Privacy and Cookie Policy

This policy was last updated on 25 June 2020.

Welcome to Borderlex’s privacy and cookie policy. This notice explains how we collect, use, and discplose personal data related to your use of our services.

Who we are

When we mention “Borderlex “we”, “us” or “our” in this Privacy Policy, we mean Borderlex Publishing Limited.

About this Privacy Notice

This Privacy Notice explains how Borderlex collects, uses, and discloses data about you and processes information that identifies or can be used to identify you (sometimes referred to as “personal data” or “personal information” under applicable privacy and data security laws, and hereinafter “personal data”) when you use our website(s), mobile apps, and other online products or services that link to this Privacy Policy (collectively, the “Services”) or when you otherwise interact with us. For some interactions, we will show you other privacy policies belonging to our third-party business partners when we collect or share your personal data, and that third party’s privacy policy will also govern the collection of your personal data in addition to this Privacy Policy.

Changes to this Privacy Policy

We’re likely to update this Privacy Policy in the future and when we make changes, we will revise the date at the top of the policy and, in some cases, will notify you through the Services, such as on our homepage, or via email or other communication. Please come back and check from time to time for the latest information on our privacy practices.

How to contact us

If you have questions or concerns about the information in this Privacy Policy, our handling of your personal data more generally, your choices and rights regarding such use, or wish to exercise your rights under law, please do not hesitate to contact us at:

Borderlex Publishing Limited

85 Great Portland Street – 1st Floor

London W1W 7LT

Attn: The company Director

privacy@borderlex.eu

What personal data we collect and how

Personal data you provide to us

We collect data you provide directly to us.

Account data. If you sign up for a Borderlex.eu account (“Account”), we will collect data you give us related to your Account, including your name, email address, professional telephone number, username and password. We describe this more fully in Section 5.4 below.

Payment data. To order products or services through our Services, you may need to provide certain financial information (such as your billing or credit card information) in order to facilitate the processing of payments. We will collect the data we need in order to process that purchase (for example, payment details). Your credit card information is collected and stored by our third party payment credit card processing company. Use and storage of that data is governed by the third party payment processor’s applicable privacy policy.

Additional Account data. You may provide additional data as part of your Account . We do not make this information visible to others.

Other data. You may provide us with data when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, post comments under borderlex.eu articles, provide us with feedback, participate in promotions, or use other features of the Services.

Data that indirectly identifies you and automatically collected data

When you access or use the Services, we collect data that indirectly identifies you and we automatically collect other data about you, including:

Log Data. We automatically receive and record information from your device or web browser when you interact with the Services. For example, we collect your internet protocol (IP) address, device ID, time zone setting, language preference, operating system, platform, internet service provider (ISP), and links you have clicked on or shared with others, including through email and social media. If you sign up for an Account, we also create a user ID that indirectly identifies you. We use this information to collect data about your activities through the Services. We associate information that indirectly identifies you with your Account (if you have one) and other information we have collected about you.

Cookies. When you visit the Services, we will set certain “cookies” and similar tracking technologies on your device, including cookies and web beacons. For more information about cookies and how to disable them, please see our “Cookie Policy” section below.

We also may use these technologies to collect data about your activities on our website over time (behavioral tracking and statistics collection).

The information we collect automatically may include personal data, or we may maintain it or associate it with personal data we collect in other ways or receive from third parties.

Location data

We use your IP address to infer your approximate location. We use these data for internal processing only and for statistical analysis, in which case your identity would not be disclosed.

Profile data

If you sign up for an Account, we will collect certain data you give us as part of your Account sign-up as described above, information you give us in connection with purchases or orders made by you, and your interests, preferences, feedback and survey responses.

Your interests and preferences are inferred from data we collect regarding what types of content you have interacted with, how long you interacted with them, how often you interacted with them, and the nature of your interaction with the content.

We do not disclose this information. We also do not disclose email addresses to other users except where it is necessary to comply with the law, to protect our rights, or to protect the rights of our users.

Special category data

We do not collect sensitive personal data about you, for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation.

Aggregated data

We analyse and aggregate personal data we collect, such as the number and frequency of your visits to the Services, to produce anonymised metrics and statistical information that does not identify you as an individual.

We combine information about you with information about other users to create audience segments of aggregated data, for example, statistical, demographic and usage data. If we combine or connect aggregated data with your personal data, we treat the combined data as personal data and deal with it in accordance with this Privacy Policy.

How we collect personal data

You may give us your personal data directly, for example when you create an Account, support us by paying for a subscription, buy other products or services we provide, subscribe to our free newsletter, publish posts or comments under our posts, participate in a promotion or survey, ask for user support, or contact us for any reason.

We automatically collect personal data when you interact with our Services. We collect information about your devices and browsing actions and interests by using cookies and similar technologies. Our “Cookie Policy” section provides more details on how this works.

What we use your data for:

We use the data we collect to provide, maintain, and improve our Services. We also use the data we collect to:

Send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;

Communicate with you about products, services, offers, and events offered by Borderlex and others, and provide news and information we think will be of interest to you;

Personalise and improve the Services. Your interests and preferences are inferred from data we collect regarding what types of content you have interacted with, how long you interacted with them, how often you interacted with them, and the nature of your interaction with the content;

Monitor and analyse trends, usage and activities in connection with our Services and personalise and improve the Services;

Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Borderlex and others; and

Carry out any other purpose described to you at the time the data was collected.

Sharing your personal data

In general, your personal data will remain with Borderlex but we may share personal data about you as follows or as otherwise described in this Privacy Policy:

We share your personal data within Borderlex Publishing Limited where necessary to fulfill a contract or precontractual measures, or where we have a legitimate interest in doing so or a legal obligation to do so.

With vendors, consultants, and other service providers who process your data on our behalf when they provide services to us, for example data analytics, research, sales, marketing and online payment and accounting/tax/audit services. With all these parties, contractual arrangements are in place to protect your data.

In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

We may be legally required to disclose or share your personal data without your consent in some circumstances, for example to comply with a court order or law enforcement. In such circumstances, we will only disclose your personal data if we have a good-faith belief that such sharing is required under applicable legal obligations.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may share aggregated or de-identified information with investors or service providers so that we, and they, can understand how people use our Services; this helps us grow our business and improve and develop our products and services.*

UK and EU users: international transfer of your personal data

When we process your personal data within Borderlex, we will do so in the United Kingdom and on European Union territory.

Third parties with whom we share your data may be based outside the EEA and their processing of your personal data may involve a transfer of data outside the EEA. For more information, please refer to the privacy policy links for such third parties in our consent management platform. Links to these policies are provided below:

Hootsuite

Sendgrid

Mailpoet

Automattic

We have entered contractual arrangements with the above parties under the assumption their Privacy Policies are in compliance with UK and EU data privacy laws, that they are EU-US Privacy Shield certified where relevant, and after careful examination of their privacy policies.

Retaining your personal data

We keep your personal data for as long as we need it for the purposes for which it was collected.

When we decide how long we will keep your information we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, why we need it, and any relevant legal requirements (such as legal retention and destruction periods).

We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.

Third-Party Sites

Our site may include links to third-party sites, apps and social media platforms (“Third-Party Sites”). Clicking on those links may allow third parties to collect or share data about you. We do not endorse or control Third-Party Sites, each of which may be governed by its own terms of service and privacy policy and we encourage you to read their privacy policies and terms so that you understand how they process information about you. You are solely responsible for all liability for any damages or other harm, whether to you or third-parties, resulting from your use of Third-Party Sites. Please take all protections necessary to protect yourself when accessing Third-Party Sites, particularly when downloading or purchasing anything therefrom.

We use social media platforms Twitter, Facebook and LinkedIn to help us publicise our content. We have not enabled social media sharing features on borderlex.eu. We do not make use of their advertisement service.

We receive from the social media platforms only aggregated statistical information about your potential interactions with our content on these platforms, such as number of views, number of times shared and so on.

We process information provided to us by the social media platforms on the basis of our legitimate interest in interacting with our audience on social media and using social media to promote our content.

For more information about the purpose and scope of data collection and processing in connection with social sharing features or your use of the social media platforms, please visit the privacy policies of the respective entities at the following links:

Facebook

Twitter

LinkedIn

Hootsuite

Cookie policy

Cookies are small data text files that are sent from a server during a browsing session. Cookies are typically stored on your computer’s hard drive and are used by web sites to simulate a continuous connection to that site. The use of cookies automatically identifies your browser whenever you interact with a site. A “web beacon,” also known as a tag, pixel tag, or clear GIF, is used to transmit information back to a web server. When we talk about “cookies” in this Privacy Policy, we mean not just cookies, but web beacons and similar technologies.

Cookies and similar technologies allow us to collect the following types of personal data: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken through our Services; time and date of those actions; country and language selected.

Browsers and devices have tools that allow you to disable cookies on sites and apps. If you disable cookies you may not be able to access all the features of our services. We suggest that you keep our essential cookies (described below) active for a better user experience and to help us keep improving and developing our products and services.

Our Services use our own cookies to recognise you and remember you as a unique user.

Session cookies remember you during your session on our Services. They are deleted when you log out of the Services and when you close your web browser. You can opt to keep those cookies active by clicking ‘remember me’ when you log into Borderlex.eu. Session cookies are used to ensure you are served content correctly, to balance and monitor load on our servers, and for other technical matters essential to the operation of our Services. The session cookies will recognise you for one month, avoiding you to type your password each time you visit our website. You can configure your device to reject these cookies, but our Services will probably not work correctly, or at all, if you do.

Analytics cookies

Analytics cookies are used by us and by third parties who process data for us for data analytics purposes (Google Analytics, Sendgrid, WordPress/Jetpacks) so that we can manage and improve the performance and design of our Services and for monitoring, auditing, research and reporting.

With respect to Google Analytics, you can read about how Google uses data gathered for that purpose here.

You may opt out of Google Analytics tracking here.

Privacy information for EEA and UK users

Information for UK/EU Users

We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for another purpose, we will explain the legal basis we rely on.

Legal rights for EEA and UK users

If you are an EU or UK resident, you have certain rights in respect of the information that we hold about you. Below is a short overview of those rights:

Access. With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.

Correction. You have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend automatically to matters of public interest or opinion, such as views expressed in our editorial content.

Deletion. In some limited circumstances, you have the right to have personal data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law, or there is a public interest dimension to it).

Objection. You have the right to object to our processing of your personal data where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.

Withdrawing consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.

How to exercise your rights

To exercise your rights, email privacy@borderlex.com. In order to protect your privacy and that of others, we will ask you to prove your identity before we take any steps in response to a request you have made. If a third party is making a request on your behalf, we will ask them to prove that they have your permission to act for you.

We may contact you to ask you for further information to help you exercise your legal rights or to speed up our response. We will try to respond to requests within one month and we will let you know if we need to take longer, for example because your request is complicated. We may have an overriding lawful basis for processing your personal data, or certain exemptions may apply. If we refuse your request, we will explain why.

Complaints

You have the right to complain about data privacy matters to the Information Commissioner’s Office (www.ico.org.uk), or the relevant data protection regulator in your country of residence. You can contact the ICO on +44 (0)303 123 1113. We invite you to raise your concerns with us first, so that we can try to resolve them.