Effective Date: April 21, 2020
I. COLLECTION OF INFORMATION
We collect the following categories of information when you use our Services (including when you download or launch our mobile applications):
- Information you provide directly to us.
a) Contact Information, including name, alias, email address, telephone or mobile phone number, or address;
- b) Sign-In Information, including email and password, account name, account number;
- c) Membership Information and Survey Responses, including your interests, preferences, demographic information, feedback, educational or professional information, employment, employment history, marital status, date of birth, age, national origin, sex, medical condition, military/veteran status;
- d) Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- e) Geolocation data;
- f) Transaction and Billing Data, including bank account and payment card details, (credit card number, expiration date, and credit card security code, where needed to complete a transaction), billing address, delivery address, signature, and transaction history; and
- g) Correspondence you send to us, including but not limited to contact information, photographs, and videos.
- Information we collect automatically. We collect internet, electronic activity, and other information automatically from the devices and browsers that you use, including your device type; Internet protocol (IP) address; device and advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers; time zone setting and location; browser type and version; browser plug in types and versions; operating system and platform; Internet service provider; pages that you visit before and after using the Services, browsing history, and search history; the date and time of your visit; information about the links you click, pages you view, and advertising you interact with within the Services and other information about how you use the Services; the technology on the devices you use to access these Services. If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred. Consistent with your mobile device or app permissions, we also collect geolocation information (including geolocation information derived from your IP address), photos stored on your device, and contacts from your mobile address book].
We also receive the categories of information described above from other sources, including from users of our Services, government entities that make information publicly available, and third-party services and organizations. For example, if you access any social media or similar services through the Services to login or to share information about your experience on our Services with others, we may collect information from these third-party services.
Without this information, we are not able to provide you with all the requested services, and any differences in services are related to your information.
II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING
We use and otherwise process each of the categories of information identified above for the following business purposes:
|Purpose/Activity||EEA lawful basis for processing, including basis of legitimate interest|
(a) Performance of a contract with you
(b) Necessity to comply with a legal obligation
(c) Necessity for our legitimate interests (for instance, to keep our records updated)
|To make suggestions and recommendations to you about things that are similar to those that you have enquired about or may otherwise be of interest to you, or to send promotional materials from us or by our affiliates and trusted business partners.||Necessity for our legitimate interests (to grow our business)|
|To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device; to administer our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes; to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.||
(a) Necessity for our legitimate interests (for running and protecting our business; for provision of administration and IT services; for network security and to prevent cybercrime and fraud; in the context of a business reorganisation or group restructuring exercise; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy)
(b) Necessity to comply with a legal obligation
Where legally required and we have no other valid legal basis to process your information, we will obtain consent (for example, to provide you with marketing information or share information with third parties), which may subsequently be withdrawn at any time by contacting us (as described in section XI below). Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.
Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may cancel a membership, product, or service you have with us.
III. DISCLOSURE OF INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
- Authorized third-party vendors and service providers. We share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, advertising and marketing (including counting ad impressions, verifying positioning and quality of ad impressions, ensuring compliance with industry standards and specifications, ad delivery, reporting, personalization, audience segmentation, and analytics), security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.
- Corporate affiliates. We may share your information with our corporate affiliates, including other members of the Manhattan Institute.
- Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
- Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of the Manhattan Institute, our affiliates, users, or the public.
- With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services—such as social media services—through the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.
If you choose to engage in public activities on the Services, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.
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V. ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES
The following types of cookies are used on our Services:
- Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without these cookies, certain services such as (such as the Adam Smith Society membership portal) cannot be provided. These cookies also help keep our Services safe and secure.
- Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you've previously made (such as a saved language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
- Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit "do-not-track" signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals
VI. YOUR RIGHTS AND CHOICES
You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, rectification, erasure, and portability of your information or more information about our information practices. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected.
You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable Local Shared Objects and similar technologies. For example, Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt-out selection in your browser.
Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your information and what choices you may have, visit their site here. Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.
You also may be able to control our collection and use of your location information through your mobile device or app settings.
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you.
You may lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful.
VII. INTERNATIONAL TRANSFERS
Some of the entities (such as third-party vendors) to which we disclose information may be located outside of the EEA, including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality.
We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.
IX. DATA RETENTION, SECURITY, AND INTEGRITY
Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.
We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
XI. CONTACT INFORMATION