The Thomson Reuters Foundation (We) are committed to protecting and respecting your privacy. This policy (together with our Website Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be collected and processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The data controller is Thomson Reuters Foundation and its trading subsidiary, Reuters Foundation Consultants Limited (30 South Colonnade, London, E14 5EP).
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Contact Data: This is information such as your name, email address and telephone number which we collect when you contact us by email, subscribe to any of our newsletters, use our services, including news, TrustLaw, media training through our Media Development platform (together our Services) or which we collect via our interaction with you (for example from business cards).
- Profile Data: This is information such as the organisation you work for, your job title and role, the country you are based in and your area of expertise which we collect when you sign-up or apply to use any of our Services.
- Application Information: This is information such as your country of citizenship, past and present employment details, home address and contact details and education history, which we collect when you apply to attend our media training courses.
- Information that you provide by filling in forms on our sites including Trust.org (our Sites). This includes information provided at the time of registering to use our Sites, subscribing to any of our Services, posting material or requesting further services. We may also ask you for information when you report a problem with our Sites.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete feedback questionnaires or surveys that we use for research purposes, although you do not have to respond to them.
- Details of the Services that you use on our Sites.
- Details of your visits to our Sites including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
WHERE WE STORE YOUR PERSONAL DATA
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- Administration: We may use the personal information we collect about you to contact you in response to your queries and to provide you with the Services you have subscribed to. For example, newsletters or news alerts or brokering contacts through TrustLaw Connect.
- Consider Applications: We may use the personal information we collect about you to consider your submissions on TrustLaw or your application to attend our courses.
- Communications: We may use personal information we collect about you to contact you by e-mail, post or telephone with information about the Thomson Reuters Foundation and events that might be of interest to you. You can opt out of receiving these communications at any point by contacting email@example.com.
- Internal statistical analysis: We may use the personal information we collect about you to facilitate internal statistical analysis, for example to determine the number of people using a particular service from a specific country or region. We have a policy of anonymising the information where possible.
- Optimisation: To ensure that news and content from our Sites are presented in the most effective manner for you and for your computer.
- To carry out our obligations to perform the Services or arising from any contracts entered into between you and us or to allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our Services.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
DISCLOSURE OF YOUR INFORMATION
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Thomson Reuters Foundation or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of the Thomson Reuters Foundation our partners, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- When explicitly agreed by you as part of our Services. For example, when you enrol in any journalism or media training we ask you whether you would like to share your name and contact details with other alumni; or when sharing information as appropriate and necessary when we put a lawyer and non-governmental organisation in contact to work on a pro bono case through TrustLaw Connect.
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.
ACCESS TO INFORMATION
You have the right to:
- Request access to your personal data. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
In case of any questions regarding our privacy practices, if you would like to execute your rights or would like to submit a complaint please contact firstname.lastname@example.org
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.
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.
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.
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