Privacy Policy
Introduction – Who we are
Substantive Research Ltd. (“Substantive Research”) provides portfolio managers the best research and data-driven insight into how research providers compare. You may contact us by emailing [email protected] or writing to Substantive Research Limited, Birchin Court, 20 Birchin Lane, London, EC3V 9DU, United Kingdom.
Our Approach to your privacy
This Privacy Notice outlines the information we may collect about you in relation to your use of our products and services (“personal data”). It also explains the legal rights that you have in relation to your data and how you may exercise these rights.
We will process your data for the following lawful purposes: with your consent; to fulfil our obligations to you; and where there is a legitimate interest to do so.
When possible, we rely on your consent to use your data for the purposes described in this Privacy Notice. We also process personal data to fulfil our contractual obligations to you, for example, when you register for any of our services, subscribe to a newsletter, sign-up for an event or purchase a product from us, we will need to process some of your personal data. This will also include details of the person/people responsible for payment (if different).
We may determine that processing your personal data serves both of our legitimate interests. This is the case in relation to many of our research, customer survey, sales, marketing and advertising activities described in this Privacy Notice. These activities allow us to better understand your requirements, which in turn enables us to provide you with a better service. We review the basis for our processing decisions carefully and you can object to these activities at any time (see the “Your Rights” section of this Privacy Notice).
Policy Scope
We provide this Policy to explain the ways in which we collect, use, and share personal information about individuals who:
- visit or interact with our websites, including substantiveresearch.com, substantive.io as well as the other websites that Substantive Research operates and that link to this Policy (collectively, “Websites”) (“Website Visitors”);
- attend or register to attend events which we organize or co-organize, or visit our offices (“Attendees”).
For purposes of this Policy “Websites”, shall refer collectively to www.substantiveresearch.com, substantive.io as well as the other websites that Substantive Research operates and that link to this Policy, the term “Services” shall refer to our tools and services made available from the Websites.
What Personal Data We Collect & Why
Our primary goal in collecting personal data from you is to give you a relevant customised experience of our products and services.
Registration, Free Trials & Subscriptions
When you subscribe to a newsletter on one of our “Websites” and/or sign up for one of products or services, we may ask you to provide your name, address, email address and telephone number, and details relevant to your occupation or employer. If you subscribe to one of our products or services, we will also ask for payment details.
Session Replay Scripts
On our Services we may also use session replay scripts provided by third-party analytics service providers to better understand our users’ needs and to optimize our Services and user experience. These website analytics tools provide us heatmaps, session recordings of your activities on the Services, form analytics, feedback campaigns, and similar features and functionalities, including to assist in website debugging and customer service matters. Our session replay script providers may record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields, and other metadata such as IP address or device type. If you would like to opt-out of the use of session replay technologies on our websites, you may do so at any time by visiting FullStory at https://www.fullstory.com/optout/ or Hotjar at https://www.hotjar.com/legal/policies/do-not-track/.
Events & Conferences
We use Eventbrite for promotion and booking of Substantive Research events. Eventbrite may collect personal data including: name, job title, company, address, telephone number and email for this purpose. This information is necessary so that we can complete your registration for the event and provide you with relevant event materials. Eventbrite is a third-party service that is not owned or managed by Substantive Research. You should refer to Eventbrite’s privacy policy as we do not accept any responsibility or liability for their policies. We may also provide delegate details (e.g. name, email) to event sponsors who, subject to your consent, may contact you for their own advertising and marketing purposes.
Surveys, Market Research & Customer Feedback
We want to understand the needs of our readers and customers. We may therefore use the information you provide us – including your name and contact details – to contact you to request your feedback, or to participate in our customer and market research.
Additional Third Party Disclosures
We may disclose your personal data to other third parties in the following situations:
To third party partners who help us by providing services such as technology, advisory or other services. These third parties only receive encrypted data and may only process personal data to provide those services to us.
Where we are required by law or regulation to do so. In each case we will seek, where practicable, to minimise the amount of data that is disclosed.
If required to protect the rights and interests of other users and/or Substantive Research and its affiliates (including our employees, agents and contractors), or as otherwise set out in our Terms of Service. This may include exchanging information with other companies and organisations for the purposes of fraud protection.
Email Tracking
We may include small pixel tags (small image files) within the emails we send you in order to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. We may also collect browser, location and the device used to engage with our email communications. This information allows us to better understand whether we are meeting our users’ needs and how we can improve our communications. No other information is collected. You can opt out of receiving our direct marketing emails either by following the instructions in each email, or by contacting us (see the “Who We Are” section of this Privacy Notice).
Retention Periods
We have a data retention policy that ensures we don’t use or store your personal data for longer than necessary. We consider the following issues to determine retention periods:
Guidance from the UK Information Commissioner or other regulatory agency, or industry best practice recommendations;
The business rationale for collection and expiry of the purpose for which personal data was collected;
Our ongoing ability to ensure the accuracy of the data; and legal and regulatory requirements.
We may occasionally need to keep personal data for either shorter or longer periods than specified in our retention policy. In such circumstances, application of the retention period to the data will be temporarily suspended. The suspension of an applicable retention period will be carried out in a manner that respects the rights and interests of all persons concerned.
How You Can Set Your Data & Privacy Preferences
You can request changes to your privacy preferences by emailing [email protected]
Your Rights
Under data protection laws, you 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;
- 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;
To exercise any of these rights, please contact us by post or email at the following addresses: Substantive Research Limited, Birchin Court, 20 Birchin Lane, London, EC3V 9DU, United Kingdom. Email: [email protected]
We may need to check your identity prior to processing a request.
Substantive Research will do our best to respond to any questions and address any of your concerns. You are also able to register any complaints regarding the processing of your personal data directly with the UK Information Commissioner.
Protecting Your Data
Substantive Research is committed to keeping your personal data secure and we will take appropriate technical and organisational measures to protect your personal data from loss, unauthorised use, disclosure or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk. All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.
