of our systems.
h) Debt management. Where a Subscriber fails to make payment we may need to transfer your personal data in order to instruct a third-party debt collection agency. Processing of this type may be carried out in order to pursue our legitimate interest in recovering such a debt.
i) Customer engagement. We may provide access to certain platforms through which we engage with our Subscribers, e.g. our own community social media platform and a customer polling platform. In operating these platforms, we may process your personal data to allow you to access and use the services on these platforms. Our lawful basis for using personal data in this way is that it is necessary to pursue our legitimate interest of promoting our business, developing new customers and to inform our marketing strategy.
Where we rely on you to provide personal data in order for us to meet statutory or contractual obligations and you do not provide this, we may not be able to provide some or all of our services to you, or the provision of these services may be reduced or delayed.
Event attendees.
What personal data do we process
Salutation, name, job title, email address, telephone number, mobile number, company/firm name, business address, social media account details, dietary requirements, personal data contained within photographs, networking activities, bank account details and payment card details, purchase and payment history, marketing and communications preferences, work history, qualifications, feedback and survey responses.
How we collect it
Provided directly by Event attendees (including by the Event attendees’ company/firm on behalf of the Event attendee).
What we use it for
We process personal data in order to effectively manage, organise and run our events and webinars. Where you sign up to attend/enter one of our events or webinars:
a) To fulfil our contract. We will collect such personal details as are required to deliver our contractual obligations (or otherwise providing requested services to you where no contract exists). The legal basis for such processing is that it is necessary for the purpose of our legitimate interests in performing the contract between us and to pursue our legitimate interest of promoting our business and developing new customers.
b) Attendance List. We may share a registration list (including your name, job title and company/firm name) which will be made available to other Event attendees and to the event/webinar sponsors. We will not provide your email address to third parties unless you provide your consent. We may share your details with the venue in order to meet dietary requirements or for venue security purposes. We consider this processing to be necessary to pursue our legitimate interest of running our events and webinars effectively.
c) Awards Judging. To create shortlists for and to judge awards, details supplied during the entry process may be shared with external judges including name, job title, company/firm, work history and qualifications. All judges sign a non-disclosure agreement to prevent sharing/use of any information obtained through this process. For awards that are externally adjudicated, these adjudicators have access to the awards entry system including all entry forms and judges’ scores.
d) Record keeping: we retain details pertaining to events and webinars for a period of up to 6 years for our internal records and for the purpose of tax and regulatory compliance. Any further use of the retained information will only be to comply with regulatory requirements or in the event of a dispute between the recipient and us. Such processing would be carried out on the basis that it is necessary to pursue our legitimate interest of protecting our business and to comply with the law.
e) Interests and preferences. We may also request and collect information about your relevant interests and preferences. We will use this information to help us make decisions about the kind of events, webinars and any services or products you might be interested in hearing about from us and will use this information for marketing purposes. See “Marketing” section below for more detail.
f) Printing and logistics. In order to properly deliver the event or webinar we may need to have certain materials printed and despatched to you. In these circumstances your personal data may be sent to a third-party printer or logistics provider. Any such transfer will be made in accordance with the terms of this privacy policy. Any such use will be on the basis that the processing is necessary- for the purposes of our legitimate interest in performing our agreement with you.
g) Photographs. Your photograph may be taken at one of our events and may be used for marketing purposes. By attending the event, you are providing consent to have your photograph taken or be filmed, which may be used by With Intelligence in future promotional material online or in print. Please contact the event manager at summits@withintelligence.com with the event name if you do not wish your photograph to be used for marketing purposes.
h) Debt management. Where an Event attendee (including their respective company or firm) fails to make payment we may need to transfer your personal data in order to instruct a third-party debt collection agency. Processing of this type may be carried out in order to pursue our legitimate interest in recovering such a debt.
Any individuals who sign up to act as speakers or judges at our events or webinars may have their personal data collected and used in the following way:
a) To fulfil our contract. We will use your contact details to contact you in connection with the event or webinar and process any payment or facilitate any obligations or rights set out in any agreement which may exist between you and us. Any such processing will be carried out on the basis that it is for the purposes of our legitimate interests in fulfilling the contract between you and us.
b) Record keeping. We will retain details of transactions between you and us for up to six years. We will only use the retained information to comply with regulatory requirements or in the event of a dispute between you and us – such processing may be carried out on the basis that it is necessary to pursue our legitimate interest of protecting our business.
c) To advertise the event. We may use any profile or personal data that you provide us with or that are publicly available to help market or advertise the event that you are speaking/judging at on the basis that such processing is necessary to achieve our legitimate aim of running an effective event or webinar. We may retain your profile and details for our internal records and to allow us to contact you in the future about similar events or webinars. Such processing is carried out to pursue our legitimate interest of promoting our business.
d) Printing and logistics. In order to properly deliver the event or webinar we may need to have certain materials printed and despatched to you. In these circumstances your personal data may be sent to a third-party printer or logistics provider. Any such transfer will be made in accordance with the terms of this privacy policy. Any such use will be on the basis that the processing is necessary to perform the agreement that we may have with you.
e) Marketing. See “Marketing” section below
Contributors.
What personal data do we process
Name, job title, email address, telephone number, firm name, business address, social media account details
How we collect it
Directly provided by Contributors.
What we use it for
The personal data is added to our databases and is made accessible by Subscribers. The legal basis for the provision of such data to the Subscribers is that it is necessary for the purpose of our legitimate interest of carrying on our business of providing insights into the alternative and traditional investment industry.
Applicants.
What personal data do we process
Name, job title, email address, telephone number, firm name, business address, social media account details, work history, qualifications, gender, date of birth and special categories of personal data, Usage data, CCTV images.
How we collect it
Provided directly by the Applicant. At some of our offices there is a CCTV system installed. Any individual who visits these offices will have their image recorded by the CCTV system.
What we use it for
a. To assess suitability for role and progress application. If you apply for a job at With Intelligence, we will use the information you provide us with to assess your suitability for the role and to progress or end your application. The personal data we will require, and use includes contact details, your curriculum vitae, your previous experience, education history and answers to questions relevant to the role you have applied for. Our HR team and the hiring manager for the role will have access to this data.
b. To comply with legal obligations as an employer. We may collect your special categories of personal data where it is necessary to do so to comply with our legal obligations as an employer. We may also ask about equal opportunities data. We use this data on an anonymised basis to produce and monitor equal opportunities statistics for legal reasons. There is no obligation to provide this data and it will not affect your application if it is not provided.
c. Sharing of data where necessary for recruitment process. We will only share your data with contracted third parties if it is necessary for the recruitment process and we will notify you at the time that we do so. We will never sell your data or use data provided to us for the purposes of your application for marketing purposes.
d. Record Keeping. If your application is not successful, we will store your details for six months to help with any questions, before securely deleting or anonymising the personal data. If you elect to hear about other opportunities in the future, we will retain your personal data for a further two years before securely deleting or anonymising the personal data.
e. To complete employment checks. If your application is successful, we will need to complete employment checks for legal reasons, in particular, to verify your right to work in the country and to verify your previous employment references.
We may carry out data processing of this nature to the extent necessary for the legitimate interest of recruiting and developing our workforce.
We operate CCTV systems at these premises in order to pursue our legitimate interests of protecting the personal safety of staff, visitors and other members of the public, to act as a deterrent against crime and to prevent crime and pursue our assets from damage, disruption, vandalism and other crime.
Asset Management Individuals.
What personal data do we process
Name, job title, email address, telephone number, firm name, business address, social media account details, identification as firm director, shareholder, stakeholder and professional adviser, and other information from profiles, reports, articles and blogs, feedback and survey responses, work history, qualifications, gender.
How we collect it
Data of this type is collected and processed both internally by our researchers and by third party agencies on our behalf. Our researchers and agencies may contact relevant individuals directly to obtain information as well as using publicly available websites, LinkedIn, regulatory filings, company registries and news articles.
What we use it for
We use this information to write profiles, articles, blogs and reports which are then published for the benefit of our subscribers (who may be based outside the UK, EEA, US, Hong Kong, the Philippines or Singapore) via a searchable database or in a newsletter. We process data in this way in order to pursue our legitimate interests of developing our products/services and growing our business and to present financial service journalism.
Website Visitors.
What personal data do we process
Cookie preferences, marketing and communications preferences, IP addresses, 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 used to access websites or services or products,
How we collect it
Our websites collect personal data using cookies.
Cookies are small data files that websites store on your electronic device so that the website can store data and will enable us to collect information, which is likely to include data from which you can be identified. For further details, including the duration that we retain data for, please see our Cookie Notice https://www.withintelligence.com/cookies.
You can control the use of cookies using the cookie management tool banner presented when you first visit our site and at the browser level by setting your web browser controls to accept or refuse cookies. If you choose to block all cookies, you may not be able to access all or parts of our website. In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information on this, please visit the websites: http://www.aboutads.info/choices/ or http://www.youronlinechoices.com or http://globalprivacycontrol.org.
In some instances we also use server logs to collect data. Our lawful basis for using cookies and server logs to collect and process usage data is that it is necessary to pursue our legitimate interests of promoting our business and for the correct functioning and operation of our websites.
What we use it for
To help us (1) make sure our website performs as intended; (2) to analyse how visitors use our websites in order to help us make our websites more effective; and (3) to help us make marketing decisions about how we promote our services online. See “Marketing” section below for more information.
Potential customers
What personal data do we process
Name, job title, email address, telephone number, firm name, business address, social media account details, networking activities, identification as firm director, shareholder, stakeholder and professional adviser, and other information from profiles, reports, articles and blogs, marketing and communications preferences, work history, qualifications, gender.
How we collect it
See “Marketing” section below.
What we use it forSee “Marketing” section below.
Processing applicable to all categories of data subject
Marketing. We use third party agencies, data research companies and our own internal team to actively identify people who we believe are likely to find our events, services products useful. Our team and our third-party researchers look for and source business contact details and information about an individual’s job role both online (using publicly available resources and websites), through networking activities and from details collected from previous event attendees, newsletter subscribers and users of our products.
We use those business contact details to send event invites and emails about relevant industry news and our products and services. We always include an unsubscribe link at the bottom of any such email which we send, so that you can let us know if you do not wish to receive any further marketing emails.
Our lawful basis for using personal data in this way is that it is necessary to pursue our legitimate interest of promoting our business, developing new customers and to inform our marketing strategy.
Administration. We may process personal data in order to allow us to properly administer our systems and our business, including data storage, hosting, reporting, systems maintenance, improving our computer systems, troubleshooting, analysis, testing and the operation of our databases. Processing of this kind is incidental to the provision of our services and products and to the efficient operation of our business. We may carry out data processing of this nature for the legitimate interest of administering, improving and protecting our business, our websites, our products and our services. We may also carry out this type of data processing to pursue our legitimate interest in ensuring our systems are secure and preventing fraud.
Analytics. We use data analytics to monitor and improve our websites, products/services, marketing, customer relationship management and user experiences. Wherever possible when carrying out this type of analytical work, we anonymise all personal data. In certain circumstances, however, cases arise whereby we need to process personal data in order to achieve the objectives of our analytical processing. Where we do so we are pursuing our legitimate interests of defining the types of customers for our products and services, keeping our websites, services and products updated and relevant, developing our business and to inform our marketing strategy.
Data security.
We have put in place appropriate security measures at organisational, technical, physical and operational levels to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. However, the transmission and storage of information is subject to vulnerabilities and unauthorised third-party activity. Although we will do our best to protect your personal data, we cannot and do not guarantee the security of your data.
When Subscribers register for an account with us, you may be required to choose or will be assigned a password which enables you to access our website. You are responsible for keeping this password confidential and for all activity that takes place through your account credentials. Do not share your password with anyone. If your password is compromised, change your password within your account. If you believe your account may have been compromised, please notify us immediately.
International transfers of personal data.
UK and the EU
We share your personal data within With Intelligence. As we have a number of offices outside of the UK and the European Union (EU) your personal data may be transferred outside of the UK and the EU (a ‘restricted transfer’). ‘UK Transfers’ refers to transfers of personal data that are subject to the UK data protection laws and ‘EU Transfers’ refers to transfers of personal data are subject to the EU data protection laws.
We also work with a number of third-party outsourcers based outside of the UK and/or the EU, including providers of research services, IT support, technology and website development agencies. From time to time, we may need to transfer certain personal data to these parties in accordance with the terms of this privacy policy.
Whenever we transfer your personal data out of the UK or the EU, we provide an equivalent degree of protection to the personal data by ensuring that at least one of the following safeguards is implemented:
a) Where the recipient is located in a country that has been deemed to provide an adequate level of protection for personal data by the UK Secretary of State (for UK transfers) or the European Commission (for EU transfers); or
b) Where the recipient is located in the United States of America and is a participant in the EU-US Data Privacy Framework (for EU transfers) and the UK Extension to the EU-US Data Privacy Framework (for UK transfers). The foregoing sentence shall apply for so long as the EU-US Data Privacy Framework is subject to an adequacy decision by the European Commission (for EU transfers); and the UK Extension to the EU-US Data Privacy Framework is subject to adequacy regulations by the United Kingdom Parliament (for UK transfers),
c) Using standard contractual clauses approved by the ICO (for UK Transfers) or the European Commission (for EU Transfers) as providing appropriate safeguards for restricted transfers.
Please contact us at legal@withintelligence.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Disclosure of personal data to third parties.
In addition to any disclosure of Contributor personal data to Subscribers via their subscription to our products and services, we may disclose any personal data that we hold to certain third parties who are contracted to help us provide our products and services (some of whom may be based outside the UK, EU, US, Hong Kong, the Philippines, or Singapore). Any such third parties will be acting as processors on our behalf and will be contractually bound to only use the data in accordance with our instructions and to implement adequate security measures. The data will only be transferred by us to a third party if appropriate contractually binding safeguards are implemented between us and the processor. We require all third parties to respect the security of your personal data and to treat it in accordance with all applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share also personal data with third parties (who will also be acting as controllers in respect of that personal data) if we:
a) have a legal duty to do so or if it is required to enforce or apply our contracts or to protect legal rights, our property, the use and functionality of our websites or the safety of us or others; and
b) sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners will only be entitled to use personal data in accordance with the provisions set out in this privacy notice.
Links to third-party sites.
Our website may contain links to other websites and companies that may be of interest to you. If you click on any of those links, you will leave our website. We are not responsible for third-party websites. Please consult the terms of service and privacy policies of those sites when you visit them.
Data retention.
Save to the extent expressly provided in the foregoing provisions of this privacy policy, we will only retain your personal data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we believe there is a reasonable prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
By law we must keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see ‘Your rights’ below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be used to identify you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your rights.
If we hold data about you, you have certain rights under applicable data protection laws.
In the UK and the EU, this includes the:
a) Right to be informed: you have a right to ask us what personal data we collect and what we use it for;
b) Right of access: you have a right to request a copy of any personal data that we hold about you. We will respond to your request within one month;
c) Right of rectification: you have a right to require us to correct any personal data held about you which is inaccurate or incomplete. We will rectify any errors you highlight to us within one month;
d) Right to restrict processing: you have a right to request us to restrict the processing carried out in respect of personal data relating to you;
e) Right of data portability: you have a right in certain circumstances to request that the personal data held by us about you transferred to another organisation;
f) Right to object: you have a right to object where processing is carried out in certain circumstances, including where we rely upon legitimate interests for such processing. You may always object to us processing your personal data for direct marketing purposes; and
g) Right to object to automated decision making and profiling: you have a right not to be subject to a decision based solely on automated processing which produces legal or similar significant effects on you.
Where we rely on your consent to process personal data, you have the right to withdraw your consent at any time, which you can do by contacting us at data@withintelligence.com.
In certain situations, we may be able to rely on one of the exemptions under the applicable data protection laws. These exemptions may mean we have a right to refuse requests for disclosure of information, erasure requests and rectification requests, as well as exempt us from some notification obligations.
We will confirm to you in writing to acknowledge receipt of any request we receive relating to your rights as a data subject, and we will let you know if we have complied with your request within the applicable timeframe. If having, carried out an assessment, we believe that we are indeed able to rely on one of the exemptions, we will let you know why we have reached that conclusion.
Privacy signals.
Some internet browsers incorporate a “Do Not Track” feature or other similar features that signal to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
Accessibility.
We are committed to ensuring this privacy policy is accessible to individuals with disabilities. If you wish to access this privacy policy in an alternate format or would like to report an issue you are experiencing on our website, please email us at support@withintelligence.com.
Questions, complaints and contact.
‘With Intelligence’ is the trading name of With Intelligence Ltd and its affiliates.
You can contact With Intelligence with any questions you might have about our use of data or this privacy policy. You also have the right to request access to and correction of the personal data held by us about you.
You can contact us via the following addresses:
UK: With Intelligence Limited: One London Wall, London EC2Y 5EA, United Kingdom
USA: With Intelligence LLC: 41 Madison Avenue, New York, NY 10010, USA
Hong Kong: With Intelligence HK Limited: Suite 1106-08, 11th Floor, Tai Yau Building, No.181 Johnston Road, Wan Chai, Hong Kong
Singapore and the Philippines: With Intelligence Pte, 24 Raffles Place, #27-04, Singapore 048621
Email: hello@withintelligence.com
With Intelligence has implemented appropriate technical and organisational measures to ensure our compliance with all applicable data protection laws. With Intelligence has formed a privacy steering group, chaired by our General Counsel.
Please let us know if you have any concerns about how we are handling your data. We will do our best to resolve the matter, but if we are unable to do so to your satisfaction you may make a complaint to our General Counsel (legal@withintelligence.com). All users in the UK also have the right to lodge a complaint with the appropriate supervisory authority. All complaints can be lodged with the ICO who can be contacted at https://ico.org.uk/make-a-complaint/
This privacy policy was last updated on 29/01/2024.