The Conversation Media Group respects your privacy and is committed to protecting your personal data. This privacy notice explains what personal data we collect from you when you visit our website or use our services, what we do with it and how we keep it safe. It also explains your privacy rights and how the law protects you.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW PERSONAL DATA IS COLLECTED
- HOW WE USE PERSONAL DATA
- DISCLOSURES OF PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
The Conversation is a news website written by academics working with our team of professional editors to provide timely, expert insight into current affairs. The Conversation is a non-profit company and charity, funded by our member universities, other education and philanthropic funding bodies, and the generous donations of our supporters.
As a non-commercial organisation we do not carry advertisements on our website or in our newsletters. We do not create profiles of you, our readers, based on data about you that we gather from your use of our site. We do not employ other organisations to do this. We collect only the bare minimum data required to deliver our services to our readers, such as website content and newsletters. This privacy notice will explain what we collect, what we do with it, and your rights to access or control that data.
The Conversation Media Group is made up of six legal entities, which correspond to six editorial editions operating in Australia, UK, US, South Africa, France and Canada. We also have staff based in Kenya, New Zealand, and Indonesia. When this notice discusses “The Conversation”, “we,” or “us”, we are referring to The Conversation Media Group as overall data controller for the purposes of data protection and privacy. In all cases, queries, questions or complaints relating to your data and your privacy rights should be directed to firstname.lastname@example.org in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This privacy notice was last updated May 2018 and this version reflects changes to data protection law under the European Union General Data Protection Regulation (GDPR), which comes into force on May 25, 2018. This notice outlines your rights under the new laws. Historic versions of The Conversation’s privacy notices can be requested by emailing email@example.com
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, for example by updating your details if you have created a reader or author account on theconversation.com, or by updating the email address with which you have signed up for one of our newsletters.
We include links to third-party websites on theconversation.com. Clicking on those links may allow third parties to collect or share data about you, which they will do in accordance with their own privacy policies. We do not control these third-party websites and are not responsible for their privacy policies. We encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data 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). Because we don’t use advertising we don’t collect much information about readers visiting our website.
The information we collect depends on how you interact with our website and services.
Visitors: if you visit theconversation.com, our website will collect certain elements of technical data about the device you are using to browse our website, such as browser version, screen size and resolution. We do this to provide you with the best browsing experience, for example so that the website looks its best to readers whether you are using a small screen on a mobile phone or a large desktop monitor. Our web server will log your IP address as having accessed our content, whether you read it on theconversation.com or via another site that has republished our content. Our web site will identify your general geographic location (country) from your IP address, but this will be stored as aggregate data from which it is not possible to identify an individual’s location. We collect statistical data on those reading our website through Google Analytics, such as which articles are read, how long is spent on a page, and which links are clicked on. This is to establish the patterns of use of our site, to identify popular and unpopular content, and to provide a better service. This data is stored as aggregate statistical data, and is not information that can personally identify you.
Subscribers: if you subscribe to our newsletters, we use the email address you provide to send the newsletter(s) you have requested to that address. The Conversation uses Campaign Monitor to send its email newsletters, software provided by a company based in Australia. Our subscriber lists - containing your email address - are stored on Campaign Monitor’s servers based in the US. Campaign Monitor’s data protection and privacy policies conform to the GDPR and European Union law, and as a data processor for The Conversation the company is contractually obliged to process your data only as we direct and only in such a way that is compatible with data protection principles and your rights under the GDPR. When you sign up for a newsletter from The Conversation, you consent to your data being stored and used in this way. Neither The Conversation nor Campaign Monitor will ever use the data you have provided for reasons other than those for which you provided it, nor transfer it to other parties, except with your consent.
Readers: regular visitors to theconversation.com may wish to sign up for a reader account so that they can comment on articles and engage in discussion with our authors and other readers. We ask readers to provide their first and last names, email address, and, optionally, a job title or profession to provide some context to the comments they leave. If you post a comment under your reader account, your comment and your name will be published to the site. Otherwise, your personal data is not used for any other purpose, or transferred to any other party, without your consent.
Authors: our authors are academics from universities all over the world, but chiefly in the countries in which The Conversation operates. In order to write for The Conversation, authors agree to create, or allow us to create on their behalf, a short profile that provides some background to their research and expertise. Authors may edit their own profiles, and we ask that they strive to keep them up-to-date. If as an author you publish an article on The Conversation, your name, job title, and institution will be appended as the article’s byline, providing you with full credit for your work. The Conversation publishes articles under a Creative Commons licence which allows other organisations to republish our content. This means that, as an author, the personal details contained in your byline may be transferred to other parties that republish your articles in order to credit you for your work. We will not otherwise share authors’ details with third parties.
Donors: those who support The Conversation through donations provide their email address and financial details and, depending on jurisdiction and where legally obliged, address or postcode. We may contact donors by email in the future. We do not share these details with third parties, except where legally obliged to.
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, we cannot send you a newsletter without an email address). In this case, we may have to cancel a service we have agreed to provide. We will notify you if this is the case.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We collect data on you either through your direct interaction with the site, or programmatically through your actions, or from third parties.
Direct interactions: You may give us your name, email address, or other details by filling in forms, for example in order to subscribe to a newsletter or set up a reader account.
Third parties or publicly available sources: In order to create profiles for authors writing for The Conversation, we may use personal biographic data about the author from publicly available third party sources, for example from their university website profile or from other linked, public accounts such as ResearchGate, Academia.edu, or LinkedIn. This information is to show readers the experience and expertise of the author whose article they are reading, and to provide authors with a profile and ‘landing page’ for their written work for The Conversation. Authors may login to their account on theconversation.com and edit their profile as desired (subject to minimum necessary details as laid out in the terms and conditions). We do not use this information for any other purpose, nor transfer it to any other party.
Other sources of data sourced from third parties may include:
Technical Data, for example: (a) Google Analytics (Google is a company based outside the EU) (b) search information providers (such as Google Search, based outside the EU)
Contact, Financial and Transaction Data, from payment services providers, for example if you make a donation to The Conversation.
4. HOW WE USE YOUR PERSONAL DATA
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:
- In order to offer the services you have asked us to provide
- Where we need to comply with a legal or regulatory obligation
- Where necessary for our legitimate interests (or those of a third party), where those interests are not overridden by your interests and fundamental rights
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|User type||Personal data collected||Use||Lawful basis|
|Website visitors||IP address||For technical, security and legal purposes||(3)|
|Subscribers||Email address||To send newsletters||(1)|
|Readers||Name, email, occupation||For commenter profiles||(1)|
|Authors||Name, email, job title, institution, brief research profile, photograph||To provide author profiles||(1)|
|Donors||Name, address, financial data||To process donations and contact for future donations||(1, 2)|
MARKETING AND COMMUNICATIONS FROM US
We send newsletters to subscribers as they have requested. We may from time to time send other emails to subscribers, relating to content offered by The Conversation, to survey you for your thoughts about our site, to solicit your support through donations, or other notices. You may unsubscribe from receiving emails from The Conversation at any time using the prominent unsubscribe link at the bottom of every email we send. We will never sell your data, or share it with other organisations without your consent.
- set the edition of The Conversation you see by default when visiting our site (which can be changed from the switcher in the top left corner)
- save a user’s authentication state, to recognise whether they are logged in or not.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with third party companies that we use in order to deliver our services, for example Campaign Monitor which we use to send our newsletters. We do so only when it is appropriate, where we have a legal basis to do so, and where legally binding contracts are in place to ensure those third party companies can provide adequate protection of your data.
We may also have to share your personal data with third parties such as government agencies, law enforcement, or if compelled to do so in order to meet a legal obligation or requirement.
6. INTERNATIONAL TRANSFERS
Your personal data as stored and used by The Conversation Media Group and its constituent companies, may be accessible to all member companies of the group and may be transferred outside the European Union or European Economic Area. All the group companies follow the same rules and policies for storing and using personal data.
If we transfer your personal data out of the European Union or European Economic Area to a third party that is not a Conversation group company, we will ensure a similar degree of protection is afforded to it by ensuring that either the country we transfer to has been deemed to provide an adequate level of protection for personal data by the European Commission, or that we have contractual agreements with third parties using contracts approved by the European Commission which give personal data the same protection it has in Europe under the GDPR. For example, the EU-US Privacy Shield in the United States, or PIPED Act in Canada.
7. DATA SECURITY
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.
8. 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 unauthorised 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. You can request details of our retention periods for different elements of your personal data by contacting us at firstname.lastname@example.org
In some circumstances you can ask us to delete your data. 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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact email@example.com. No fee is usually required, however, we may charge a reasonable fee for, or refuse to comply with, your request if it is clearly unfounded, repetitive or excessive.
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.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Any questions, queries or requests should be directed to firstname.lastname@example.org