Privacy Policy

The China Academy Privacy Policy

The China Academy values your privacy. In this privacy policy we explain how we collect, use and protect your personal data. We know that transparency and trust are important. It’s also important to us that you enjoy using our products, services and websites in a safe and secure way. This policy explains how we collect and use different types of personal and behavioural information, and the reasons for doing so.

About us and this policy

This privacy policy applies to all companies within the Group and all the products and services we offer.

You should read this policy in conjunction with our cookies policy and the relevant terms of use for the product or service you access. The terms of use for The China Academy website are available here. Please ensure that you understand how we collect and use your information.

Our policies will be updated from time to time. Please refer back regularly to keep yourself updated. Where we make a material change to our policies, we will notify our customers.

This policy applies to ‘users’ and ‘customers’ (or ‘you’) of The China Academy; that is anyone ordering, registering or interacting with any product or service from The China Academy. This includes, for example, subscribers, registered users, website users, app users, event attendees, and education course participants. This policy refers interchangeably to ‘your information’ and ‘your personal data’.

1. Why we collect your personal data

We collect and store information about you in order to deliver our products and services. Information you provide to us directly, and information we gather based on your activity, helps us to deliver relevant content and advertising to you, as well as create a more seamless experience across the products and platforms through which you may access our content.

2. What types of personal data we collect

We collect information you provide us with, such as your contact details, to provide you with our services and products.

When you use any of our online platforms or apps we collect information that helps us to deliver the service you have chosen and to improve your experience. This is done through cookies and other similar technologies. Examples of the types of information we may collect are:

Browser
Email provider
The pages you read or otherwise access on our websites and apps, and how you navigated to them
Device
IP address
Internet connection
Location (in some cases)

Depending on our use of cookies and other technologies, you can also choose to provide additional information which may not be essential for us to deliver a service to you, or to serve personalised advertising. This information helps to understand our audiences and ensure we communicate with you in a way that’s most relevant and engaging for you. We may collect and ask for additional information when you order, purchase, register, subscribe or make use of our products or services in any way; for example, in person, via our marketing campaigns, via phone or mail orders, or on our websites.

Information we receive from third parties

We work with third parties who may provide us with additional information that you have shared with them, such as your telephone number and postal address (for example if you’ve moved house or updated your phone number and we need to contact you with important service information). Some third parties may also share further information about your interaction on our sites to help us personalise our services to you. More information can be found in the section headed ‘For audience profiling’ below.

3. How we use your data

We use your information to deliver the products and services you have chosen to receive, and to personalise our interactions (including advertising) with you. See below more information about the main reasons we process your data.

i) To provide our products and services

To fulfil your orders and contracts with us (across all our products and services) this includes our third party specialised payment providers.
To manage your access to our online content and apps, and to send you content via push notifications, newsletters and subscriptions if you have requested this.
To provide you with services where you attend our events.
To send you service notifications related to our products and services such as subscription renewal notifications, password resets and order confirmations.
To manage customer-services queries and complaints.
To manage your privacy preferences and to ensure you only receive communications that you have requested, which may include using your details to suppress you from communications.
To send you administrative emails about your account, reminders of upcoming events, service changes or new policies. These updates, changes and notifications are essential for the services that you have selected.
To provide general location-based services (eg, the region or country you are in), advertising or search results for our content.
To detect and reduce fraud including fraudulent orders.
To prevent users from posting illegal, offensive or objectionable comments on our site.
To run competitions, prize draws and promotions or if you agree to be a speaker or contributor at, or in, one of our events, projects or films. In these cases, subject to any specific terms The China Academy with you separately, you grant a global right to The China Academy to use your name, picture, likeness, voice, biographical information and statements, for advertising, trade, publicity and promotional purposes in all media now known or discovered afterwards and on the internet.

ii) To deliver marketing and advertising

We may send marketing communications via a range of channels, including email and push notifications. You can opt out of these at any time. We may contact you to tell you about special offers and related or similar products or services provided by The China Academy. We may need your consent to use your information for some specific purposes such as marketing, brand-response communications and personalised advertising.

We may pass your information to our partners who may contact you with information regarding their own products and services such as other subscriptions or content services. Where required, we’ll tell you before we share this data and ask for your consent to do this. For corporate events attended by our business clients, we rely on our legitimate interests to collect and share personal data with event sponsors who may then choose to contact you about their services and products. Those parties are responsible for their use of your data and you should read their privacy policies carefully.

Depending on whether you are an individual customer or corporate client, we will ask you to consent to our marketing, or opt out of such communications when you first sign up to receive our products or services. You can also opt out of email marketing by clicking the unsubscribe link at the bottom of our emails. This does not apply to important service notifications such as payment confirmations, or where we have some other legal basis for contacting you.

In order to deliver advertising and marketing messages that are relevant to you, we may use the information we hold about you, including details that we collate from your use of our services or third parties, such as more precise information on your location or your company's profile (eg, company name, company size), to ensure that the advertising you see is of interest to you.

iii) Social-media

The China Academy publishes content on social media platforms to reach current and potential readers.

We may place one or more social-media platform ‘tags’ on our website in order to better understand how The China Academy may be of best value to you by providing you with the most relevant content available according to what you have chosen to read on our own websites. We do not have direct access to your personal data on your social-media platforms.

iv) For audience profiling

To enable us to personalise the content and advertising you see (including on social media), we may use your interaction and browsing behaviour,preferences (such as how and what you read on our websites and our apps) or data collected for market research purposes to create audience profiles. This is to enable content and message personalisation and, in some cases, advertising to be delivered to you or a group of users (an audience) with similar interests to you. This can be done both on our site and on those of third parties. Please see our cookie policy for more information.

We may analyse your individual information to create a profile of your interests and preferences as a part of an audience. These insights are used to help us make marketing decisions so that we can ensure our messages are relevant to you. There are times we may use additional information available from external sources to help us do this effectively (see ‘How we work with third parties’ section below).

v) To personalise your experience

We may also offer you personalised content, advertising and marketing. Personalising these services and products aims to enhance your experience by recommending content and features that are relevant to your reading history and interests.

For personalised content, where you consent to analytics cookies and don’t opt out of the use of aggregated analysis from these cookies, we use information about how you consume Economist Group products to tailor our content. We personalise content to you on the basis of our legitimate interests as a commercial publisher, to understand audiences and tailor content that you find most engaging and suited to you.

We’ve assessed what, if any, impact processing this information will have on your privacy rights and concluded that personalisation affords you, our customer, with a unique experience without any significant impact on your privacy.

vi) How do we process data in the context of our journalism?

We may process people’s information as part of our journalism. This may include the data of contributors, sources, as well as the subjects of our journalism. We process this personal data on the basis of our legitimate interests to produce journalistic material. Where we process special-category or criminal-offence data as part of our journalistic output, we will identify an additional lawful basis to process that data, or rely on the exemption for processing data where it is done for the ‘special purposes of journalism, art and literature’.

4. How we work with third parties

In some instances, we will share information with our third-party partners and service providers to; deliver a service or product, help us improve your experience with us; or when we are required to do so by contract or law. These third parties include agents, subcontractors, sponsors for our events, and other associated organisations. We have contracts in place to ensure the information remains secure and limited in use. Some examples of when we share your information are:

When you make a payment on any of our sites, your payment will be processed by a specialist payment processor to ensure a secure transaction. All payment processors used by The China Academy are compliant with required security standards.
When you log on to your account, a third party provider who specialises in online account management will manage your access including, for example, resetting your password.
When we send you an email or a push notification, these are delivered by marketing platforms. As part of this service, certain information such as whether the message was opened, clicks and formatting are recorded to help deliver the best email experience.
When we test and launch new products, services or offers, we may work with trusted third parties to support us.
We also employ third parties to carry out statistical analyses and conduct surveys on our behalf, to support our advertising and content-production efforts respectively.
To provide information for auditing and legal purposes when required by our regulators.
To enhance your profile with non-personal information.
To enable third parties such as advertisers or sponsors to contact you with information about their own products and services that may be of interest – but only if you give explicit permission for us to do so.

5. What lawful bases do we rely on to process your data?

We need to identify a legal reason, or ‘lawful basis’, to process your personal data.

Other than where we have asked for your consent, we mainly rely on two other separate bases to lawfully use your information. First, we need to use your information in certain ways to provide our products or services to you, in accordance with our contract(s) with you. In this case, it is necessary for us to use your information so that we can deliver the products or services you have chosen. Second, as described in more detail below, in certain cases we may use your information where necessary to further our legitimate interests, where those legitimate interests are not outweighed by any negative impact on your rights or interests. Some of the purposes for which we may process your data based on our legitimate interests include:

To measure customer and user response and engagement with our products and services such as online content, email newsletters and subscription offers. This may include sharing your information with third parties who help us to analyse and measure these things.
To ensure our products (including websites and apps) are compatible with the browsers and operating systems used by most of our visitors.
To help us improve our customer and user experience and to support product development. We may send customer satisfaction surveys and market research questionnaires (for which we may share your information with third party suppliers employed by us).
To create audience profiles for personalised advertising, marketing or research and development on and off our websites.
To detect and reduce fraudulent activity and for other security-related purposes such as to help us protect against harassment, IP infringement, crime or other security issues.

You have the right to object to any of the above uses of your information, so please contact us if you wish to do so. We will consider all objections reasonably, but there may be legal reasons where we deem that the use of your information is still necessary and reasonable in the circumstances. We will explain our decision to you in a timely manner.

We may share your personal data with third parties for any purpose required by law or regulation and to verify information that we provide to third parties for compliance and audit purposes.

Below, we outline the lawful bases we rely on to process your data and general examples of the types of data we collect under each basis.

Consent

Marketing - generally, if you’re a new customer, we need your consent to send you marketing

Legitimate interests

Marketing - if you’re an existing customer, we may rely on our legitimate interests to send you information about new products
Personalised content
Contributor data and the personal data of those identified in our journalistic output for the purposes of producing journalism

Necessary for performance of a contract

Manage subscription payments
To identify customer usage data for group subscription accounts
To send subscribers important service messages

Defence of a legal claim

In circumstances where The China Academy commences or defends a legal claim involving the processing of personal data

Required by law

For tax and auditing purposes

6. When may we send your data overseas?

As a global company, we have offices in different locations and we work with trusted third parties around the world. This means we may collect and share your personal information internationally. Generally, we will notify you when we do this and always ensure we have appropriate legal safeguards in place to protect the transfer of data.

7. How do we keep your data safe?

We take information security seriously. We run a comprehensive security programme and have policies and procedures in place to ensure the information we hold on you remains safe. We limit who has access to your information and ensure that those who do are bound by contracts to keep your information availability restricted and safe.

8. What are my data rights and how can I exercise them?

Under the laws of Hong Kong SAR and other laws that may apply, you may have the right to request the following, subject to exemptions:

You have the right to correct the personal data we hold about you.
You also have the right to ask us to rectify, delete or restrict access to your data.
Where applicable, you have the right to object to processing of your personal data for specific purposes, including marketing.
Where you have provided us with consent to use your personal data, you can withdraw this at any time.

Please be aware that there are circumstances in which complete erasure of your information will not be possible for operational, legal and business reasons. This may include if you remain a customer for whom we need to provide services, or where we need to retain some of your details in order to facilitate a ‘Do Not Contact’ request by keeping you on a suppression list.

From time to time, we may make changes to our privacy policy. This may be in relation to changes in the law, best practice or changes in our services. These changes will be reflected in this statement, so you should check here regularly.