Turbine provides recognized publishers to global & local advertising buyers. We have held true to our values of integrity, authority and independence for more than 25 years. Central to this mission is our commitment to upholding the highest standards of data protection for our customers.
If you wish to amend any of the personal information that we hold about you or update your marketing preferences, you can do so at any time through your account.
If you have any queries about how we use your personal information, please contact our Data Protection Officer at Privacy.Officer@MediaGroupInternational.com.
Information we collect
This section details the information we may collect about you. We explain why, and how, we use it in later sections.
If you decide to create an account or enquire about one of our products or services, we’ll ask you to provide us with some specific information, for example:
- Basic personal details– such as name, title and date of birth;
- Personal contact details– such as home address, delivery address, home phone number, mobile phone number, and email address;
- Work details – such as job title, department, company name, company address, work email address and office phone number;
- Log in details – such as username and password;
- Payment details – such as your bank account and payment card information.
On occasion, we will ask you to voluntarily provide additional information, for example:
- Your opinion of our products and services;
- Your preferences, including newsletters or my Turbine topics;
- Your investment details if you use our portfolio tool to store your holdings;
- Your career details and CV if you use exec-appointments.com or our other recruitment pages;
- Information such as your dietary preferences and accessibility requirements when attending a Turbine Live event, which may be considered special categories of personal data.
Information we obtain from partners and public sources
In some circumstances, we collect information about you from our partners or from publicly available websites to help us better understand our audience and enhance the relevance of our content. For example, in some cases we obtain the contact details of potential speakers for Turbine Live events from public websites.
Information we obtain through cookies and similar tools
Lawful basis for processing
We only process personal information where we have a lawful basis for doing so, such as the following:
- User consent – This is where you have given us explicit permission to process personal information for a given purpose. For example, if you complete one of our general inquiry forms, we would ask for your consent if we wanted to use your personal information for any other purpose. You have the right to withdraw this consent at any time. You can manage your preferences within your account or by contacting customer services.
- Legitimate business purposes – This is where we have a legitimate interest, as a business, to process personal information. For example, where we are aware of copyright infringements on our Site, it is in our legitimate interests as a business to identify those responsible. We take due care to balance our interests against your right to privacy.
- Contractual necessity – This is where we have to process personal information to meet our contractual obligations. For example, if you are a print subscriber, we would need to process your delivery address to fulfill your subscription.
- Legal obligation – This is where we have to process personal information in order to comply with the law. For example, we process and retain customer invoice information to comply with financial regulations.
How we use your personal information
We collect personal information for the following main reasons:
- To provide our service – We require some of your basic personal information so our services work as you would expect, for example, delivering the newspaper to your correct address, providing access to our digital content, notifying you of changes to our services and dealing with customer services queries. We record customer calls for monitoring and training purposes.
- To improve and maintain performance – In order to provide you with the best possible user experience and value, we need to make sure that our products and services work as they should. Using personal information helps us understand how our readers experience our Sites and services, so we can make improvements. This includes contacting customers with market research surveys or for telephone interviews, hosting subscriber focus groups and analysing onsite data to test new and existing events, products and developments for the Media Group International.
- To bill our customers – We, along with our authorised payments processors, securely process your payment information to take payments, give refunds and to detect and prevent fraudulent activity. We will also update your payment information in the event that a payment is unsuccessful. You can manage your payment information at any time by contacting customer services. If your subscription is provided under a group subscription or trial, we will report information about your activity on our Site(s) for the purposes of billing.
- To monitor compliance with our policies and terms – We monitor for breaches of our terms and conditions and copyright policies. For example, we reserve the right to inform the subscription holder if, through use of a group subscription, you are using our content in breach of the terms and conditions or copyright policies of our Sites. We also monitor activity on our Sites to detect and prevent invalid or fraudulent traffic.
- To personalise our products and services – We improve your experience of our products and services by personalising parts of our Sites and apps with the information you give us and what we learn about you. This includes showing you articles you may be interested in and recommending emails you may wish to sign up to. Where our Sites have such functionality, you can manage elements of personalisation in your account.
- To communicate product changes and offers – We want you to get the most out of our products and services, including showcasing our latest content and newsletters. We will contact you with carefully-curated Media Group International offers and promotions, exclusive event invitations and feature announcements. For example, if there are no updates on topics you follow in Turbine, we will send you articles on other topics that we think you might be interested in. You are able to change your preferences at any time through your account or by contacting customer services. We also personalise our communications for strategic purposes. For example, we might offer group subscriptions to advertising managers.
- For the purpose of advertising – We rely on advertising revenue in part to support our award-winning journalism. We need to process your information to understand the effectiveness of the advertising we serve to you and others, and to deliver relevant personalised advertising. We use the information you give us and the information we collect about you to serve you with the most appropriate advertisements. You can manage your advertising settings for the Sites that carry out this activity in your account. If you do decide to turn off personalised advertisements or advertisements tailored to you, you will still see the same number of advertisements but they may be less relevant to you. You may continue to see advertisements that are targeted to you based on other non-personal information, for example, the article that you are reading.
- Recruitment – If you apply for a role via one of our Sites, we will process your information in order to facilitate the application process.
- To build directories – A number of our sites (including Turbine) process personal information to create databases and directories. These directories provide key business insights and profiles to those that have licensed access. Where we make an individual’s contact details accessible on our Sites, we inform the individual and provide instructions on how to have their contact details removed.
- To administer prize draws and competitions – If you enter a prize draw or competition, we will process your information in order to run the competition or administer the prize draw. For example, we will process your address information if you are a winner and we need to send your prize by post. We may be required to publish or otherwise make available your name and/or region if you are selected as a winner in a competition or prize draw.
Who we share your personal information with
We disclose personal information to facilitate the running of our business or to provide specific services you have requested. Commonly, we will disclose information to:
- Service providers – We engage service providers who help to support our business and improve our products. These service providers include, for example, fulfilment providers for delivery of our digital content and marketing; customer service agencies; hosts, organisers and sponsors of our events; organisations that host our Sites or databases; and providers of online surveys.We also work with a number of distribution partners to deliver subscriptions. We have contracts in place with these data processors and they can only use your personal information under our instruction. For example, if you have a print subscription with us, we will disclose your information (address, contact details) to our distribution partners to facilitate delivery of the newspaper or magazine.
- Institutional customers – If your subscription is provided under a group subscription or trial, we will provide our client with information about your activity on our Site(s) for the purposes of billing. This information is provided at a high level and our client cannot track exactly what articles you have read. We may also provide current or prospective clients with activity information about individual subscribers who registered using that entity’s email address. We will always contact individual subscribers before doing so, and will respect any requests not to share this information.
i) Job application service
When you apply for jobs through exec-appointments.com, your job application is forwarded directly to the advertiser of the job that you are applying for (“Recruiters”). Recruiters include agencies who may pass your information to companies that are recruiting in employment field(s) relevant to your interests. Applications that are made through Recruiters’ sites, or other external websites, will be subject to their privacy policies.
ii) Executive profile and match service
Users are provided with the option to create a personal Executive Profile and to control access to it through various settings. Profile information includes anything that you provide in the relevant information fields on exec-appointments.com.Users are offered a Match Service which allows authorised Recruiters to search our Profile Database for profile information that meets their search criteria. Whether your profile is included in the searchable Profile Database will depend on the settings you have chosen.
- Social media providers – Information will be shared with social media platforms where you log in to our Sites via a social media account, or use components on our Sites provided by social media platforms (e.g. the “Facebook Recommend” function). We also share the information of our subscribers with social media partners for the following reasons:
- To prevent existing subscribers from being targeted with subscription offerings on social media platforms;
- To create lookalike audiences for the purposes of targeted advertising on social media platforms
- To encourage users to get the most out of their subscription.
- Other users – Our Sites are publicly accessible and anyone around the world who accesses our Sites will be able to see anything you post, such as comments about an article. We encourage you to use a pseudonym when commenting on our Sites if you do not wish to be identifiable to other readers.
- Turbine – We share your information within the Media Group International to provide our services and to better understand the relationship between our products. More information about Turbine group is on our “About us” website. For example, Media Group International Live may send exclusive invitations to MediaGroupInternational.com subscribers if an event may be of particular interest to that individual.
How long we retain your personal information
We retain the majority of your personal information for as long as your account is active and therefore open; this allows you to continue accessing our content, products and services.
If you become inactive and are not a subscriber, we may delete elements of the information associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account.
Where we don’t need to keep all of your information in full, we will obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary.
A summary of how long your personal information is retained can be found below:
|Billing information||Masked details of most recently used payment method||7 years||For regulatory reasons we are required to retain accounting records for 7 years.|
|Business intelligence||Web activity on https://Turbine.run||36 months (then aggregated + non-personally identifiable)||To improve and maintain performance, personalise our services and to provide our product.|
|Comments||Comment on a Turbine article||Life of the article||To improve and maintain performance, personalise our services and to provide our product.|
|Customer service queries||Complaint about non-delivery of newspaper||7 years||To provide a case history to assist us to answer your queries.|
|Communication history||Email stating that your subscription is up for renewal||7 years||So that we have a record of what communications we have sent to you, to better assist your queries.|
|Event registration||Sign up information for Innovative Lawyer Awards||13 – 36 months||For event administration and, with your permission, to invite you to future events.|
|Market research||Responses to a survey about Turbine journalism||13 months (then aggregated + non-personally identifiable)||To administer market research incentives, avoid duplicating research requests and to understand research responses against usage of our Sites.|
|Site features||Portfolio tool information||Lifetime of the account||To improve your experience of our products and services and to enable you to continue accessing site features.|
|Subscription information||Account information relating to Turbine and The Turbine subscription||7 years post-subscription||To enable us to fulfill your contract with us.|
|Category of Data||Example||Retention Period||Justification for Retention|
It is sometimes necessary for us to keep your personal information for longer periods of time, for example:
- If there is a statutory requirement to retain it;
- If we require the information for legal reasons or there is a legitimate business need for us to retain it;
- To ensure we do not contact you if you have asked us not to.
How we keep your personal information secure
We have appropriate technical and administrative security measures in place to help ensure that our users’ information is protected against unauthorised or accidental access, use, alteration, or loss. To demonstrate our commitment to security, we have achieved the UK Cyber Essentials Plus accreditation. We use encryption technology, such as Transport Layer Security (TLS), to protect your personal information when you order products or services from us. More information about our approach to cyber security can be found in our Cyber Security Statement.
We operate a global business, so your personal information may be processed and stored outside the European Economic Area (EEA). For example, our global customer services team need to access information about you in order to respond to your queries. We put in place safeguards, such as EU standard contractual clauses, to protect information that is transferred in this way.
Under data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include:
- The right to object to direct marketing – your preferences, including in relation to direct marketing, can be found in your account;
- The right to access the personal data that we process about you;
- The right to request the deletion of your personal data;
- The right to request the rectification of your personal data – you can manage some of this information in your account.
You can exercise these rights through your account or by contacting customer services.
You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO).
Personal information is collected by Turbine on behalf of the Turbine of companies and its trading entities.
Our Sites are not intended for children under 16 years of age. We do not intentionally collect or use any information from children.
If you have a query in regards to the processing of your personal information, please contact our Data Protection Officer directly at Privacy.Officer@MediaGroupInternational.com.
|The News Building|
London Bridge Street
London SE1 9SG
|EUROPE||UNITED STATES||ASIA||MIDDLE EAST|
|London||New York||Hong Kong||Dubai|
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San Francisco, CA 94111
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No 193 Kat 2 34300 Levent
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Washington D.C. 20036
This policy is effective from 20 October 2020.