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VANTAGE ASIA PUBLISHING LIMITED

DATA PRIVACY POLICY

Last update: 24 May 2018

CONTENTS

  1. Scope
  2. Responsibilities
  3. Privacy notice
    1. Who are we
    2. Information we collect
    3. Information we do not collect
    4. Data relating to minors
    5. Information from third parties
    6. Keeping your information safe
    7. How we use your information
    8. Our legal basis for processing personal data
    9. Consent
    10. Disclosure
    11. Retention period
    12. Your rights as a data subject
    13. Complaints procedure
  4. Frequently asked questions
  5. Document owner and approval

This privacy notice tells you how we, Vantage Asia Publishing Limited, will collect and use your personal data.

 

  1. SCOPE

This privacy policy applies to all data subjects whose personal data is collected, in line with the requirements of the General Data Protection Regulation (GDPR).

  1. RESPONSIBILITIES

The directors of Vantage Asia Publishing Limited are responsible for ensuring that this notice is made available to data subjects prior to the collection/processing of their personal data by Vantage Asia Publishing Limited.

All employees and representatives of Vantage Asia Publishing Limited who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and that their consent to the processing of their data is secured.

  1. PRIVACY NOTICE
  1. Who are we?

Established in 2006, Vantage Asia Publishing Limited is an independent business-to-business publisher based in Hong Kong. We publish three of the region’s leading legal magazines – Asia Business Law Journal, China Business Law Journal and India Business Law Journal – and operate vantageasia.com, a leading digital resource for in-house counsel, lawyers in private practice and other legal and business professionals with an interest in the Asia-Pacific region.

Our Data Protection Officer (DPO) and data protection representatives can be contacted directly here:

  • publisher@vantageasia.com
  • +852 3622 2673
  1. Information we collect

The personal data we will collect from you may include some or all of the following:

  • Name
  • Company name
  • Job title and nature
  • Industry/profession
  • Work address and postcode
  • Work telephone and fax numbers
  • Mobile phone number
  • Email address
  • Details of your previous employers if you have changed jobs
  • Details of your previous purchases, subscriptions and free registrations with us
  • Details of the geographical regions and/or legal practice areas that you are interested in
  • Details of times when you have been mentioned or quoted in our publications
  • Details of our interactions with you, and the outcome of such interactions
  • If you write articles or appear in videos for any of our publications or websites, or if you agree to be quoted in our editorial coverage, we may collect additional information from you, including your picture, likeness, voice, details of your views on a certain subject and your biographical information.

In addition, when you use any of our websites we use cookies and other technologies to collect information that is needed to improve your experience on our websites. This information may include:

  • IP address
  • Browser
  • Email provider
  • The pages you visited on our websites and how you reached them
  • Device
  • Internet connection
  • Location
  1. Information we do not collect

We do not store any of your payment information such as credit card details. Also we do not track or collect any sensitive information about you, such as your race, religion, ethnicity, political opinions, philosophical beliefs, trade union memberships, genetic data, biometric data, sexual orientation or health data.

  1. Data relating to minors

Vantage Asia Publishing Limited does not intentionally or knowingly process or store data relating to minors (persons under the age of 18 years). If details relating to minors are inadvertently collected, we will make every effort to delete such details.

  1. Information from third parties

As part of our ongoing efforts to reach out to new readers, we may sometimes legally acquire data from third parties (such as list brokers and researchers who have gathered this information lawfully) and from secondary sources such as online directories, social media platforms and company websites where contact information has been deliberately made available in the public domain.

  1. Keeping your information safe

We take information security seriously and have policies and procedures in place to ensure the information we hold on you remains safe. Our user database and customer relationship management system is stored on a cloud server operated by Zoho Corporation, a multinational business software development company, and our websites and accompanying data are hosted by DOOD Limited, a Hong Kong-based web design and hosting company.

  1. How we use your information

The personal data we collect may be used for some or all the following purposes:

  • For our journalists and editors to contact you to arrange interviews or invite you to write for our publications, appear in our videos or speak at events, and/or to seek your inputs and quotes for editorial reports, surveys and special features.
  • To invite you to register or subscribe to our publications and online services, and to attend relevant events organized by us and/or other organizations, and to keep you informed of advertising and sponsorship opportunities in our publications, websites, videos and events.
  • To fulfil your subscriptions and other purchases with us.
  • To send you service notifications and administrative emails such as subscription renewal reminders, outstanding payment reminders, password resets and details of updates to our policies.
  • To manage your access to online content on our website, and send you content via push notifications and email newsletters.
  • To manage your preferences and ensure we only send you communications you have requested. We may retain your details in order to suppress you from receiving our communications if you have opted out.
  • To handle customer service enquiries and complaints.
  • To detect and prevent fraud and prevent users from posting illegal or objectionable comments on our websites.
  • To inform you of special offers, competitions and promotions.
  1. Our legal basis for processing personal data

Other than where you have provided your consent, we can justify lawfully using your information on two counts. First, because it is necessary for us to use your information to deliver the products or services you have requested. And second, in certain cases we may use your information to further our legitimate interests, such as measuring user engagement with our products or informing users of new products or services. We will only do this in cases where our legitimate interests are not overridden by your rights or interests. You have the right to object to any such uses of your information. Please contact us by email at publisher@vantageasia.com or by phone on +852 3622 2673 (during Hong Kong office hours) if you wish to object. We will consider all objections fairly, but there may be legal reasons for which we deem the use of your data to be reasonable and lawful.

  1. Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by using the opt-out feature that can be found at the bottom of any email newsletters we send you. Alternatively you may contact us by email at publisher@vantageasia.com or by phone on +852 3622 2673 (during Hong Kong office hours) to inform us of your decision to withdraw your consent.

  1. Disclosure

Vantage Asia Publishing Limited will not share your data with any third parties except in cases where the sharing of your data with reputable third parties is necessary for us to effectively manage our relationship with you and provide the product or services you have requested. For example, it may be necessary to share you data with distribution companies if we are sending magazines to you, and with web hosting companies to enable you to access our websites appropriately.

We will never sell you data to other companies.

  1. Retention period

Vantage Asia Publishing Limited will store your personal data for as long as we need to in accordance with applicable law in order to provide our products and services to you and manage our relationship with you.

  1. Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your data.
  • Right of portability – you have the right to have the data we hold about you transferred to another organization.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Vantage Asia Publishing Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
  • All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
  1. Complaints procedure

In the event that you wish to make a complaint about how your personal data is being processed by Vantage Asia Publishing Limited, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Vantage Asia Publishing Limited’s data protection representatives.

Please send any complaints to the following address:
The Data Protection Manager
Vantage Asia Publishing Limited
1603 Shun Kwong Commercial Building
8 Des Voeux Road West
Hong Kong
T: +852 3622 2673
E: publisher@vantageasia.com

  1. FREQUENTLY ASKED QUESTIONS

What is personal data?

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Why does Vantage Asia Publishing Limited need to collect and store personal data?

In order for us to provide you a high quality service and send you relevant publications, newsletters and other correspondence, we need to collect personal data for correspondence purposes and/or detailed service provision. We are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

Will Vantage Asia Publishing Limited share my personal data with anyone else?

We will never sell your contact details to third parties, but it may sometimes be necessary for us to share your data with reputable third parties (for example distribution companies, data storage companies, event organizers and other companies associated with Vantage Asia Publishing Limited) in order to deliver the product or service you have requested from us. Any third parties that we share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Vantage Asia Publishing Limited’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will Vantage Asia Publishing Limited use the personal data it collects about me?

We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Vantage Asia Publishing Limited is required to retain certain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Vantage Asia Publishing Limited contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorised access or disclosure.

Can I find out the personal data that Vantage Asia Publishing Limited holds about me?

At your request, we will be happy to confirm what information we hold about you and how it is processed. You can request the following information:

  • Identity and the contact details of the person or organization that has determined how and why to process your data.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Vantage Asia Publishing Limited or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Vantage Asia Publishing Limited accepts the following forms of ID when information on your personal data is requested:

  • Passport
  • National identity card
  • Driving license
  • Birth certificate
  • Utility bill (from last three months)

Who can I contact at Vantage Asia Publishing Limited for more information?

Please send any enquiries to the following address:
The Data Protection Manager
Vantage Asia Publishing Limited
1603 Shun Kwong Commercial Building
8 Des Voeux Road West
Hong Kong
T: +852 3622 2673
E: publisher@vantageasia.com

  1. DOCUMENT OWNER AND APPROVAL

The Data Protection Officer at Vantage Asia Publishing Limited is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR. A current version of this document has been circulated by email to all staff of Vantage Asia Publishing Limited and is available to all members of staff at www.vantageasia.com.

Version: 0002

 

Date: 24 May 2018