Medley Global Advisors (MGA) provides premium news, insight and analysis to a growing audience of global decision makers. We have held true to our values of integrity, authority and independence for more than 21 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 representative.
If you have any queries about how we use your personal information, please contact our Data Protection Officer at firstname.lastname@example.org.
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 and title;
- Personal contact details – such as mobile phone number;
- 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.
On occasion, we may ask you to voluntarily provide additional information, for example:
Information we obtain from partners and public sources
- Your opinion of our products and services;
- Your preferences, including topics you may find interesting.
In some circumstances, we collect information about you from our partners or from publicly available sources 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 events from public websites.
Lawful basis for processing
We only process personal information where we have a lawful basis for doing so, such as the following:
How we use your personal information
- 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 enquiry 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 by contacting your account representative.
- 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 Sites, 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 an event attendee, we would need to process your information to enable your attendance.
- 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.
We collect personal information for five main reasons:
Who we share your personal information with
- To provide our service – We require some of your basic personal information to be able to provide you with our services, for example, delivering the emailed reports to your correct address, providing access to our digital content, notifying you of changes to our services and dealing with customer services queries. We make a record of customer calls and interactions for monitoring usage of our services.
- To improve and maintain performance – In order to provide you with the best possible user experience, we need to make sure that our products and services work as they should. Using personal information helps us understand how our clients use our Sites so we can make improvements. This includes testing proposed developments on our Sites, reaching out to our customers with market research surveys and hosting subscriber focus groups.
- 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.
- 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 offers, exclusive event invitations and feature announcements. You can change your preferences at any time by contacting your account representative.
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:
How long we retain your personal information
- 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. For example, if you attend one of our events, we may provide your details to the event venue to facilitate your attendance.
- Institutional customers – Because your subscription is provided by your employer under a group subscription or trial, we will provide your employer or educational institution with information about your level of activity on the site and interactions with our employees. We may also provide current or prospective institutional clients with activity information about individual subscribers who registered using that entity’s corporate email address.
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.
A summary of how long your personal information is retained can be found below:
|Category of Data
||Justification for Retention
||Web and interaction activity
||36 months (then aggregated + non-personally identifiable)
||To improve and maintain performance, personalise our services and to provide our product.
|Customer service queries
||Complaint about non-delivery of reports
||To provide a case history to assist us to answer your queries.
||Email stating that your subscription is up for renewal
||So that we have a record of what communications we have sent to you, to better assist your queries
||Sign up information for Meet the Policymaker Events
||13 – 36 months
||For event administration and, with your permission, to invite you to future events.
||Responses to a survey about MGA services
||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.
||Account information relating to MGA consulting contracts
||7 years post-subscription
||To enable us to fulfil your contract with us.
It is sometimes necessary for us to keep your personal information for longer periods of time, for example:
How we keep your personal information secure
- 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.
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. We use encryption technology, such as Secure Socket Layer (SSL), to protect your personal information when you interact with products or services from us.
We operate a global business, so your personal information may be processed and stored globally (i.e. information about our European customers will be stored outside the European Economic Area (EEA)). For example, our global customer services team may need to access information about your account to respond to your queries. Where necessary, we put in place safeguards to protect information that is transferred in this way.
Under data protection laws, you may have rights as an individual in relation to the personal data we hold about you. These rights might include:
- The right to object to direct marketing – your preferences can be updated by contacting your account representative;
- 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 exercise these rights by contacting your account representative.
If you are based in Europe, you may also have the right to lodge a complaint with a data protection supervisory authority such as the Information Commissioner’s Office (ICO)
in the UK.
Personal information is collected by Medley Global Advisors, L.L.C.
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 email@example.com .
Medley Global Advisors L.L.C.
330 Hudson Street, 8th floor, New York, NY 10013, USA
European Data Protection Representative: The Financial Times Ltd,
Number One Southwark Bridge, London SE1 9HL, UK.
This policy is effective from 4 December 2018.