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PRIVACY POLICY

This Privacy Policy applies to all websites, products and web applications which
link to this policy; a full list of relevant titles can be found at the bottom
of this page. These products and services provide premium news, insight and
analysis to a growing audience of global decision makers. We are committed to
upholding the highest standards of data protection for our customers.

If you wish to update your email newsletter or marketing preferences, you can do
so at any time through your account. Additionally, you can request to modify or
update any of your personal information that we hold by emailing
cssupport@money-media.com.

If you have any queries about how we use your personal information, please
contact our Data Protection Officer at privacy.mm@ft.com.



INFORMATION WE COLLECT

This section details the information we may collect about you. We explain why,
and how, we use it in later sections.


Account information
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 your full name;
 * Work details - such as job title, role and department, company name, company
   address, work email address and office phone number;
 * Personal contact details - because Money-Media subscriptions are corporate
   rather than individual, we will only ask you to provide us with your personal
   contact details, such as home address, delivery address, home phone number,
   mobile phone number and email address, when no work details are available.
   For example, on Agenda and BoardIQ , we allow outside directors to create an
   account even though in some cases they may be retired; individuals who are in
   between jobs are also allowed to register for a trial using their personal
   email address at the discretion of our sales team.
 * Log in details - such as username and password.
 * If you choose to register for our ThinkTank Continuing Education Credit
   service, we will also ask you to provide your relevant license registration
   information.

Additional information
On occasion, we will ask you to voluntarily provide additional information, for
example:

 * Your opinion of our products and services;
 * Your mailing preferences, including issue types or topics;
 * Your demographic data, such as role and department related to your job or
   profession.
 * Your name, email address and comments, as well as the recipient’s name and
   email address if you use the “Email this Article” functionality.

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 may obtain
additional demographic details from our partners to enrich our data for the
purpose of understanding reader preferences or attracting potential advertisers.

Information we obtain through cookies and similar tools
We use cookies (and similar technologies) and analytics tools across our Sites
to collect information about you. This information can be used to improve the
performance of the site, make advertising more relevant and enhance your user
experience. We provide detailed information about cookies and similar
technologies within our Cookie Policy; examples include:

 * Your location - we monitor the IP addresses, or location, along with the
   corresponding username and password of each user in order to prevent
   unauthorized access to our sites. We also use location to tailor
   functionality on our websites to conform to certain regulatory requirements.
 * Your usage - statistical data regarding access to each site is gathered,
   including the frequency of use, duration of use, scroll-depth, and number of
   visits per page. This helps us identify usability issues and improve the
   assistance we can provide to users and is also used for aggregated and
   statistical reporting purposes. For users of our ThinkTank Continuing
   Education Credit feature, we will also track your active reading time on
   accredited documents.
 * Your device - we use analytics tools to understand what type of device you
   are using to show you the best version of the site.
 * Your engagement with advertisements - on some of our sites we use cookies to
   understand what advertisements you have been shown, or clicked on, to bill
   our advertising partners, and to present you with advertisements that are
   more relevant to you.



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 within your account
   or by contacting cssupport@money-media.com.
 * Legitimate business purposes
   This is where we have a legitimate interest, as a business, to process
   personal information. For example, where we are aware of copyright
   infringements on our Site, it is in our legitimate interests as a business to
   identify those responsible. 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 registered reader, we would need to
   process your corporate email 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 main reasons:

 * To provide our service
   We require some of your basic personal information so our services function
   as you would expect, for example, delivering the newsletter to your correct
   email address, providing access to our digital content, notifying you of
   changes to our services and dealing with customer services queries. We record
   customer calls 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 with market research surveys and hosting
   subscriber focus groups.
 * For billing purposes
   With the exception of Financial Advisor IQ , which has free registration, all
   Money-Media subscription products are corporate rather than individual. For
   all subscriptions provided by your employer or through a group entity, we
   will routinely report how active you are in order to justify the price of the
   group subscription. Any usage information provided about your reading
   activity is at a high level in aggregate form (e.g. total page views, last
   login date).
 * To monitor compliance with our policies and terms
   We monitor for breaches of our terms and conditions and copyright policies.
   For example, we reserve the right to inform the subscription holder if,
   through use of a group subscription, you are using our content in breach of
   the terms and conditions or copyright policies of our Sites. We also monitor
   activity on our Sites to detect and prevent invalid or fraudulent traffic.
 * To personalise our products and services
   We improve our products and services by personalising your experience based
   on the information you give us and what we learn about you. This includes
   personalising communications to ensure that they are relevant to you.
 * 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. We will contact you with
   carefully-curated offers and promotions, exclusive event invitations and
   feature announcements. You are able to change your preferences at any time
   through your account or by contacting cssupport@money-media.com.
 * For the purpose of advertising
   We rely on advertising revenue in part to support our award-winning
   journalism. We need to process your information to understand the
   effectiveness of the advertising we serve to you and others, and to deliver
   relevant personalised advertising. We use the information you give us and the
   information we collect about you to serve you with the most appropriate
   advertisements. We provide detailed information about advertising in our
   Cookie Policy.



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; hosts, organisers and
   sponsors of our events; organisations that host our Sites or databases; and
   providers of online surveys.

   For Agenda and BoardIQ subscriptions only which are offered in print (all
   other products are exclusively online), we also work with key distribution
   vendors to deliver subscriptions. 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 magazine.

 * Advertisers
   With the exception of Ignites Europe and any subscriptions to MandateWire
   (which has no advertisements), we, and our advertising partners, use cookies
   to collect personal information and serve you with advertisements that we
   believe are relevant to you and your interests. There is more specific
   information about our advertising partners and data sharing in our Cookie
   Policy.
 * MandateWire directories
   As part of our MandateWire service, we offer a database of individuals who
   are linked to investment activities or listed as a key company contact. We
   collect this data through research using publicly available information and
   also through our journalists who speak with individuals directly about their
   investment activities. This data is published and shared with our subscribers
   who, on occasion, contact individuals in our directory. We limit the data we
   publish to work details only, including full name, job title, department,
   company name, company address, corporate email address, and office phone
   number.

   If you no longer wish to have your details included in our database, or would
   like us to share the exact details we hold on you, please send an email to
   support@mandatewire.com.

 * Group subscription and free trial registrants
   With the exception of Financial Advisor IQ which has free registration, all
   Money-Media subscription products are corporate rather than individual. If
   you are a licensed reader as part of a group subscription or have free trial
   access, your contact details along with usage information may be shared with
   key contacts within your organization for the purpose of validating that your
   contact details are accurate, preventing unauthorized access, and justifying
   the price of a corporate subscription. Any usage information shared about
   your individual reader account is in aggregate form and your employer cannot
   track exactly what articles you have read.
 * Think Tank - continuing education credit providers and publishers
   If you choose to read documents on our ThinkTank pages, your name, email
   address and company may be provided to the publisher of the document for
   their marketing purposes. If you choose to use our ThinkTank Continuing
   Education Credit feature, your registration details and credit hours earned
   on ThinkTank will be provided to your credit provider e.g. CFP.
 * Social media providers
   Your information will be shared with social media platforms where social
   media plugins are used to recommend or share content (e.g. share an article
   on LinkedIn). 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.
 * FT group
   We share your information within the FT group to provide our services and to
   better understand our audiences and the relationship between our products.
   More information about FT group is on the FT Group “About us” website. For
   example, FT Live may send exclusive invitations to subscribers of products
   and services offered by Money-Media, a Financial Times group company, if an
   event may be of particular interest to that individual. FT may also contact
   you if you engage with FT content on our sites.
 * Legal processes and successors in title
   We may also disclose your information to comply with applicable laws, court
   orders or other valid legal processes, and to enforce or apply our terms of
   use, any subscription agreement, or any of our other rights.

   We may transfer or disclose your personal information to any entity which
   takes over or acquires the relevant Money-Media business.

We also share aggregated, non-identifiable information with third parties.
Before sharing this information, we ensure that it cannot identify you as an
individual. For example, we regularly release information about the size and
growth of our audiences.



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.

A summary of how long your personal information is retained can be found below:

Category of DataExampleRetention PeriodJustification for RetentionBusiness
intelligenceWeb activity on services offered by Money-Media, Inc.7 years after
account is inactiveTo improve and maintain performance, personalise our services
and to provide our product.Comments and Site FeaturesComment on an article or
saving an article7 years after account is inactiveTo enable our readers to see
other readers’ comments about our content and to improve your experience of our
products and services and to enable you to continue accessing site
features.Customer service queriesComplaint about non-delivery of email
newsletter7 yearsTo provide a case history to assist us to answer your
queries.Event registrationSign up information to FT Rankings and ODX events7
yearsFor event administration and, with your permission, to invite you to future
events.Subscription informationAccount information relating to your Ignites
subscription7 years post-subscriptionTo keep a record of the products to which
you have subscribed to in the past across our different brands, to assist with
queries.



It is sometimes necessary for us to keep your personal information for longer
periods of time, for example:

 * If there is a statutory requirement to retain it;
 * If we require the information for legal reasons or there is a legitimate
   business need for us to retain it;
 * To ensure we do not contact you if you have asked us not to.



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 use encryption technology, such
as Transport Layer Security (TLS), to protect your personal information when you
order products or services from us.

We operate a global business, so your personal information (even if you are an
EU customer) will be processed and stored outside the European Economic Area
(EEA).



YOUR RIGHTS

Under data protection laws, you have rights as an individual in relation to the
personal data we hold about you. Depending on where you are based, these rights
may include:

 * The right to object to direct marketing - your preferences, including in
   relation to direct marketing, can be found in your account;
 * The right to access the personal data that we process about you;
 * The right to request the deletion of your personal data;
 * The right to request the rectification of your personal data - you can manage
   some of this information in your account.

You can exercise applicable rights through your account or by contacting
customer services.

Depending on where you are based you may also have the right to lodge a
complaint with a supervisory authority. In the UK, this is the Information
Commissioner’s Office (ICO).



WHERE THIS PRIVACY POLICY APPLIES

Personal information is collected by Money-Media, Inc., The Financial Times (M-M
UK) Limited, and The Financial Times Limited on behalf of the Financial Times
group of companies and its trading entities. This policy specifically applies to
the following titles:

 * Agenda
 * BoardIQ
 * CPG Specialist
 * Financial Advisor IQ
 * FundFire
 * Health Payer Specialist
 * Ignites (US)
 * Ignites Europe
 * Ignites Asia
 * Life Annuity Specialist
 * MandateWire (US)
 * MandateWire (EU)
 * MandateWire (Asia)
 * P&C Specialist

Our Sites are not intended for children under 16 years of age. We do not
intentionally collect or use any information from children.

Our Sites contain links to third party websites which are not subject to this
privacy policy. We are not responsible for their content, use of personal
information, or security practices.

If you have a query in regards to the processing of your personal information,
please contact our Data Protection Officer directly at privacy.MM@ft.com.

EU Representative
The Financial Times Ltd
Registered Office: Bracken House, 1 Friday Street, London, England, EC4M 9BT, UK
Registered Number: 227590
ICO Registration Number: Z7087146



CHANGES TO THIS PRIVACY POLICY

This policy is effective from 5/24/2019.

Any changes we may make to this privacy policy will be posted on this page. If
changes are significant, we may choose to notify you by email or to clearly
indicate on our home page that the policy has been updated.



PRIVACY NOTICE FOR CALIFORNIA CONSUMER PRIVACY ACT

This section was updated on 1 July 2020 and supplements the information in our
Privacy Policy above.

Rights for California Residents
If you are a California resident, the California Consumer Privacy Act (CCPA) may
provide you with additional rights regarding the use of your personal
information. These rights include:

 * The right to access the personal information we process about you;
 * The right to know what personal information is collected about you, whether
   any information is sold or disclosed, and to whom;
 * The right to request the deletion of your personal information, if
   applicable;
 * The right to opt-out from the sale of your personal information, if
   applicable;
 * The right to not be discriminated against for exercising any of the rights
   above.

You can exercise any applicable rights by emailing ccpa.mm@ft.com. You may be
required to submit proof of your identity and/or address, if we are unable to
confirm your identity or cannot verify that you are a California resident. We
endeavor to respond to a verifiable consumer request within 45 days. You may
also designate an authorised agent to make a request on your behalf, subject to
proof of identity and authorisation.

Summary of consumers’ personal information we have collected in the preceding 12
months

Categories of Personal Information(as defined by California law)

Sources of InformationBusiness PurposesCommercial PurposesIdentifiers: real
name, alias or account name; contact information including email or postal
address and telephone number; unique personal identifiers including online
identifier and IP address.

Directly from you: as part of the account information you provide when you sign
up to our services, or when you enquire about our products or services.

Information we obtain: including information from partners, service providers or
public sources.

Providing Services: including fulfilment of orders; running our events;
providing customer services; verifying customer information; maintaining
accounts and auditing interactions with customers.
Advertising: short term use of personal information for the customisation of ads
to make the advertising on our sites more relevant.
Security: including detecting security incidents and debugging.
Quality Assurance: including internal research for technological development and
maintaining the quality of our products and services.
Legal: including monitoring compliance with our policies and terms and
communicating product changes.
Operational Purposes: other operational purposes, such as recruitment.

Marketing: including sales and promoting products and services.
Advertising: allowing third parties who advertise with us to measure the
effectiveness of their ads.
Directories: including the building and ongoing upkeep of directories.

Competitions: including administering prize draws and
competitions.Characteristics: protected classifications under California or
federal law, including gender and age.

Directly from you: as part of the account information you provide when you sign
up to our services.

Inferred by us: from data we hold about you.

Advertising: short term use of personal information for the customisation of ads
to make the advertising on our sites more relevant.

Quality Assurance: including maintaining the quality of our products and
services.

Competitions: including administering prize draws and competitions.

Commercial information: including purchase history and transactions; financial
details and payment information.Directly from you: as part of the account
information you provide when you sign up to our services.

Providing Services: including fulfilment of orders; providing customer services;
verifying customer information; accounting purposes and conducting audits.
Security: including detecting security incidents and debugging.
Quality Assurance: including internal research for technological development and
maintaining the quality of our products and services.
Legal: including monitoring compliance with our policies and terms.

Not applicable.Professional or employment related information: including job
title; industry; company.

Directly from you: as part of the account information you provide when you sign
up to our services.
Information we obtain: including information from partners, service providers or
public sources.

Advertising: short term use of personal information for the customisation of ads
to make the advertising on our sites more relevant.
Quality Assurance: including maintaining the quality of our products and
services.

Operational Purposes: other operational purposes, such as recruitment.

Directories: including the building and ongoing upkeep of directories.

Internet/other electronic network activity: online identifiers including device
and IP address; geolocation and online behaviour including interest data,
interactions with advertisements and records of the actions you take on some of
our sites.Indirectly from you: for example through cookies or similar technology
when you are using our websites.

Advertising: short term use of personal information for the customisation of ads
to make the advertising on our sites more relevant.

Quality Assurance: including maintaining the quality of our products and
services.Advertising: allowing third parties who advertise with us to measure
the effectiveness of their ads.Audiovisual: audio, electronic, visual and
similar information (such as images, videos or call recordings).Directly from
you: when you enquire about our products or services, or contact us about your
account.

Providing Services: including providing customer services; verifying customer
information; maintaining accounts and auditing interactions with consumers.

Quality Assurance: including internal research for technological development and
maintaining the quality of our products and services.Not applicable.Inferences:
drawn from any of the personal information listed above to create a profile or
summary about you (for example, an individual’s preferences or
characteristics).Inferred by us: from data we hold about you.

Advertising: short term use of personal information for the customisation of ads
to make the advertising on our sites more relevant.

Quality Assurance: including maintaining the quality of our products and
services.Marketing: including sales and promoting products and services.


Service Providers
As described in our Privacy Policy above, we share your personal information
with third parties for business purposes. Commonly, these include service
providers who help to support our business operations and improve our products.

We also use service providers to serve you with advertisements that we believe
are relevant to you. These third parties are permitted to process your personal
information only for the purposes of providing services to the FT; this may
include the use of their own cookies or similar technologies to collect your
personal information (IP address or other unique identifier) as part of
providing their services to FT.

Do Not Sell My Personal Information
Our Advertising
If you are a California resident, the CCPA also provides you with a right to
opt-out of the sale of your personal information. The definition of sale is
extremely broad under the CCPA, and may include sharing certain pieces of
information with our advertising partners, such as cookie identifiers,
geolocation and interactions with advertisements, for the purposes of showing
you advertising that is relevant to your interests.

You can choose to block sharing of this data with advertisers. This means that
we turn off some types of advertising based on information you have given us and
your use of our Sites, ensuring that our advertising partners do not receive
this data. By opting out, you will stop receiving adverts that are targeted
specifically to you; however, you will still see the same number of adverts on
our Sites.

You can opt out using the ‘Do Not Sell My Info’ link located in the footer of
the website you are using, if that website shows the types of advertising
described above. Alternatively, you can request this by emailing ccpa.mm@ft.com.

MandateWire
MandateWire is a news service and database that provides money managers with
rapid, reliable and high-value intelligence on institutional asset flows in
Europe, North & Central America, APAC and India, The Middle East & Africa. As
part of our service, we offer a database of individuals who work for
institutional investors/consultants and are involved in the investment process.

If your contact details have been included in the database, you will have
received an email from us containing instructions on how to opt-out, which you
can do by emailing support@mandatewire.com or by calling +1 212 542-1245.

More Information
For more information on how we use your personal information and who we share
your personal information with, please see our Privacy Policy above or contact
ccpa.mm@ft.com.



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