Privacy Policy

Privacy Policy

Castlereagh Associates Consultancy Limited (“Castlereagh”), publisher of the information service accessed at or through www.castlereagh.net or its related or subsidiary websites or mobile applications, or provided to you by email or other electronic means (collectively, the “Service”), is committed to maintaining the privacy of information that you provide to us when using the Service. This Privacy Policy describes how we treat information we receive or obtain about you when you visit www.castlereagh.net or its related or subsidiary websites or mobile applications, that are part of the Service, otherwise use the Service, or otherwise interact with Castlereagh. As you read this Privacy Policy, keep in mind that Castlereagh maintains equivalent privacy practices with respect to data that is collected off-line.

Castlereagh complies with the European General Data Protection Regulation 2016/679 regarding the collection, use, and retention of personal information, including human resources (HR) data.

We may make content or services from other websites, including our affiliated or co-branded websites, available to you from links located on the Service. These other websites are not subject to this Privacy Policy. We recommend that you review the privacy policy at each such website to determine how that site protects your privacy. Castlereagh has no control over these websites and is not responsible or liable for the policies and practices followed by these other websites. The personal data you choose to provide to – or that is collected by – these other websites is not covered by this Privacy Policy.

You can request that we mail you a paper copy of this Privacy Policy by contacting contact@castlereagh.net.

Information We Collect About You

General: When you subscribe to or otherwise use the Service, sign up to receive emails from us, and at other times, we may ask you to provide us with certain categories of personal information. Personal information is information that could reasonably be used to identify you personally, such as your name, date of birth, age, gender, occupation, industry, interests, e-mail address(es), physical address, telephone number(s), profession, facts about your computers and other devices through which you access the Service, any information we receive from the applicable third parties when you register or otherwise interact with the Service by means of social media, and similar information (collectively, to the extent we collect it from time to time, “Personal Information”). We may collect this information through various forms and in various places, including account registration forms, contact us forms, or when you otherwise interact with us.

Surveys: We may conduct occasional online surveys. We collect information about your participation in and responses to these surveys (“Survey Information”). For example, when you’re within our websites, you may see a pop-up window offering you the optional opportunity of participating in a survey. These surveys are entirely voluntary and you may decline to participate.

Usage Information: We automatically collect IP addresses, website usage information and other technical information regarding your interaction with the Service from you when you visit our websites (“Usage Information”). This information helps us evaluate how our visitors and subscribers use and navigate our websites on an aggregate basis, including the number and frequency of visitors and subscribers to each web page, the length of their visits, the web browser version they use, and any publications or other information that they download.

Community Forums: Our Service may include community or user forums, or similar features (each a “Forum”) that are designed to be visible to other users and participants, including your screen name or other identifying information, as well as comments or other information that you may post on a Forum. By using any Forum, you agree to abide by the terms and conditions we have posted for such Forum, and you consent to the disclosure of your screen name (if a screen name is permitted or used in the applicable Forum, or if not, your actual name), identifying information and comments or other information that you may post on the Forum. We are not responsible for any Personal Information that you may choose to post in any Forum.

Conferences and Other Events: We may invite you to, or you may otherwise participate in, video or telephonic conferences, webinars, or other live or recorded events that we offer. We may share any information you provide when signing up for any such event with other sponsors of the event.

Testimonials: We display personal testimonials of satisfied subscribers on our websites from time to time. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us at contact@castlereagh.net.

Technical Information: We also collect certain technical information, as described below under the heading “Additional Technical Information We May Collect.”

How We Use the Information Collected

Our primary goal in collecting your Personal information, Survey Information and Usage Information is to provide you with an enhanced experience when using the Service. We may use information about you, including Personal Information, Survey Information and Usage Information, in the following ways:

We may use information about you for the purposes for which you specifically provided the information including, for example: to enable us to process, validate and verify subscriptions; to send you e-mail notifications about our new or existing products and services, special offers, or to otherwise contact you; to send you e-mail notifications, through companies who work on behalf of Castlereagh, about certain approved third-party products and services (unless we tell you differently, these companies do not have any right to use the Personal Information we provide to them beyond what is necessary to assist us); to enhance existing features or develop new features, products and services; to provide advertisers and other third parties with aggregate information about our user base and usage patterns; to allow us to personalize the content and advertising that you and others see based on personal characteristics or preferences.

We may combine the information that we collect from you with information that you provide to us in connection with our other products, services and websites, including marketing those products, services and sites to you.

Castlereagh uses web analytics services (which may include, but are not limited to, Google Analytics) to analyze how users use our websites. These services may use javascript, cookies or other tools that include cookies that we place on your computer or mobile device. We and our service providers use these tools to collect information about your usage of our websites, such as your IP address, the name of your internet service provider, your operating system and other computer or mobile device information and statistics, the URL for the web pages you visit and how long you spent on those pages, how you arrived at our pages, and the date and time you visited. The information generated about website usage may be transmitted to Google or other service providers and used for a variety of purposes, including, without limitation, to improve our websites, prevent fraud, evaluate users’ use of our websites, complete statistical reports on website and user activity, provide other related services, and enable, improve and support our marketing programs. This information may be stored on servers located in the United Kindom, United States or elsewhere. For more information about Google Analytics or the Google Analytics opt-out browser add-on, go to https://tools.google.com/dlpage/gaoptout.

You are responsible for maintaining the accuracy of the information you submit to us, such as your user preferences and contact information provided as part of subscription registration. If your Personal Information changes, or if you no longer desire our Service, you may correct, delete inaccuracies, or amend information by making the change in your profile on-line, or by contacting us by email at contact@castlereagh.net. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.

We will retain your Personal Information, Survey Information and Usage Information for as long as your account with the Service is active and as needed to provide you the Service. Even after your account is terminated, we will retain your Personal Information, Survey Information and Usage Information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons as we deem appropriate.

At times Castlereagh may use third party network advertisers to deliver ads to you on our behalf. We may also use third-party service providers to contact you on our behalf, or facilitate some aspects of the Service or fulfill your purchase requests. These network advertisers and service providers may be supplied with or have access to your Personal Information solely for the purpose of providing these services to us or on our behalf, to the extent permitted by applicable law.

We may disclose and use Personal Information, Survey Information and Usage Information at our discretion without notice, unless such disclosure is prohibited by law. We may disclose and use Personal Information in special circumstances where it is necessary to enforce our contracts or our Terms of Use (for example, when necessary to protect our intellectual property rights).

We may also disclose or use your Personal Information when we believe that the law requires us to do so. For example, we may be obliged to release your Personal Information pursuant to judicial or other government subpoenas, warrants, or other orders. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your Personal Information including disclosure to third parties such as government or law enforcement officials or private parties, as we reasonably determine is necessary and appropriate: to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process; to protect the safety, rights, property or security of Castlereagh, the Service, or any third party; to detect, prevent or otherwise address fraud, security or technical issues; and to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Further, we may use IP addresses or other unique identifiers for computers, tablets, smartphones or other devices used to access the Service, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion.

We contract with other companies to provide services on our behalf, including ad serving, email distribution, list processing and analytics or promotions management. We provide these companies only with the information they need to perform their services. These service providers are restricted from using your Personal Information in any way other than to provide services for us, except for certain anonymized, aggregated statistical data.

We may share your information, including your Personal Information, Survey Information and Usage Information, with our subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information to a subsequent owner, co-owner or operator of the Service, or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including during the course of any due diligence process.

Any and all of the foregoing disclosures may be carried out without notice to you.

Castlereagh’s Commitments under EU General Data Protection Regulations (GDPR)

Castlereagh is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Castlereagh also commits to cooperate with European Union (EU) data protection authorities (DPAs) with regard to customer data and human resources data transferred from the EU.

Castlereagh is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent permitted by applicable law, Castlereagh commits to inform its subscribers in the event of an information request regarding their Personal Information.

In the context of an onward transfer, Castlereagh has responsibility for the processing of Personal Information it receives under GDPR and subsequently transfers to a third party acting as an agent on its behalf. Castlereagh remains liable under the GDPR Principles if its agent processes such personal information in a manner inconsistent with the Principles.

Castlereagh complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the EU GDPR Principles shall govern.

Additional Technical Information We May Collect

Device Information: We may collect non-personal information about the computer, mobile device or other device you use to access the Service, such as IP address, geo-location information, unique device identifiers, browser type, browser language and other transactional information.

Analytics, Log Files and Reading History: We may gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), browser type, operating system and other usage information about the use of the Service, including a history of the pages you view.

Cookies: We may employ cookies or other technology to help visitors and subscribers move faster through our site and for the other purposes described above. When you sign on to our websites or take advantage of several key features, we may pass cookies to your computer. A cookie is a string of information that is sent by a website and stored on your hard drive or temporarily in your computer’s memory (read our Cookie Disclosure Statement for more information on our use of cookies).

Security: The Personal Information we collect about you is stored in limited access servers. We will maintain commercially reasonable safeguards to protect the security of these servers and your Personal Information. However, no security technology or system is impenetrable. We cannot guarantee the security of our systems or databases, nor can we guarantee that your information will not be intercepted while being transmitted to us over the Internet or wireless communication.

Other Information: We (directly, or through third parties that support our distribution of emails and related matters) use a variety of technical means, which may include, but are not limited to, pixels, cookies or transparent GIF files, to help manage online advertising. These files may be provided by one or more of our advertising management partners. These files enable Castlereagh and those partners to recognize a unique cookie or other script associated with or on your web browser, which in turn enables us to learn which advertisements bring users to our websites. The information that we collect and share through such means is anonymous and not personally identifiable. It does not contain your name, address, telephone number or email address.

Policy Modifications

We may change this Privacy Policy from time to time. We will post any changes here and revise the “last updated” date accordingly, so be sure to check back periodically. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of Personal Information you have provided to us, we will attempt to obtain your consent before implementing the change. Except as stated in the preceding sentence, any changes will be effective when we post them here, and your use of the Service after we post any changes means you consent to those changes.

Choice/Opt-Out

Castlereagh provides its users the opportunity to opt-out of receiving communications from Castlereagh and its partners. To remove your information from our database, to not receive future communications or to no longer receive our Service, please send an e-mail request to: contact@castlereagh.net.

Correcting/Updating Your Information

You can change or modify information you previously provided to us by sending an email to contact@castlereagh.net.

Comments and Questions

If you have any comments or questions about this Privacy Policy, Castlereagh’s practices, the Service, or your dealings with us, you can contact:

Castlereagh Associates Consultancy Limited
Suite 15.12, Millbank Tower
21-24 Millbank, London SW1P4QP UK

Or email us at contact@castlereagh.net.

Cookie-Disclosure Statement

We employ cookies at Castlereagh to, among other things, allow you to move quickly through the Service. Below you’ll find information describing Castlereagh’s most common uses of cookies, which are an inherent part of our production, communication and distribution processes and have enabled us to better serve our users.

What’s a cookie? A cookie is a small file that is sent to your computer by a site’s server. A cookie can be a record of your visit to our websites, including information such as your user name, registration information, time of last visit, pages viewed, etc. Cookies created by the servers of one site can be retrieved only by that site’s servers.

Castlereagh uses cookies for a variety of purposes, including, without limitation, to allow you to move quickly through the Service, and to evaluate users’ use of our websites, complete statistical reports on website and user activity, provide other related services, and enable, improve and support our marketing programs.

Castlereagh accomplishes this in many ways, using several different cookies. When you first enter one of our Websites or otherwise access the Service, for example, Castlereagh may use a test cookie to confirm your browser’s ability to retain cookies.

Other cookies that you might receive are from Castlereagh or our third-party service providers or third-party network advertisers. These network advertisers may use their own cookies in order to serve ads on our Websites, to reduce the likelihood that you see the same ads over and over again.

Some of the advantages of cookies include:

  • Faster more convenience access. We can deliver customized information an store your settings (such as preferences and account information) ore efficiently.
  • Better information. Castlereagh wants to provide features and services in which you are interested.  Through the use of cookies, Castlereagh can determine which features are most popular with subscribers on an aggregate basis, and thus better serve your needs by developing new features and services in response to Castlereagh’s analysis of usage of the System.
  • More efficient ad processing. Cookies enable us to streamline our ad presentations.

Will the cookies Castlereagh sends to your devices go away?

  • Some cookies are long term. Some cookies expire after a short period of time. Cookies are small files (just a few hundred bytes) and should not pose any significant disk-space concerns. You are, of course, free to clear cookies from your devices at any time.

Can you set your browsers to not accept cookies or to alert you each time you receive one?

  • Most browsers can be set to alert users each time a cookie is passed to the applicable device.

Last Updated: 7 June 2019
Castlereagh Associates Consultancy Limited

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