Privacy & Cookies Policy

WHO WE ARE?

The website www.blenheimstrategy.com is operated and owned by Blenheim Strategy Ltd. of  . For the purpose of this Policy, Blenheim Strategy and www.blenheimstrategy.com will be referred to as ‘we’ or ‘us’. We can be contacted via email at [email protected].

We understand the importance of maintaining your privacy, keeping your personal information secure and complying with data protection laws, and we seek to be completely transparent about what data we collect, from whom, by what means, and what we do with this data.

We are the data controller of any personal information about you. This means that we are responsible for complying with data protection laws.

 

WHAT DOES OUR PRIVACY POLICY DO?

These terms set out (i) the terms of use on which you may make use of our website at www.blenheimstrategy.com (‘Site’) and interact with us in other ways, and (ii) the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read these terms carefully before you start to using the Site or our other services. By visiting and using the Site and interacting with us by email, phone, at events and in other ways, you confirm that you accept these terms, consent to the practices described in these terms and that you agree to comply with these terms. If you do not agree with these terms, you must not use our site or services.

Our privacy policy tells you what to expect when we collect personal information about you. It applies to information we collect via (a) our website www.blenheimstrategy.com and (b) our e-newsletter sign-up forms embedded on our website using the third party application ‘MailChimp’ (our newsletter system) as well as (c) any other communications/interaction you might have with us, such as by email or phone.

By providing your personal information to us, you acknowledge that we may use it in the ways set out in this privacy policy. We may provide you with further notices highlighting certain uses we wish to make of your personal information. We may also give you the ability to opt-in or opt-out of selected uses such as electronic communications, including invitations to events, when we collect your personal information.

If you are registering other people (eg for one of our events) and are providing personal information, you must ensure this privacy policy has been drawn to the attention of those individuals and that you have permission to share their information with us.

 

WHO DO WE COLLECT INFORMATION FROM?

We collect the following information from:

  • present and past Blenheim Strategy subscribers
  • individuals who attend or register for our events
  • individuals who subscribe to receive our communications
  • users of our website
  • members of the public who contact us with inquiries
  • past and future authors
  • partners with which we work
  • expert speakers at our events or who participate in our workshops or engage in other capacities with us

 

WHAT INFORMATION DO WE COLLECT?

We collect some or all of the following information, depending on how you choose to interact with us:

Website Visitors

  • IP address
  • Traffic data
  • location data
  • weblogs and other communication data (whether this is required for our own purposes or otherwise)
  • interaction behaviour (including which pages you click, how long you stay on the website etc)

Newsletter Subscribers

  • email address
  • IP address
  • Tracking interactions (including opens, clicks, location data, etc)

Attendees at our events

  • your full name
  • email address
  • job title and organisational affiliation/company name

Speakers at our events

  • your full name
  • email address
  • phone number
  • job title and organisational affiliation/company name;
  • business and/or personal phone number
  • business and/or personal address
  • biographical information about your professional background
  • information relating to your area of expertise or interests

Authors

  • your full name
  • email address
  • job title and organisational affiliation/company name;
  • biographical information about your professional background;
  • information relating to your area of expertise or interests;
  • pictures of authors

 

WHEN AND HOW DO WE COLLECT INFORMATION ABOUT YOU?

By visiting our Website

Use of ‘cookies’

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of our Site. We do not do this to track individual users or to identify them, but to gain useful knowledge about how the Site is used so that we can keep improving it for our users.

Cookies may also be used by some parts of the site where we utilise third-party services, such as YouTube and Vimeo for video content. These cookies are managed by these external sites.

Otherwise, our website uses website cookies strictly for system administration to provide you with the best possible experience – used in order to create reports relating to web traffic and user preferences. This includes: your IP address; details of which web browser or operating system was used; and information on how you use the site.

If you do not wish to receive cookies from us or any other website, you can turn cookies off on your web browser: please follow your browser provider’s instructions in order to do so. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org and www.allaboutcookies.org.

Embedded content

Some of the content on our site is provided by third parties. This includes but is not limited to: YouTube or Vimeo for hosted video, Flickr for images, Facebook or Twitter for social media feeds. When you visit a page containing content from one of these sites a cookie may be set. We do not have any control over these cookies and you should check the relevant third party website for more information about these.

Links to third party websites

Users may find advertising or links to external content such as articles, media or blogs on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

By signing up to receive our newsletter or contacting us via email

You might give us information about you by filling in forms on the Site or by corresponding with us (for example, by e-mail or otherwise). This includes information you provide when you register to receive our newsletter, participate in any discussion boards or other social media functions on our site, sign up for events or surveys on the Site and when you report a problem with the Site.

If you contact us by email, we may keep a record of that correspondence. The information you give us may include your name, address, e-mail address and phone number where applicable.

When you sign-up for our e-newsletter, we only collect your email address and we will only use this information to send you our monthly (maximum two newsletters a month) newsletter, which contains invitation to our upcoming events, or the events of selected partners, our latest articles and analyses and any news related to our activities. We will not pass your details on to any third parties aside from the third party providers we use for our sign-up forms and to process and store your information and send you newsletters. MORE ON THIS UNDER THE THIRD PARTY SECTION OF THIS POLICY.

By registering (via email or phone) to attend one of our events

When you sign up by email or phone to attend one of our events, we record your full name, any organisational affiliation (although you can choose not to provide this information) and email address. We collect this information in order to confirm your attendance, notify you of any changes prior to the event (such as speaker changes, cancellations or changes in date/timing/venue) as well as to prepare attendance lists that we hand out to all attendees during the event to facilitate networking among attendees in the context of the event. On such attendance lists, we never provide email addresses of course, only the attendee’s names and organisational affiliations. If you would not like to be included on such attendance lists, please do let us know when registering for an event.

Since we frequently collaborate with partners for the organisation of an event, in some cases we do not ourselves manage the registration process for the event. In these cases, we might pass your details (name, email address and affiliation) on to our partners to process your registration and communicate with you concerning this registration.

We will not sell, distribute or lease your personal information to any third parties unless we have your permission or are required by law to do so.

By physically signing one of our attendance or registration consent forms

We might make available registration forms at our events or in other contexts, where interested attendees and visitors can subscribe to our newsletter lists, if they so choose.

 

WHAT WE DO WITH YOUR INFORMATION?

Information you provide us with (by visiting our website, registering for our events, signing up to our e-newsletter or by emailing or calling us, for example) are used in the following ways, and for the following purposes:

  • to ensure that content from our Site is presented in the most effective manner for you and for your computer
  • to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
  • to carry out our obligations arising from any contracts entered into between you and us, for example if you take up employment with us. If you unsuccessfully apply for a job, volunteering role, or as a freelancer, your personal information will be held for 12 months after the recruitment exercise has been completed and will then be destroyed or deleted
  • to allow you to participate in interactive features of our service, when you choose to do so
  • to invite you to events ran by us or our co-partners
  • to administer your donations or support your fundraising, including processing Gift Aid (we do not store credit card details)
  • to notify you about changes to our service
  • as part of our efforts to keep the Site safe and secure;
  • to fulfil orders for goods and services
  • to administer your membership
  • to create personal pages for our authors
  • to carry out in-house research and analysis, for example data mining, marketing statistics or equal opportunities monitoring
  • to approach you for charitable funding where you have consented to be contacted for such purposes
  • to monitor customer traffic patterns, Site usage and related Site information in order to optimize your use of our Site; data collected in this way will be aggregated and anonymized and passed to a reputable third-party, but these statistics will include no information personally identifying you

 

WHERE DO WE STORE YOUR PERSONAL INFORMATION

Depending on the user’s interaction with us, i.e. website use, newsletter registration, email interaction, or as experts and authors, we might store your personal information in one or more of the following ways:

  • On our hosting providers dedicated data centres located in the UK.
  • On select computers operated by our managers and staff.
  • On the servers of any third party data processors we might use (more information below under Third Parties)


DATA RETENTION DURATION

We will only hold your personal information on our systems for as long as is necessary to operate the service in accordance with the services you have requested from us, legal requirements and tax accounting rules. Where your information is no longer required, we will ensure it is disposed of in a secure manner.

 

WHICH THIRD-PARTIES THAT WE WORK WITH COLLECT INFORMATION ABOUT YOU?

Google Analytics

As already mentioned previously, when someone visits www.blenheimstrategy.com we use a third-party service, Google Analytics, to collect standard internet log information and details of visitors’ behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site so to improve our webdesign to make it more user friendly, improve the user experience as well as a mean to understand and be able to communicate to potential advertisers or partners the size of our readership and its growth.

Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Google’s privacy policy is available here.

MailChimp

Information obtained from you when you sign up to receive our monthly newsletter (twice a month) include only your email address. We use of the third party mailing list/newsletter service provider ‘MailChimp’, which is owned by Rocket Science Group, LLC, 675 Ponce De Leon Ave # 5000, Atlanta, GA 30308, USA.

The e-mail addresses collected of our Newsletter subscribers, as well as their other information described in these notes, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletters on our behalf. Furthermore, MailChimp may, according to its own information, use this data to optimize or improve its own services, e.g. for the technical optimization of the shipping and the presentation of the newsletter, or to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to contact subscribers directly, or to pass them on to any other third parties.

We rely on the reliability, IT and data security of MailChimp. MailChimp is certified under the US-EU and US-Swiss privacy shield frameworks and is committed to complying with EU data protection requirements. Furthermore, we have concluded a data processing agreement with MailChimp. This is a contract in which MailChimp pledges to protect the data of our users, to process it in accordance with its privacy policy on our behalf and, in particular, not to disclose it to third parties.

Please see here for MailChimp’s Terms of Use and Privacy Policy policies.

Hootsuite

We use a third party provider, Hootsuite to manage our social media interactions. If you send us a private or direct message via social media the message will be stored by Hootsuite for three months. It will not be shared with any other organisations.

For more information, please see Hootsuite’s privacy policy.

 

LEGAL BASIS FOR COLLECTING INFORMATION

We believe we have two separate legal bases for collecting private data, depending on the exact context/activities:

Legitimate Interest: It is imperative for our work, and the services and public goods we provide that we approach, via email or phone, experts who we wish to invite as writers or participants in our events, and that we contact experts from a variety of private and public sector organisation as well as the media, not-for-profit organisation, international organisation and academia to our events as discussants. Thus, the carefully considered and specific purposes for which we use data in the context of legitimate interest might for example include the following:

  • inviting potential speakers and participants in a business / professional capacity to our meetings or events.
  • inviting experts and authors to write for our website or conduct research on our behalf.
  • engaging with particular individuals holding relevant policy-making positions, hand-picked experts, corporate professional individuals, journalists and those working in other relevant sectors in a business / professional capacity.

Consent: However, for the purpose of operating our newsletter and mailing list, and sending out invitations to our events, news about new articles and about other Blenheim Strategy activities, the legal basis on which we operate is ‘consent’. Hence, for sending out our newsletter, which is also open to the general public, we rely on consent, which we acquire through a GDPR compliant sign-up forms on our website, and which requires acceptance of our privacy and cookies policies as well as clearly setting out the purpose of the newsletter and any additional ways in which we would contact subscribers as well.

 

YOUR RIGHTS

Under the UK Data Protection Act and/or the upcoming European Data Protection Regulation (GDPR) and eprivacy laws, you have the following rights:

The right to be informed

The right of access

The right to rectification

The right to erasure

The right to restrict processing

The right to data portability

The right to object

Rights in relation to automated decision making and profiling.

For more information on these rights, please see the guidance provide by the Information Commissioner’s Office.

Controlling your personal information

Under the UK Data Protection Act 1998 and the upcoming European Data Protection Regulation (GDPR) give you the right to access information held about you.

You can also at any time ask for the data we hold about you to be changed or erased.

Your right of access and erasure can be exercised by contacting us at [email protected]

Complaints

If you are concerned that we have breached a privacy law or code binding on us, please send an email to [email protected] We aim to respond in a reasonable time (normally within 14 days). Our team will manage your complaint and will give you additional information about how it will be handled.

You have the right to complain to the Information Commissioner’s Office (ICO) if you believe we do have not handled your request in an appropriate manner. For information on contacting the ICO please see their website.

 

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect online.

 

CHANGES TO THESE TERMS

We may revise these terms at any time. Any changes we may make will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to take notice of any updates or changes to our terms, as they are binding upon you.

 

CONTACT US

Any questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]

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This is version 1.0 of our privacy policy, created on 22nd May 2018.