This Policy covers our collection, processing and use of personal data when you use any of our Website. When you supply any personal data to us we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:
- What is personal data and what do we collect
- How and why do we use/share your information
- For how long do we keep your information
- Your Rights
- Contact Details
It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data. This Policy supplements other notices including our Websites’ respective Terms and Conditions and Cookies Policies and is not intended to override or replace them (for this Website’s Cookies Policy please click here). By visiting or otherwise using our Websites, you are agreeing to the practices set out in this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using the Websites. We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let registered users of the Websites know. However, it is your responsibility to check this Policy before each use of our Websites – for ease of reference the top of this Policy indicates the date on which it was last updated. Please note that our Website is not directed at children under the age of 13 (each a “Child” together “Children“) and we do not knowingly collect personal information about Children. If you believe we have collected personal information about your Child, you may contact us at firstname.lastname@example.org and request that we cease processing information about your Child.
2. What is Personal Data and what do we collect?
What is personal data? Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address. By law all organisations are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Policy.
Data we collect from you when you use the Websites Voluntary Provision of Data
When you voluntarily supply your personal data to us, for example where you; use the Websites to upload or send personal data (by filling out a form, subscribing to a publication or newsletter, taking part in an online survey, posting a comment, entering a competition, or engaging in similar activities in which you volunteer data about yourself); contact us by post, telephone, email or SMS; report a problem with a Website; we may collect, store and use the personal data that you disclose to us. The information we collect from you may include your title, name, address, e-mail address, company, job title, birthday, phone number, financial and credit card information – but will depend on precisely what details you volunteer to us and the precise nature of the reason for your submission of that data.
Automated Collection of Data We may also collect information about you when you visit the Websites through the use of technologies such as cookies. The following are examples of information we may collect:
- information about your device, browser or operating system;
- your IP address;
- information about links that you click and pages you view on our Website
- length of visits to certain pages;
- subjects you viewed or searched for;
- page response times;
- records of download errors and/or broken links;
- page interaction information (such as details of your scrolling, clicks, and mouse-overs);
- methods used to browse away from the page; and
- the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).
We use the data described above for several different reasons. Firstly we use it to ensure that the Websites work properly (e.g. to manage technical functionality, such as enabling you to log in to sections that you access with a username and password) and that you are able to receive the full benefit of them. Second, we use the data to monitor online traffic and audience participation across the Website. Cookies that relate to these functions will be deployed on your computer automatically, either as you access the Website or as you engage the relevant functionality. If you block these cookies then certain aspects of the site may not operate properly (as they rely on the cookies to work). We undertake these activities because we have a legitimate interest in doing so and, for most of the cookies in question, because we need to do so in order to deliver the parts of the Websites that you are trying to access to you.
3. How and why do we use/share your information
Core Services We will use your personal data to provide various services that you request from us. Depending on which services you tell us that you want to receive this may include sending you printed publications, sending you e-mail updates and newsletters, enabling you to receive news of and apply for job vacancies, and enabling you to attend and participate in events. Where an individual nominates you for an award which is to be presented at one of our events, or where you are suggested as a potential judge at such events, then we will process your data on the basis that we have a legitimate interest in doing so in order to ensure that awards are fairly awarded to the most worthy winners. Where we wish to process your personal data for more than a brief period of time (if, for example we decide to add your details to a short list of potential winners or judges) then we will notify you that this processing is taking place and give you the opportunity to ask us to stop if you are not happy for it to continue. Where you provide us with your personal data in this way we will use it to the extent necessary to fulfil the terms of the contracts that we enter into with you. Where you subscribe to receive e-mail updates from us which represent marketing communications we will use your personal data on the basis that you have consented to use using your data for this purpose. You can withdraw this kind of consent at any time – for more information see ‘Your Rights’ below. Sharing your information Depending on how and why you provide us with your personal data we may share it in the following ways:
- we may share your personal information with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
- with selected third parties who we sub-contract to provide various services and/or aspects of the Website’s functionality, such as where third party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below); and
- with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.
We will not share your information with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a competition where a third party is providing the prize) and you have provided your consent for that use. Such activity may have its own terms and conditions relating to the way in which your information may be used, which you will be notified of at the relevant time. We may also disclose your personal information to third parties in the following events:
- if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets as part of that sale;
- if Connecting Travel or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
Service Providers Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of our major service providers:
- Where you subscribe to one or more streams of e-mail communications from us (such as newsletters or other e-mails) we use Salesforce’s ‘Pardot’ system to store your details and to manage the sending of those communications to you.
- Where you register to come to one of our events we are likely to use Version Two’s ‘Evessio’ platform to manage your registration and attendance details.
- Where you use any part of our Websites that involve job vacancies, your details (including details of any listings or applications that you make) will be stored on and processed via Madgex’s ‘Job Board’ system. Your details will also be passed to an company or individual to which you make any form of application.
- Our Websites are hosted on third party servers which are provided to us by a variety of hosting service providers, all of those servers are locate within the EEA (or where they are provided on a ‘cloud’ basis appropriate mechanisms are in place to ensure that your data is kept secure) for more information on these mechanisms see ‘Security’ below.
- Where you subscribe to receive a printed publication to you we will share your details with various fulfilment partners (which will depend on which publication you subscribe to) who handle tasks such as printing and distribution for us. We may also pass your details to organisations which handle telephone contacts for us, such organisations may be used to contact you if/when your subscription is due to lapse to remind you that you will need to renew that subscription if you wish to continue receiving the relevant publication.
Links to third party sites Where we provide links to third party websites that are not affiliated with the Connecting Travel those sites will have their own privacy policies and will not be covered by this policy. Such sites are out of our control and if you access them using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.
- For how long do we keep your information? We will hold your personal information on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected. For more specific descriptions of how long we will retain your data for specific activities please see the details provided below in respect of certain key areas of processing:
Magazine Subscriptions Where you subscribe to receive a printed publication from a member of the Connecting Travel we will hold your details for the duration of your subscription. We will also keep your details for a period of up to [six years] after your subscription has lapsed as part of our books and records – which enable us to properly account for our business each year, and which we need to keep on file in order ensure that we are able to properly respond to any disputes which may arise relating to that subscription (or the fulfilment of it by our fulfilment agents).
Newsletter Subscriptions and other e-mail communications Where you subscribe to receive a newsletter or similar e-mail communication we will hold your e-mail address for the full duration of that subscription in order to ensure that we are able to deliver that subscription to you. We may also hold other details about you which you provide to us (such as your name and title) to personalise those communications to you. If you unsubscribe from a publication (by way of sending us an ‘opt-out’ message telling us that you do not wish to receive it in the future) we will keep a record of your e-mail address indefinitely in order to ensure that we know that we must not send similar correspondence to it going forwards (this practice is often referred to as ‘supressing’ an e-mail address) – for more information see ’Your Rights’ below.
Use of Online Job Boards Where you use online job boards featured on our Websites to advertise your availability for, or to apply directly to, job vacancies we will use that data to advertise your ability and to send any applications that you may make to the relevant recipients. That data will be held and made available on the job board for so long as you maintain an active profile. You can deactivate your profile at any time, either by ‘hiding’ your data or by deleting your profile entirely. If you give us your consent to send you future updates about vacancies that may be relevant to you (which you may do we will use your details in the same way as described in ‘Newsletter Subscriptions’ above. Where we do this we will use the details that you have supplied to us in order to ensure that we are supplying you with details of jobs that are relevant to the interests/qualifications that you have described to us. You can unsubscribe from these e-mails at any time – however, please note that this is a separate service to hosting your profile, and that you will need to unsubscribe from these e-mails separately if you wish to stop receiving them. You can do this by using the ‘unsubscribe’ link contained in each e-mail – for more information see ’Your Rights’ below.
Applications to the Connecting Travel Where you approach us to enquire about employment opportunities or to apply for an advertised vacancy at the Connecting Travel we will keep your details and your application on file irrespective of whether you are successful or not. We do this on the basis that we have a legitimate interest in ensuring that we are able to contact you should a suitable vacancy arise in the future. Usually we will keep your details in this fashion for a period of twelve months or less. However, if you are a candidate who we consider has particularly specialist skills that may be relevant to our business in the future (or where you have gained additional experience or qualifications) then we may keep your details on file for several years. You are always entitled to ask us not to do this, or to have us dispose of your data if you do not wish for us to retain it – for more information, please see the section on your rights below
Events and Awards Where you attend one of our events (as a guest or as a judge) and/or are awarded an award at such an event then we will keep your details on file for up to six years to ensure that we are able to accurately record who attended. If you are awarded an award at such an event then we will keep your details in a similar fashion in order to ensure that we have an accurate record of previous winners. We will keep such details on file for so long as we continue to operate the same or similar events. We do this on the basis that we have a legitimate interest in being able to withhold a list of previous winners for reference purposes. Please note that where you supply sensitive personal data to us as part of your attendance at an event (such as disclosing dietary preferences to us which indicate that you suffer from a particular health condition) we will retain that data on file for future reference to ensure that we respect those preferences in the event that you attend future events. You may ask us to stop holding that data at any time and we will always honour and respect those requests. In some circumstances you can ask us to delete your data: see ’Your Rights’ below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Security Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your order, the processing of your payment details, the hosting of one or more of the Websites, and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. In most cases the safeguard which we rely on is the ‘Standard Contractual Clauses’ permitted by the GDPR, but where our Suppliers are members of programs such as the USA’s ‘Privacy Shield’ or have other appropriate mechanisms in place we may rely on those mechanisms instead. If you would like more information about the mechanisms via which your personal data is transferred, please contact email@example.com If we ever give you (or where you have chosen) a password which enables you to access certain parts of this Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Your Rights As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”). Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data. You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request. Your Right to Rectification and Erasure You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request. You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request. Your Right to Restrict Processing Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy above which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims. Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it. You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request. Your Right to Portability Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format. Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests. Your Right to stop receiving communications Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications). Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at firstname.lastname@example.org and telling us which communications you would like us to stop sending you. Your Right to object to automated decision making and profiling You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you. Exercising your rights When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity. It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
7.Contact Details If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above or if you think that the Policy has not been followed, please contact us at
General Manager Connecting Travel Media Group Fz LLC Office 115, Building 8, Dubai Media City, Dubai, UAE