This statement was last updated on 5th March 2018.
This Privacy Statement explains what information we gather about you, what we use that information for, and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.
NYA is strongly committed to protecting your personal information. This Privacy statement describes how NYA handles personal information collected through the sites on www.nyarisk.com that link to this Privacy Statement (collectively, “the Websites”).
By using the Websites and providing personal information to us, you acknowledge you have read this Privacy Statement, and, to the extent your consent is necessary and valid under applicable law, you consent to the collection, use and disclosure of such personal information by NYA and any third party recipients in accordance with this Privacy Statement.
As used in this Privacy Statement and the Websites, NYA, us, and we refer to the NYA network and/or one or more of its offices that may process your personal information. The data controllers of the Websites are one or more of the offices listed here. Each office is a separate legal entity. For further details, please see http://nyariskprod.wpengine.com/contact/ for a list of countries in which NYA has offices.
Third party links
Collection of personal information
When you use our Websites, we may collect information about you and your use of the relevant site, including through cookies and analytics tools. We may collect personally identifiable information about you, such as your name, job title, company name, address, email address, telephone number, and fax number, either directly from you or by combining information we collect via the Websites with personal information we collect and maintain through other means (such as client relationship management systems or identification and access management systems, including IP addresses) or as we may receive from social media or other third-party sites.Below are some examples of how you may provide personal information to NYA:
- searching and browsing for content
- subscribing to or ordering newsletters and/or publications
- registering for premium online services
- participating in “join our mailing list” initiatives
- participating in bulletin boards, discussion or message forums
- entering Surveys, eLearning courses or Feedback Surveys
- registering for events and conferences
- submitting resumes or work history information
- contacting us for further information
- visiting our Websites while logged into a Social Media platform
- providing us with business cards or other contact information
We do not intend to collect sensitive information through the Websites unless we are legally required to do so. Examples of sensitive information include race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records. We ask that you do not provide sensitive information of this nature when using the Websites.
If you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local law, for us to collect and use that information in the ways described in this Privacy Statement or as described at the point where you choose to disclose this information.
We also do not actively seek demographic information from visitors to the Websites. However, you may choose to provide such information (including for example when becoming a Registered User, visiting our site from a social media site, submitting a resume, or responding to an online job application). If you choose to provide demographic information to us, the act of doing so constitutes your explicit consent, where such consent is necessary and valid applicable law, for us to collect and use that information in the ways described in this Privacy statement or as described at the point where you choose to disclose this information.
It is our policy to collect only minimum information required to complete your request. If the Websites seek non-mandatory personal information about you, you will be notified of this at the point of collection. If you believe a Website has collected excessive information about you, please contact us to raise any concerns.Some pages on the Websites may permit you to send emails to us. Messages sent via the Websites will contain your screen name and email address, as well as any additional information you may wish to include in the message.
If you choose to become a Registered User, as part of the registration process you will be asked to provide us with personal information through a registration form. Information we collect may include: your name, email address, password, country, organisation, and job title. Some of the information is required and, if you do not provide it, you will not be able to register and receive the benefits of being a Registered User (for example, obtaining access to premium content). We have marked with an * those registration fields seeking information that you must provide in order to become a Registered User.
For as long as you are a Registered User, you are responsible for providing us with accurate information about you and for keeping that information up to date. You may update your information by editing your user profile in your Account.Once you are a Registered User, we may combine the information you give us as part of the registration process with information we collect and/or have previously collected through your use of the Websites (such as articles you read, comments you make).
As a Registered User, all of the data you provide as part of registration may be tied back to the information we collect or have previously collected about you through your use of the Websites.We may also match the information you provide us against third-party data to supplement your user profile. For example, if a third party has additional information related to your email address (such as a social media profile URL or a photo), we may match your email address and activity on the Websites (including activity information collected prior to your becoming a Registered User) against that data and then use the third party data for additional marketing activities.
Use of personal information
When you provide personal information to us, we may use it for any of the purposes described in this Privacy Statement or as stated at the point of collection (or as obvious from the context of collection), including:
- to administer and manage the Websites, including to confirm and authenticate your identity and prevent unauthorised access to restricted areas of the site, premium content, or other services limited to Registered Users
- to personalise and enrich your browsing experience by displaying content that is more likely to be relevant and of interest to you
- to sort and analyse user data (such as determining how many users from the same organisation have subscribed to or are using the Websites)
- to determine the company, organisation, institution, or agency that you work for or with which you are otherwise associated
- to develop our businesses and services
- to conduct benchmarking and data analysis including, for example, regarding usage of the Websites and demographics analyses of their users
- to conduct quality and risk management reviews
- to understand how people use the features and functions of our Websites in order to improve the user experience
- to monitor and enforce compliance with our Terms, including acceptable use policies
- any other purposes for which you provided the information to NYA, including any of the purposes given in the ‘Collection of personal information’ section above
Our Websites do not collect or compile personally identifying information for sale to non-NYA parties for consumer marketing purposes.
If you would like to find out more about the different categories of information we collect on the Websites, please review the ‘Collection of personal information’ section.
If you choose to become a Registered User, we may also use your information for the following purposes:
- to tailor the content within our Websites and across NYA digital properties, including content shown to you, to your preferences and interests;
- to manage our relationship with you or the organisation for which you work (for example, by including personal data we collect about you from your use of the Websites in our customer relationship management systems);
- to provide you with information about us and our services including via personalised marketing messages and/or communications unique to your organisation about our products and services;
- to invite you to attend events, participate in forums, etc.;
- to conduct quality and risk management reviews;
- any other purposes for which you provided the information to NYA
Legal grounds for processing personal information
Your local law may require us to set out in this Privacy Statement the legal grounds on which we rely in order to process your personal information. In such cases, we rely on one or more of the following processing conditions:
- our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (provided these do not interfere with your rights)
- to satisfy any legal and regulatory obligations to which we are subject
- to perform legal obligations
- where no other condition for processing is available, if you have agreed to us processing your personal information for the relevant purpose
Security of personal information
We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorised persons are provided access to personally identifiable information collected via the Websites; such individuals have agreed to maintain the confidentiality of this information.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by email) is never completely secure.
We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.
Cookies and Beacons
Transfers of personal information
As NYA is a global company with offices around the world, your personal information may be transferred to and stored outside the country where you are located. This includes countries outside the European Economic Area (EEA) and countries that do not have laws that provide specific protection for personal information. Where we collect your personal information within the EEA, transfer outside the EEA will be only:
- to a recipient located in a country which provides an adequate level of protection for your personal information
- under an agreement which satisfies EU requirements for the transfer of personal data to data processors or data controllers outside the EEA, such as standard contractual clauses approved by the European Commission
The US entity of NYA, NYA International Limited (“NYA US”), adheres to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information that is transferred from the European Union and its Member States, and the EEA and Switzerland to the United States. NYA US has certified that it adheres to the Privacy Shield Principles within the scope of NYA US’s Privacy Shield certification.
Third party providers
We may transfer or disclose the personal data we collect to NYA offices and to their third party contractors, subcontractors, and/or their subsidiaries and affiliates. When we transfer personal data, we do so for the purposes for which the information has been submitted, for the purposes listed above under Use of Personal Information, for the administration and maintenance of the Websites and associated systems, and/or other internal or administrative purposes. We also may transfer personal data to third party service providers of identity management, website hosting and management, data analysis, data backup, security and storage services.The third party providers may use their own third party subcontractors that have access to personal data (sub-processors). It is our policy to use only third party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by NYA, and to flow those same obligations down to their sub-processors.
We may also disclose personal information to third parties under the following circumstances:
- when explicitly requested by you
- when required to deliver publications or reference materials as requested by you
- when required to facilitate conferences or events hosted by a third party
- for regulatory compliance purposes
We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation. This includes disclosures outside the country where you are located. NYA may also review and use your personal information to determine whether disclosure is required or permitted.
Retention of personal information
We will retain your personal information on our systems only for as long as we need it, given the purposes for which it was collected, or as required to do so by law. We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honour your request. We dispose of resumes when they are no longer under consideration.
Where we are legally required to obtain your explicit consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.If you opt into any subscriptions, you will receive automated emails when content is updated. If you opt into any newsletters, you will receive curated emails known as newsletters. If you select any preferences such as issues, topics, subjects or industries, you may receive email communications related to those self-selected topics.If you become a Registered User, we may also contact you with email and marketing communications about subjects that we believe may be of interest to you. We may send emails and marketing communications on our own or in conjunction with another organisation with which we have entered into a collaboration arrangement.
If you want to unsubscribe from mailing lists or any registrations, you should look for and follow the instructions we have provided within the appropriate area(s) of the Websites or in the relevant communications to you.If you do not wish to receive emails or marketing communications from us, you can at any time contact us to request that such communications cease. If you wish to unsubscribe or no longer receive only certain communications, please identify such communications in your request.
If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honour your request.
If you are a Registered User, you may deactivate your account at any time via the Registered User section of the Websites. If you deactivate your account on the Websites, you will no longer receive the benefits of being a Registered User. If you choose to deactivate your account, we may retain information sufficient to identify you so that we can honour your request.If you have other registrations with NYA, or have provided your information to NYA through other means (such as subscribing to newsletters), those registrations will be maintained unless you to take specific action to inform us to cease contacting you.Any user generated content that you may have created before then will not be anonymised following deactivation, nor will it be immediately removed from our systems or records.
Access to data
We are committed to providing reasonable and practical access that allows visitors to the Websites to identify and correct any inaccuracies in the information we collect about them.
When we keep personally identifiable information about you, we are responsible for keeping an accurate record of the information that you have submitted to us and verified. We do not assume responsibility for verifying the ongoing accuracy of your personal information. If you are a Registered User, you may update your personal information; to do so, log in using your account credentials and update your information.If you have questions about the accuracy of identifying information you previously submitted to NYA, or want to have outdated information removed, please contact us. When requested, and provided that it is practical and commercially feasible to comply with the request and there is no legal or regulatory need for us to keep the information, we will delete identifying information from current operational systems.
Rights in relation to your information
You may have certain rights under your local law in relation to the personal information we hold about you. In particular, you may have a right to:
- request a copy of personal information we hold about you
- ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
- ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
- object to our processing of your personal information
- withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing)
If you would like to exercise these rights or understand if these rights apply to you, please contact us by sending an email or by one of the means set out at the end of this Privacy statement. We may charge for a request to access your information, if permitted by applicable law.
We understand the importance of protecting children’s privacy, especially in an online environment. The Websites covered by this Privacy Statement are not intentionally designed for or directed at children, and the Terms and Conditions of use require all users to be above the age of majority in their local country. We adhere to laws regarding marketing to children.
If you have any questions or complaints about this Privacy statement or the way your personal information is processed on the Websites, or would like to exercise one of your rights set out above, please contact us by one of the following means:
Post: NYA, 40 Lime Street, London, EC3M 7AW, United Kingdom
You may also have the right to lodge a complaint with your local data protection regulator.
This statement was last modified in February 2018. We may update this Privacy Statement at any time by publishing an updated version here. So you know when we make changes to this Privacy Statement, we will amend the revision date at the top of this page. The new modified or amended Privacy Statement will apply from that revision date. Therefore, we encourage you to review this Privacy Statement periodically to be informed about how we are protecting your information.