Privacy Policy

Introduction

Welcome to the CTFN, LLC's Privacy Policy.

CTFN, LLC respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the Policy here. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.


  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal data collected?
  4. Disclosures of your personal data
  5. International transfers
  6. Data security
  7. Data retention
  8. Your legal rights
  9. Glossary
  10. Cookie Policy


Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how CTFN, LLC collects and processes your personal data through your use of the ctfn.news website and its subdomains (collectively the Site), including any data you may provide through the Site when you complete the trial form in our homepage to request your CTFN account to be activated, when you sign in to your CTFN account, when you request a subscription to our services, when you subscribe to our email alerts, when you contact us by email or telephone, or when you purchase one of our services. This Site is not intended for children under 16 years of age. No one under age 16 may provide any information to or on this Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or on or through any of its features/complete the trial form in our homepage to request a CTFN account, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@ctfn.news or by phone at +44 203 514 5314. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller

CTFN, LLC is the controller and responsible for your personal data (collectively referred to as "CTFN," "we," "us," or "our" in this Privacy Policy. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.


Contact details

Our full details are:
CTFN, LLC
Name and title: Jonathan Spitzer, Data Privacy Manager
Email address: privacy@ctfn.news
Postal address: 152 Main Street, Westport, CT 06880
Telephone number: +44 203 514 5314 or +1 203 635 6555

If you are based in the European Union, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on May 24, 2018 and historic versions can be obtained by contacting us. If you are based in the European Union, please note that the data protection law in the EU will change on 25 May 2018. Although this Privacy Policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
We reserve the right to change the terms of this Privacy Policy at any time. We will notify you of any material changes by way of a pop-up notice on the Site announcing that the Privacy Policy has changed. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This Site may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.


The data we collect about you

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together follows:



We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.



How is your personal data collected?

We use different methods to collect data from and about you including through:




Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.



We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.



International transfers


We share your personal data within our company. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:


Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.



Data security


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.



Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us set out in the table in paragraph 4 above.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymize 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.



Your legal rights


Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:



No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.



Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES



YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.



Cookie Policy

Information about our use of cookies

CTFN uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.

Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:



You can find more information about the individual cookies we use and the purposes for which we use them in the table below:


Anonymous User

Cookie:

UTMA, UTMB, UTMC, UTMV, UTMZ

Purpose:
  • Identify visitors to the site.
  • Track the amount of time a user is on the site.
  • Track when a user exits the site.
  • Further segment and analyse the site audience beyond the categories provided by Google Analytics.
  • Segment visitors into categories.

Cookie:

CTFN_Privacy

Purpose: Logs users consent to CTFN Privacy Policy and CTFN Cookies Policy.

Cookie:

XSRF-TOKEN

Purpose: Protects against cross site request forgery.


Logged-In User

Cookie:

ctfn_session

Purpose: These cookies are essential for our site to: Check if cookies are enabled to provide an appropriate user experience. Check whether the user is logged in. Maintain a users configuration. Track whether a user has already performed an action.

Cookie:

Google Analytics

Purpose

These cookies are essential for the function of the site to: Distinguish users. Throttle request rates. Contain tokens to manage client id and requests.

Anonymous User

Cookie

Name of Provider

Purpose

More information

UTMA, UTMB, UTMC, UTMV, UTMZ

Google Analytics

These cookies are essential for our site to enables CTFN to:

  • Identify visitors to the site.
  • Track the amount of time a user is on the site.
  • Track when a user exits the site.
  • Further segment and analyse the site audience beyond the categories provided by Google Analytics.
  • Segment visitors into categories.

Google Developers Cookie Usage Documentation

CTFN_Privacy

CTFN

Logs users consent to CTFN Privacy Policy and CTFN Cookies Policy.

None

XSRF-TOKEN

CTFN

Protects against cross site request forgery.

None



Logged-In User

Cookie

Name of Provider

Purpose

More information

ctfn_session

CTFN

These cookies are essential for our site to:

  • Check if cookies are enabled to provide an appropriate user experience.
  • Check whether the user is logged in.
  • Maintain a users configuration.
  • Track whether a user has already performed an action.

Google Analytics

These cookies are essential for the function of the site to:

  • Distinguish users.
  • Throttle request rates.
  • Contain tokens to manage client id and requests.

Google Developers Cookie Usage Documentation



Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.