Privacy policy: The Financial Times (Overseas) Limited
The FT Locations portfolio, a powerhouse of foreign and domestic investment products and services, offers an unrivalled centre of excellence globally, providing news and analysis, data tools, events and strategic guidance for the industry. Central to this mission is our commitment to upholding the highest standards of data protection for our customers.
This Privacy Policy applies to all websites and web applications which link to this policy and are provided by The Financial Times (Overseas) Limited ("Sites").
If you wish to amend any of the personal information that we hold about you, or update your marketing preferences, you can do so at any time through your account.
If you have any queries about how we use your personal information, please contact our Data Protection Officer at ftprivacy.fto@ft.com.
Information we collect
This section details the information we may collect about you. We explain why, and how, we use it in later sections.
Account information
If you decide to create an account or enquire about one of our products or services, we'll ask you to provide us with some specific information, for example:
- Basic personal details - such as name and title;
- Contact details - such as address, phone number, and email address;
- Work details - such as job title, department, company name, and office phone number;
- Student or institution details, if you are signing up to a subscription through an educational establishment - such as student status, graduation year, establishment name;
- Log in details - such as username and password;
- Payment details - such as your bank account and payment card information.
Additional information
On occasion, we will ask you to voluntarily provide additional information, for example:
- Your opinion of our products and services;
- Your preferences, including newsletters;
- Information such as your dietary preferences and accessibility requirements when attending one of our events.
Information we obtain from partners and public sources
In some circumstances, we collect information about you from our partners or from publicly available sources to help us better understand our audience and enhance the relevance of our content and marketing.
We also obtain some information from publicly available sources for the purpose of inclusion in our directories; IncentivesFlow, InvestmentFlow, Influencers and fDi Markets. These are online databases, which track companies investing overseas and government incentives. As part of the research process, we identify publicly available details of key individuals who are linked to either project activities or listed as a company contact. If your contact details have been included in the database, you will have received an email containing instructions on how to opt-out, which you can do by calling +44 (0)20 7775 6667 or emailing ftprivacy.fto@ft.com.
Information we obtain through cookies and similar tools
We use cookies (and similar technologies) and analytics tools across our Sites to collect information about you. This information can be used to improve the performance of the site, make advertising more relevant and enhance your user experience; examples include:
- Your location - we use cookies to display the information that is most relevant to your location. For example, if you access our Sites from the US, you will be shown prices in US Dollars.
- Your usage - we use cookies to understand how our customers use our Sites, and interact with our communications and content. For example, we use technology on our Sites which records user movements, including page scrolling, clicks and text entered. (It does not record payment details.) This helps us to identify usability issues and improve the assistance we can provide to users and is also used for aggregated and statistical reporting purposes.
- Your device - we use cookies to understand what type of device you are using to show you the best version of the site.
- Your engagement with advertisements - we use cookies to understand what advertisements you have been shown, or clicked on, to bill our advertising partners, and to present you with advertisements that are more relevant to you.
Lawful basis for processing
We only process personal information where we have a lawful basis for doing so, such as the following:
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User consent
This is where you have given us permission to process personal information for a given purpose. For example, if you complete one of our general enquiry forms, we would ask for your consent if we wanted to use your personal information for any other purpose. You have the right to withdraw this consent at any time. You can manage your preferences within your account or by contacting your account manager.
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Contractual necessity
This is where we have to process personal information to meet our contractual obligations. For example, if you subscribe to one of our products, we would need to process some personal information to fulfil your subscription.
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Legal obligation
This is where we have to process personal information in order to comply with the law. For example, we process and retain customer invoice information to comply with financial regulations.
We may also rely on relevant exemptions under the GDPR to the requirement to identify a lawful basis for processing.
How we use your personal information
We collect personal information for the following main reasons:
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To provide our service
We require some of your basic personal information so our services work as you would expect, for example, providing access to our digital content, notifying you of changes to our services and dealing with customer services queries. We may record customer calls for monitoring and training purposes. Our support team may need to access your account to assist you with queries.
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To improve and maintain performance
In order to provide you with the best possible user experience and value, we need to make sure that our products and services work as they should. Using personal information helps us understand how our readers experience our Sites and services, so we can make improvements. This includes contacting customers with market research surveys or for telephone and video interviews, hosting subscriber focus groups and analysing onsite data to test new and existing events, products and developments for the FT group.
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To bill our customers
We, along with our authorised payments processors, securely process your payment information to take payments, give refunds and to detect and prevent fraudulent activity. We will also update your payment information in the event that a payment is unsuccessful. You can manage your payment information at any time by contacting customer services. If your subscription is provided under a group subscription or trial, we will report information about your activity on our Sites for the purposes of billing.
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To monitor compliance with our policies and terms
We monitor for breaches of our terms and conditions and copyright policies. For example, we reserve the right to inform the subscription holder if, through use of a group subscription, you are using our content in breach of the terms and conditions or copyright policies of our Sites. We also monitor activity on our Sites to detect and prevent invalid or fraudulent traffic.
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To personalise our products and services
We improve your experience of our products and services by personalising parts of our Sites and apps with the information you give us and what we learn about you. This includes showing you articles you may be interested in and recommending emails you may wish to sign up to. Where our Sites have such functionality, you can manage elements of personalisation in your account.
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To communicate product changes and offers
We want you to get the most out of our products and services, including showcasing our latest content and newsletters. We will contact you with carefully-curated offers and promotions, exclusive event invitations and feature announcements. You are able to change your preferences at any time through your account or by contacting your account manager.
We also personalise our communications for strategic purposes. For example, we might offer group subscriptions to portfolio managers.
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For the purpose of advertising
We rely on advertising revenue in part to support our content. We need to process your information to understand the effectiveness of the advertising we serve to you and others, and to deliver relevant personalised advertising. We use the information you give us, the information we collect about you, and the information we infer, to serve you with the most appropriate advertisements.
You can manage your advertising settings for the Sites that carry out this activity in your account. If you do decide to turn off personalised advertisements or advertisements tailored to you, you will still see the same number of advertisements but they may be less relevant to you. You may continue to see advertisements that are targeted to you based on other non-personal information, for example, the article that you are reading.
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To build directories
A number of our sites (including IncentivesFlow, InvestmentFlow, Influencers and fDi Markets) process personal information to create databases and directories. These directories provide key business insights and profiles to those that have licensed access. Where we make an individual's contact details accessible in our directories, we inform the individual and provide instructions on how to have their contact details removed.
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To administer prize draws and competitions
If you enter a prize draw or competition, we will process your information in order to run the competition or administer the prize draw. For example, we will process your address information if you are a winner and we need to send your prize by post. We may be required to publish or otherwise make available your name and/or region if you are selected as a winner in a competition or prize draw.
Who we share your personal information with
We disclose personal information to facilitate the running of our business or to provide specific services you have requested. Commonly, we will disclose information to:
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Service providers
We engage service providers who help to support our business and improve our products. These service providers include, for example, fulfilment providers for delivery of our digital content and marketing; customer service agencies; hosts, organisers and sponsors of our events; organisations that host our Sites, events or databases; and providers of online surveys. We have contracts in place with suppliers who process data to provide these services and they can only use your personal information under our instruction. For example, if you have been included in one of our directories, your personal information may have been researched by one of our suppliers and provided to us for inclusion in the directory.
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Advertisers
We, and our advertising partners, may use cookies to collect personal information and serve you with advertisements that we believe are relevant to you and your interests.
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Institutional customers
If your subscription is provided under a group subscription or trial, we will provide our client with information about your activity on our Sites for the purposes of user management, licence administration, content suggestion and billing.
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Social media providers
Information will be shared with social media platforms where you log in to our Sites via a social media account, or use components on our Sites provided by social media platforms (e.g. if you choose to share our content via LinkedIn using one of the buttons on our website). We also share the information of our customers with social media partners for the following reasons:
- To prevent existing subscribers from being targeted with subscription offerings on social media platforms;
- For the purposes of targeted advertising on social media platforms, and to create lookalike audiences for these purposes;
- To encourage users to get the most out of their subscription.
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Other Users
Where we have researched publicly available information about you for inclusion in one of our directories, this information is available to subscribers of those directories. For example, if you are listed as a contact for a project that is included in a directory, subscribers will be able to see your name and contact information, unless you opt-out.
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FT group
We share your information with other companies within the FT group to provide our services and to better understand the relationship between our products. More information about the FT group is on our "About us" page. Sometimes services are provided between legal entities in the FT group, which may involve the processing of personal data by one entity on behalf of another. For example, if you have subscriptions to multiple products, your personal information may also be held and jointly controlled by The Financial Times Limited, as well as The Financial Times (Overseas) Limited.
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Legal processes and successors in title
We, and our suppliers, may also disclose your information to comply with applicable laws and regulations, court orders or other valid legal processes, and to enforce or apply our terms of use, any subscription agreement, or any of our other rights.
We may transfer or disclose your personal information to any entity which takes over or acquires the relevant FT business.
We also share aggregated, non-identifiable information with third parties. Before sharing this information, we ensure that it cannot identify you as an individual. For example, we regularly release information about the size and growth of our audiences.
How long we retain your personal information
We retain the majority of your personal information for as long as your account is active and therefore open; this allows you to continue accessing our content, products and services.
If you become inactive and are not a subscriber, we may delete elements of the information associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account.
Where we don't need to keep all of your information in full, we may obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary.
A summary of how long your personal information is retained can be found below:
| Category of Data | Example | Retention Period | Justification for Retention |
|---|---|---|---|
| Billing information | Masked details of most recently used payment method | 7 years | For regulatory reasons we are required to retain accounting records for 7 years. |
| Business intelligence | Web activity on our sites | 36 months (then aggregated + non-personally identifiable) | To improve and maintain performance, personalise our services and to provide our product. |
| Customer service queries | Complaint about a service you're subscribed to | 7 years | To provide a case history to assist us to answer your queries. |
| Communication history | Email stating that your subscription is up for renewal | 7 years | So that we have a record of what communications we have sent to you, to better assist your queries. |
| Event registration | Sign up information for European Cities & Regions of the Future 2023 Awards Ceremony | 13 - 36 months | For event administration and, with your permission, to invite you to future events. |
| Market research | Responses to surveys about our products | 36 months (then aggregated + non-personally identifiable) | To administer market research incentives, avoid duplicating research requests and to understand research responses against usage of our Sites. |
| Site features | Trends and Analysis Tool | Lifetime of the account | To improve your experience of our products and services and to enable you to continue accessing site features. |
| Subscription information | Account information relating to your subscriptions | 7 years post-subscription | To enable us to fulfil your contract with us. |
It is sometimes necessary for us to keep your personal information for longer periods of time, for example:
- If there is a statutory requirement to retain it;
- If we require the information for legal reasons or there is a legitimate business need for us to retain it;
- To ensure we do not contact you if you have asked us not to.
How we keep your personal information secure
We have appropriate technical and administrative security measures in place to help ensure that our users' information is protected against unauthorised or accidental access, use, alteration, or loss. We use encryption technology, such as Transport Layer Security (TLS), to protect your personal information when you order products or services from us. More information about our approach to cyber security can be found in our Cyber Security Statement.
We operate a global business, so your personal information may be processed and stored outside the UK and the European Economic Area (EEA). For example, our global account managers need to access information about you in order to respond to your queries. We put in place safeguards, such as standard contractual clauses, to protect information that is transferred in this way.
Your rights
Under data protection laws, you may have rights as an individual in relation to the personal data we hold about you. These rights include:
- The right to object to direct marketing - your preferences, including in relation to direct marketing, can be found in your account;
- The right to access the personal data that we process about you;
- The right to request the deletion of your personal data;
- The right to request the rectification of your personal data - you can manage some of this information in your account.
You can exercise these rights through your account or by contacting your account manager.
You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO).
Where this Privacy Policy applies
Personal information is collected by The Financial Times (Overseas) Limited on behalf of the Financial Times group of companies and its trading divisions (including FT Locations and GIS Planning).
Our Sites are not intended for children under 16 years of age. We do not intentionally collect or use any information from children.
Our Sites contain links to third party websites which are not subject to this privacy policy. We are not responsible for their content, use of personal information, or security practices.
If you have a query in regards to the processing of your personal information, please contact our Data Protection Officer directly at ftprivacy.fto@ft.com.
The Financial Times (Overseas) Limited
Registered Office: Bracken House, 1 Friday Street, London, EC4M 9BT, United Kingdom.
Registered Number: 1613899
FT Group
Please also refer to the relevant Privacy Policies for FT Locations and GIS Planning if you are also using, or have notified us of marketing contact permissions relating to, these products.
EU Representative
To comply with the General Data Protection Regulation (2016/679) we have appointed a European representative:
Bird & Bird GDPR Representative Services Ireland
Deloitte House
29 Earlsfort Terrace
Dublin 2
D02 AY28
EUrepresentative.FinancialTimes@twobirds.com
Key Contact: Vincent Rezzouk-Hammachi
Privacy notice for California Consumer Privacy Act
This section is intended for California residents and supplements the above.
Rights for California Residents
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, (CCPA) may provide you with additional rights regarding the use of your personal information. These rights include:
- The right to access the personal information we process about you;
- The right to know what personal information is collected about you, whether any information is sold or disclosed, and to whom;
- The right to request the deletion of your personal information;
- The right to request the correction of your personal information;
- The right to opt-out from the sale and sharing of your personal information;
- The right to opt out of automated decision-making and profiling;
- The right to limit the processing of your sensitive personal data;
- The right to not be discriminated against for exercising any of the rights above.
You can exercise any applicable rights by emailing ccpa.privacy@ft.com. You may be required to submit proof of your identity and/or address, if we are unable to confirm your identity or cannot verify that you are a California resident. We endeavor to respond to a verifiable consumer request within 45 days. You may also designate an authorised agent to make a request on your behalf, subject to proof of identity and authorisation.
Summary of consumers' personal information we have collected in the preceding 12 months
| Categories of Personal Information (as defined by California law) |
Sources of Information | Business Purposes | Commercial Purposes |
|---|---|---|---|
| Identifiers: name; contact information including email or postal address and telephone number; unique personal identifiers including online identifier and IP address. |
Directly from you: as part of the account information you provide when you sign up to our services, or when you enquire about our products or services. Information we obtain: including information from partners, service providers or public sources. |
Providing Services: including fulfilment of orders; running our events; providing customer services; verifying customer information; maintaining accounts and auditing interactions with customers. Advertising: short term use of personal information for the customisation of ads to make the advertising on our sites more relevant. Security: including detecting security incidents and debugging. Quality Assurance: including internal research for technological development and maintaining the quality of our products and services. Legal: including monitoring compliance with our policies and terms and communicating product changes. Operational Purposes: other operational purposes. |
Marketing: including sales and promoting products and services. Advertising: allowing third parties who advertise with us to measure the effectiveness of their ads. Directories: including the building and ongoing upkeep of directories. Competitions: including administering prize draws and competitions. |
| Commercial information: including purchase history and transactions; financial details and payment information. | Directly from you: as part of the account information you provide when you sign up to our services. |
Providing Services: including fulfilment of orders; providing customer services; verifying customer information; accounting purposes and conducting audits. Security: including detecting security incidents and debugging. Quality Assurance: including internal research for technological development and maintaining the quality of our products and services. Legal: including monitoring compliance with our policies and terms. |
Not applicable. |
| Professional or employment related information: including job title; industry; company. |
Directly from you: as part of the account information you provide when you sign up to our services. Information we obtain: including information from partners, service providers or public sources. |
Advertising: short term use of personal information for the customisation of ads to make the advertising on our sites more relevant. Quality Assurance: including maintaining the quality of our products and services. Operational Purposes: other operational purposes. |
Directories: including the building and ongoing upkeep of directories. |
| Internet/other electronic network activity: online identifiers including device and IP address; geolocation and online behaviour including interest data, interactions with advertisements and recordings of the actions you take on some of our websites. | Indirectly from you: for example through cookies or similar technology when you are using our websites. |
Advertising: short term use of personal information for the customisation of ads to make the advertising on our sites more relevant. Quality Assurance: including maintaining the quality of our products and services. |
Advertising: allowing third parties who advertise with us to measure the effectiveness of their ads. |
| Audiovisual: audio, electronic, visual and similar information (such as images, videos or call recordings). | Directly from you: when you enquire about our products or services, or contact us about your account. |
Providing Services: including providing customer services; verifying customer information; maintaining accounts and auditing interactions with consumers. Quality Assurance: including internal research for technological development and maintaining the quality of our products and services. |
Not applicable. |
| Inferences: drawn from any of the personal information listed above to create a profile or summary about you (for example, an individual's preferences or characteristics). | Inferred by us: from data we hold about you. |
Advertising: short term use of personal information for the customisation of ads to make the advertising on our sites more relevant. Quality Assurance: including maintaining the quality of our products and services. |
Marketing: including sales and promoting products and services. |
Service Providers
As described in our Privacy Policy above, we share your personal information with third parties for business purposes. Commonly, these include service providers who help to support our business operations and improve our products.
We also use service providers to serve you with advertisements that we believe are relevant to you. These third parties are permitted to process your personal information only for the purposes of providing services to The Financial Times (Overseas) Limited; this may include the use of their own cookies or similar technologies to collect your personal information (IP address or other unique identifier) as part of providing their services to FT.
Do Not Sell or Share My Personal Information
Our Advertising
If you are a California resident, the CCPA also provides you with a right to opt-out of the sale and sharing of your personal information. The definitions of 'sell' and 'share' are extremely broad under the CCPA, and may include sharing certain pieces of information with our advertising partners, such as cookie identifiers, geolocation and interactions with advertisements, for the purposes of showing you advertising that is relevant to your interests.
You can choose to block sharing of this data with advertisers. This means that we turn off some types of advertising based on information you have given us and your use of our Sites, ensuring that our advertising partners do not receive this data. By opting out, you will stop receiving adverts that are targeted specifically to you; however, you will still see the same number of adverts on our Sites.
You can opt out using the 'Do Not Sell or Share My Info' link located in the footer of the website you are using, if that website shows the types of advertising described above. Alternatively, you can request this by emailing ccpa.privacy@ft.com.
Our Directories
IncentivesFlow is an online database tracking government incentives on a global and real time basis.
InvestmentFlow is an online database that tracks and profiles domestic investment in the UK and Canada.
Influencers is an online database that tracks and profiles investment intermediaries.
fDi Markets is an online database that tracks and profiles companies investing overseas and uses this information to understand the trends in FDI on a global basis.
As part of the research process for these directories, we identify publicly available details of key individuals who are linked to either project activities or listed as a company contact.
If your contact details have been included in one of these directories, you will have received an email containing instructions on how to opt-out, which you can do by calling +44 (0)20 7775 6667 or emailing ccpa.privacy@ft.com.
More Information
For more information on how we use your personal information and who we share your personal information with, please see our Privacy Policy above or contact ccpa.privacy@ft.com.
Changes to this Privacy Policy
This policy was reviewed on 28/02/2023 and last updated on 28/02/2023.
Any changes we may make to this privacy policy will be posted on this page. If changes are significant, we may choose to notify you by email or to clearly indicate on our home page that the policy has been updated.
