Privacy Policy

At CTFN, we take your privacy seriously. This Privacy Policy explains what personal information we collect and how we use it.

Introduction

Welcome to CTFN, LLC's Privacy Policy. CTFN, LLC respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you on how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the Policy here. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. Disclosures of your personal data
5. International transfers
6. Data security
7. Data retention
8. Your legal rights
9. Glossary
10. Cookie Policy

Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how CTFN, LLC collects and processes your personal data through your use of the ctfn.news website and its subdomains (collectively the Site), including any data you may provide through the Site when you complete the trial form in our homepage to request your CTFN account to be activated, when you sign in to your CTFN account, when you request a subscription to our services, when you subscribe to our email alerts, when you contact us by email or telephone, or when you purchase one of our services. This Site is not intended for children under 16 years of age. No one under age 16 may provide any information to or on this Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or on or through any of its features/complete the trial form in our homepage to request a CTFN account, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@ctfn.news or by phone at +44 203 514 5314. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller

CTFN, LLC is the controller and responsible for your personal data (collectively referred to as "CTFN," "we," "us," or "our" in this Privacy Policy. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:
CTFN, LLC
Name and title: Jonathan Spitzer, Data Privacy Manager
Email address: privacy@ctfn.news
Postal address: 55 Post Road West, 2nd floor, Westport, CT 06880
Telephone number: +44 203 514 5314 or +1 203 635 6555
If you are based in the European Union, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on May 24, 2018, and historic versions can be obtained by contacting us. If you are based in the European Union, please note that the data protection law in the EU will change on 25 May 2018. Although this Privacy Policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes. We reserve the right to change the terms of this Privacy Policy at any time. We will notify you of any material changes by way of a pop-up notice on the Site announcing that the Privacy Policy has changed. 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.

Third-party links

This Site may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, 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). We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title.
• Contact Data includes billing address, delivery address, email address, and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our Site, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
  • complete the trial form to request a CFTN account on our Site;
  • sign in to your CTFN account;
  • request a subscription to our services;
  • subscribe to our email alerts;
  • request marketing to be sent to you;
  • give us feedback.
• Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google Analytics and Jetpack (Automatic Inc.), based outside the EU;
  • Identity and Contact Data from publicly available sources based inside and outside the EU.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We share your personal data within our company. This will involve transferring your data outside the European Economic Area (EEA). Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see EUROPEAN COMMISSION: ADEQUACY OF THE PROTECTION OF PERSONAL DATA IN NON-EU COUNTRIES.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see EUROPEAN COMMISSION: MODEL CONTRACTS FOR THE TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see EUROPEAN COMMISSION: EU-US PRIVACY SHIELD.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We will only retain your personal data for as long as necessary to fulfill 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 unauthorized 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. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us set out in the table in paragraph 4 above. In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymize 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 to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

• Service providers acting as processors based in Italy who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the United States who provide consultancy, banking, legal, insurance, and accounting services.
• Regulators and other government authorities acting as processors or joint controllers based in the United States or European Union who require reporting of processing activities in certain circumstances.

Cookie Policy

Information about our use of cookies

CTFN uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it.
• Functionality cookies. These are used to recognize you when you return to our website.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited, and the links you have followed.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.