Purpose and who we are
What You Agree to by Using Our Site
Please note that we rely on legitimate interests as the basis for processing your data in the limited circumstances set out below:
- In situations where we obtain your personal data from a source other than you, we process your data on the basis of legitimate interests, until the earlier of (a) the point at which you provide your consent; or (b) the point at which you ask us to stop processing your data on the basis of our legitimate interests;
- We will archive information about your use of our services, even after you withdraw your consent to our processing of your data. This information will only be used in very limited circumstances, such as for defending legal claims relating to contracts we have with you or a third party and retention for audit purposes relating to commercial contracts; and
- We will use information relating to your use of our services for statistical analysis and research purposes, however we delete your name and email address from such information before we do so.
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 – we provide you with the ability to pay for a print or digital subscription to our content, and other services using a credit card through a third party payment processing service provider. Please note that our payment service provider – not Kyiv Post – collects and processes your credit 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 other content offerings;
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 our 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 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 us at email@example.com.
- Legitimate business purposes – This is where we have a legitimate interest, as a business, to process personal information. 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 fulfil 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 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 keep records of communications with our customers for monitoring and training purposes.
- 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 readers use our Sites so we can make improvements. This includes testing proposed developments on our Sites, reaching out to our customers to communicate changes or new offerings.
- To bill our customers – We provide you with the ability to pay for subscriptions and other services through a third party payment processing service provider. 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 at firstname.lastname@example.org
- To monitor compliance with our policies and terms – For example, we 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 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 settings.
- 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. On some occasions, we will contact you with offers and promotions, exclusive event invitations and feature announcements. You are able to change your preferences at any time by contacting customer services. We also personalise our communications for strategic purposes. For example, we might offer group subscriptions to certain companies.
- For the purpose of advertising – We rely on advertising revenue in part to support our journalism. We need to process your information to understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising. You may also see advertisements that are targeted to you based on other non-personal information, for example, the article that you are reading.
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 print editions. 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.
- 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.
Retention of Personally Identifiable Information
If you reside or are located in the EEA, we keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
Confidentiality & Security of Personally Identifiable Information
Updating or Deleting Your Personally Identifiable Information
You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site and visiting your user account page or contacting customer support.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via email@example.com. If you reside or are located in the EEA, you have the right to request that we:
- provide access to any Personally Identifiable Information we hold about you;
- prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
- update any Personally Identifiable Information which is out of date or incorrect;
- delete any Personally Identifiable Information which we are holding about you;
- restrict the way that we process your Personally Identifiable Information;
- provide your Personally Identifiable Information to a third party provider of services; or
- provide you with a copy of any Personally Identifiable Information which we hold about you.
We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation.
When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Questions, Suggestions and Complaints
If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via firstname.lastname@example.org.
If you reside or are located in the EEA, we may assist with all queries regarding our processing of Personally Identifiable at email@example.com.
If you reside or are located in the EEA, you may also make a complaint to our supervisory body for data protection matters (namely the UK Information Commissioner’s Office) or seek a remedy through local courts if you believe that your rights have been breached.
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.
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.
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.
Personal information is collected by Businessgroup LLC.
Our Sites are not intended for children under 13 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 us at firstname.lastname@example.org.