Mondaq Ltd
Privacy and Cookies Notice

Mondaq Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Notice (“Notice”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us when you use our website at www.mondaq.com (“Website”) or any of our services, or where we enter into any other business relationship with you. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Mondaq Limited.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all of the following types of information from you in the course of your use of the Website, our provision of our services, or otherwise conducting any business relationship with you:

  • Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the Website, subscribing to our services (including but not limited to news alerts), or requesting further information or services. We may also ask you for information when you complete a survey or enter contests.
  • Specifically, personal details such as name, email address, place of work, position, country, telephone number or any information input by you when using the Website, completing our survey forms or using our services.
  • In respect of the personnel engaged by our customers and suppliers (or prospective customers and suppliers), and with whom we come into contact in connection with the relationship between Us and our customer and supplier, we will process your contact details and any other information that you provide to us.
  • If you contact Us, We may keep a record of that correspondence.
  • We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
  • Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

The provision of name, email address, place of work, position, country and telephone number is required from you to register to use the Website. Your name and email address are required from you to register for news alerts. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.

Information We Collect From Other Sources

We use public sources such as LinkedIn to obtain the contact details of individuals who we reasonably believe may have an interest in our products and services.

USES MADE OF YOUR INFORMATION

Provision of data to our content contributors

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a “free to view” business model. Our services are paid for by content contributors (“Contributors”) in exchange for Mondaq providing them with access to information about who reads their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the summary of the content that you are able to view before you access the applicable Content. Contributors may be located within or outside the EEA – their location will also be clearly indicated. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

We have always been completely transparent about the provision of users’ personal data to our Contributors, and until 24th May 2018 have relied on legitimate interest to collect and process our users’ information in this way. As a courtesy to our users, we have in the past provided the right to opt-out from this use of their personal information.

From 24th May 2018 although we believe that we continue to have a legitimate interest in providing your information to the Contributors whose content you access, and that the Contributors continue to have a legitimate interest in receiving this personal data, we have decided to give you more control by asking for your express consent to this processing when you register. Users who register after 24th May 2018 will therefore be required to opt in or out of this use. Users who registered prior to 24th May 2018 will not be asked to expressly consent to the use, but may opt out at any time by amending the settings in their profile or by contacting Us at the contact details set out below.

Mondaq’s own use of your personal data

We use information held about you in accordance with the following “legal bases” and for the following purposes:

  • To provide you with our Website and associated functionality (such as password reminders) and to carry out any other obligations arising from any contracts entered into between you and Us. We rely on “performance of a contract with you” as the legal basis for this processing.
  • To provide you with news alerts. We rely on “consent” as the legal basis for this processing.
  • To notify you about changes to our service. We rely on “performance of a contract with you” as the legal basis for this processing.
  • To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website. We rely on “legitimate interest” as the legal basis for this processing, and the legitimate interest is the maintenance and improvement of our Website for the benefit of all our users.
  • To allow you to participate in interactive features of our service, when you choose to do so.

We may use information held about you to promote our products and services that may be of interest to you. We rely on a number of legal bases for this type of processing, as follows:

  • if you are an existing or prospective customer of and/or contributor to Mondaq, we will only do this where we reasonably believe that our services may be of interest to you and we rely on “legitimate interest” to promote our products and services to you.
  • if you were registered as a Mondaq user prior to 24th May 2018 we rely on “legitimate interest” to promote our products and services to you that are similar to those in which you have previously shown an interest.
  • if you register as a Mondaq user after 24th May 2018, although we believe that we continue to have a legitimate interest in promoting our similar products and services to you, we have decided to give you more control by asking for your express consent before contacting you by electronic means for this purpose.

In any case, if you would prefer that we do not use your data to market or promote our products and services to you, please either (i) tick the relevant box on the form through which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) contact Us at the contact details set out below.

DISCLOSURE OF YOUR INFORMATION

We routinely disclose your personal data to third parties as follows:

  • To our Contributors, as described above.
  • To our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

  • in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
  • if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
  • if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions or the Terms and Conditions that we have in place with our content providers; or
  • to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website.

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

If your personal details change you may update them by accessing the relevant page of the Website, or by contacting Us at EditorialAdvisor@mondaq.com. If you have any questions about how We use data collected which relates to you, please contact Us by emailing enquiries@mondaq.com.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How long we keep your personal data

  • For Website Users will hold your personal data (eg name, address and contact details) for a minimum of 3 years unless you ask Us to delete it.
  • For Mondaq employees we will retain your personal data for a minimum of six years as required by UK tax law.

Where we store your personal data

All information We hold about you is stored on our secure servers within the EEA.

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.

Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that [such countries] provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a [provide details of the appropriate or suitable relevant safeguards eg European Commission approved contract] (as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information please contact Us, or our Data Protection Officer (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal data and to certain other supplementary information that this Notice is already designed to address
  • require Us to correct any mistakes in your information which We hold
  • require the erasure of personal data concerning you in certain situations
  • receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal data concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal data
  • otherwise restrict our processing of your personal data in certain circumstances
  • claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they aply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to Us,
  • let Us have enough information to identify you [(eg account number, user name, registration details)],
  • let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let Us know the information to which your request relates [, including any account or reference numbers, if you have them]

HOW TO COMPLAIN

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Notice at any time. Any changes We may make to our Notice in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied Privacy Notice.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We may collect information about your mobile phone, computer or other device from which you access the Website including where available [your IP address, operating system and browser type], for systems administration [and to report aggregate information to third parties affiliates]. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.

Our Website uses cookies to distinguish you from other users of our Website. This helps Us to provide you with a good experience when you browse our Website and also allows Us to improve the Website. By using our Website you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies We use include:

  • “Analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  • “Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
  • “Functionality” cookies. These are used to recognise you when you return to our Website. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • “Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties affiliates may also use cookies, over which We have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

CONTACT

All questions, comments and requests [except where specified above] regarding this Privacy and Cookies Notice should be addressed to enquiries@mondaq.com write to Us at Mondaq Ltd, The Old Church, Quicks Road, Wimbledon, London SW19 1EX