Reorg Privacy Policy

Effective Date: February 29, 2020

Reorg Research, Inc., Reorg Research Limited, and Reorg (Hong Kong) Limited (collectively, “Reorg, “We”, or “Us”) respect the privacy rights of our users and are committed to protecting your privacy and complying with all data protection regulations, including the General Data Protection Regulation (EU) 2016/679) and any national legislation implementing this Regulation and related statutory instruments as amended or in force from time to time (including the Data Protection Act 2018) (“GDPR”) and the applicable U.S. federal and state privacy laws. This Privacy Policy applies to www.reorg.com, dai1media.com, and any Reorg application (the “Sites”), your interactions with the news, media, data, reports, analyses, information, opinion and other subscription services offered by Reorg (the “Services”), emails you receive in connection with the Services, and any information collected from you by us on the Sites or via the Services. We take your privacy seriously and ask that you read this Privacy Notice carefully as it contains important information about your rights.

Contact Information

Please contact us with any questions, comments or requests regarding this Privacy Policy using the information below:

Contact: Legal Department

Address:
11 E 26th St, 12th Floor
New York, NY 10010

Email: privacy@reorg.com

Contact Our European Representative

If you are based in Europe please contact our European representative using the information below:

Contact: Reorg Research Limited

Address:
20 St Andrew Street, 5th Floor
London, EC4A 3AG

Email: privacy@reorg.com

What personally identifiable information (“PII”) does Reorg collect about you?

We may collect and process the following information about you:

  • Identifiers, such as name, email address, telephone number, and IP address;
  • Professional or employment-related information, such as employer and job title; and
  • Internet or other electronic network activity information, such as details of your visits to, and actions you may take, on the Sites or via the Services, including but not limited to traffic data, location data, logs of web usage and the resources that you access.

We may also collect the IP address of any person to whom you forward an electronic communication from Reorg that such person opens.

Why does Reorg collect PII and how long do we keep it for?

We collect the above PII for the following purposes:

  • to carry out our obligations arising from any contracts entered into between you or your employer and us, for at least as long as such contract is effective;
  • to allow you to access the Sites and use the Services, for at least as long as you have access to the Sites;
  • to contact you regarding the Sites, the Services, events, and other issues that may be of interest to you for as long as you show an interest in them;
  • to operate, administer and maintain the Sites and the Services;
  • to analyze use of and improve the Sites and the Services, including through the use of automated evaluation tools that analyze the nature and frequencies of usage and interaction with the Sites and the Services by visitors;
  • to evaluate a potential employment or contractor relationship with you (if you apply for a job with Reorg); and
  • to respond to your inquiries.

Where permitted by law, we may combine PII collected through the Sites and the Services with Reorg’s offline records and information provided to us by third parties. We use this consolidated information for the purposes described above.

How do we share PII that is collected through the Sites and the Services?

Reorg does not offer, sell or otherwise provide your PII to third parties for the purpose of allowing such third parties to market to you and in no event does Reorg sell your PII. We may share your PII with vendors who help us provide the Sites and the Services, including those that help us communicate with our subscribers and website visitors and those that provide us with technical and administrative services. If you would like more information about these providers, please contact us using the details above. We may share your PII with other entities in our corporate family in connection with the above purposes, with your employer, in the event that we undertake a sale or similar transfer of our business, if we are legally compelled to do so, or for other legal purposes.

Security of PII

Any PII you provide to Reorg is kept on secure servers, and Reorg uses reasonable technical and organizational measures to ensure the integrity of PII and guard against loss, theft, unauthorized use, disclosure or modification. To help us protect your privacy, you should maintain the secrecy of the password that you set up in connection with your usage of the Sites and the Services.

We strive to implement appropriate technical and organizational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access and any other unlawful forms of processing.  We employ measures so that the level of security adopted to protect your personal data is appropriate for the risks presented by the nature and use of your personal data. We follow recognized industry practices for protecting our IT environment and physical facilities.

Storage of PII

Your PII may be transferred to, and processed in, various countries around the world that may have different levels of privacy protection than your country. By using the Sites and the Services, you consent to such transfers and processing, including to and in the United States. With respect to PII collected by Reorg affiliates outside the United States, transfers to Reorg’s affiliates in the United States are governed by Reorg’s Internal Contractual Clauses, which are based on the Standard Contractual Clause and can be obtained by emailing privacy@reorg.com.

Use of Cookies

This Sites may place cookies on your device to keep track of your browsing session and to store your authentication information between sessions.

We use cookies to deliver a better and more tailored user experience. Without these cookies, you will not stay logged in to your Reorg account when your browser session ends. Your web browser allows you to control and limit cookies on your computer, although that may prevent you from accessing the Sites or otherwise affect Site and Service functionality. Websites must get consent to send cookies to your computer or mobile device unless the cookies are strictly necessary to provide services to you.

The table below explains what cookies we use on our website, why we use them and whether they are essential or another type of cookie. We also state in the table whether a cookie is a “persistent” or “session” cookie. The difference is that:

  • Persistent cookies remain on your device between browsing sessions. They are activated each time you visit the website that created that particular cookie. For example, where a “persistent cookie” is used on a website to remember your log-in details, you will not need to enter those details each time you visit that website.
  • Session cookies allow website operators to link the actions of a user during a browser session. A browser session starts when you open the browser window and finishes when you close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookie Type Purpose

Browser Session

These are essential, persistent, first-party cookies that we use to authenticate your user access and allow you to remain logged in to the Sites. The Sites would not work as designed or be able to provide certain features and functionalities without these cookies. It may be possible to disable some or all of these cookies manually via your web browser but doing so could affect the functionality and usability of the Sites. These cookies are permanent and will be used throughout your interactions with the Sites unless you manually delete them from your device.

Analytics

These are non-essential, persistent, first-party cookies that we use to measure the performance of the Sites and our email communications, develop improvements to the Sites, and provide an improved user experience. These cookies are permanent and will be used throughout your interactions with the Sites unless you manually delete them from your device.

For more information about cookies, please visit www.allaboutcookies.org.

DO NOT TRACK: Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked.  This is different from blocking cookies as browsers with the “do not track” option selected may still accept cookies.  Right now, there is no industry standard for how companies should respond to “do not track” signals, although one may be adopted in the future.  We do not respond to “do not track” signals at this time. If we do so in the future, we will modify this Privacy Policy accordingly.  More information about “do not track” is available at www.allaboutdnt.com.

Sharing of Data and Communications

We may use your email address to contact you. We may use your registered name and email address to provide the Services to you and to provide you with announcements about Site functions or Services that you are registered to use, about Reorg events or about other significant developments that may concern your use of the Sites or the Services. You can choose not to receive these emails by using the ‘unsubscribe’ mechanism provided at the bottom of these emails. Usage information may also be provided to your employer (or the entity that subscribes to the Services you have access to if different than your employer).

GDPR

The following information is only applicable to you if you are located in the European Union or the United Kingdom or otherwise within the scope of GDPR.

How is processing your personal data lawful?

We are allowed to process your personal data for the following reasons and on the following legal bases:

Legitimate interests

We are permitted to process your personal data if it is based on our ‘legitimate interests’, i.e., we have good, sensible, practical reasons for processing your personal data which is in our interest. We have explained these reasons in the previous section “Why does Reorg collect PII and how long do we keep it for?”. We have considered the impact on your interests and rights and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. You can object to any of the processing that we carry out on the grounds of legitimate interests (see the section “Your Rights” below to find out how).

Consent

Where you have given us consent to do so, we will collect and use your personal data for specific purposes which are optional. You can withdraw your consent at any time.

Retention Periods

We retain your PII for an appropriate period based on the purposes of collection listed above.

Your Rights

As a data subject, you have the following rights under GDPR:

  • Right to object to processing of your personal data;
    • You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing.
  • Right of access to personal data relating to you;
    • You may ask to see what personal data we hold about you and be provided with:
      • a copy of the personal data;
      • details of the purpose for which the personal data is being or is to be processed;
      • details of the recipients or classes of recipients to whom the personal data is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers;
      • the period for which the personal data is held (or the criteria we use to determine how long it is held);
      • any information available about the source of that data; and
      • whether we carry out any automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision or profiling.
    • To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.
  • Right to correct any mistakes in your information;
    • You can require us to correct any mistakes in your information which we hold. If you would like to do this, please let us know what information is incorrect and what it should be replaced with.
  • Right to prevent your personal data being processed;
    • You may request that we stop processing your personal data temporarily if:
      • you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;
      • the processing is unlawful but you do not want us to erase your data;
      • we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
      • you have objected to processing because you believe that your interests should override our legitimate interests.
  • Right to withdraw your consent;
    • You have the right to withdraw consent you have given us at any point. This is a vital and necessary aspect of consent. To withdraw your consent, you can contact us at the details at the end of this Privacy Policy.
  • Right to have your personal data ported to another controller; and
    • You may ask for an electronic copy of your personal data which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.
  • Right to erasure.
    • You can ask us to erase your personal data where:
      • you do not believe that we need your data in order to process it for the purposes set out in this Privacy Policy;
      • if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;
      • you object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or
      • your data has been processed unlawfully or has not been erased when it should have been.
  • Right to not be subject to a decision when it is based on automated processing or profiling.
    • You may ask for an explanation of our automated processing and request human intervention when such processing has a significant legal effect or similar on you.

Data Transfers

Any transfer of your data outside the United Kingdom and the European Economic Area will be carried out in accordance with GDPR and applicable law to safeguard your privacy rights and give you remedies in the unlikely event of a security breach or to any other similar approved mechanisms.

What will happen if your rights are breached?

You may be entitled to compensation for damage caused by contravention of GDPR.

Complaints to the Regulator

It is important that you ensure you have read this Privacy Policy. If you do not think that we have processed your data in accordance with this notice, you should let us know as soon as possible. You may also complain to the ICO. Information about how to do this is available on its website at www.ico.org.uk.

CALIFORNIA RESIDENTS

California residents have certain specific rights with respect to a business’s use and disclosure of their PII:

  • Right of Access | Right to Notice. You have the right to request that a business disclose to you the categories of PII the business has collected about you, the categories of sources from which the PII is collected, the business purpose or commercial purpose for collecting or selling PII, the categories of third parties with whom the business shares your PII, the categories of PII sold about you or disclosed about you for a business purpose, and the specific pieces of PII the business has collected about you in the preceding 12 months.
  • Right to Deletion.  You have the right to request that a business delete the PII it collects from you.  However, in certain situations the business is not required to delete your PII, such as when the information is necessary in order to complete the transaction for which the PII was collected.
  • Right to Opt-Out of the Sale of PII.  If a business sells your PII to third parties, you have the right, at any time, to direct the business not to sell your PII.
  • Right Not to Be Subject to Discrimination.  A business shall not discriminate against a consumer because the consumer exercised any of the consumer’s California rights described above.

Reorg collects, maintains, and discloses PII on behalf of the businesses we service and only for the specific purpose of performing the services for such businesses.  As a result, you should submit any request to exercise the rights above directly to the business on whose behalf Reorg processes your PII.

Changes to Privacy Policy

We may amend this Privacy Policy from time to time. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Sites and/or Services or by sending you an email.

Thank you for signing up
for Reorg on the Record!