Privacy for our clients and other individuals is a priority for us, and we are committed to ensuring that all personal data is processed with the upmost respect for the rights of the individual. This privacy policy explains how The Project Syndicate, with its registered office at 9 Bay Colony Court, East Hampton, NY 119 37, United States of America, company ID: 26 - 146 99 01 (“Project Syndicate” or “we”) processes personal data.
We only collect, use, and process your personal information in accordance with actual data protection legislation. This includes but is not limited to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and applicable national data protection legislation.
Your personal data are usually obtained directly from you. In this case, you provide your personal data on a voluntary basis. Specific cases of non-disclosure of personal data may affect the ability of Project Syndicate to properly provide services, or properly perform contractual obligations.
Project Syndicate acts on behalf of its subscribers and other clients in the capacity of a data controller.
FOR WHAT PURPOSES ARE PERSONAL DATA PROCESSED?
Project Syndicate processes your personal data as needed for the following purposes:
- (i) Provision of services – this includes the creation and management of your user account or delivery of digital content (legal basis: processing necessary for contractual performance or for the implementation of measures taken before a contract is concluded);
- (ii) Processing payments – this includes the maintenance of payments, together with payment processors (legal basis: processing necessary for contractual performance);
- (iii) Marketing activities – this includes the delivery of personalized content, targeting of advertising or the sending of newsletters (legal basis: legitimate interest);
- (iv) Determination and enforcement of Project Syndicate’s legal claims (legal basis: legitimate interest); and
- (v) Compliance with legislation.
If necessary, Project Syndicate will ask you for permission to process your personal data.
WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS?
Using the services provided by Project Syndicate may require the following data:
- (i) Name, surname, and date of birth;
- (ii) Username and password;
- (iii) Address, telephone number, and email;
- (iv) Payment details (payment card information);
- (v) Your preferences and opinions on products and services, comments on specific articles; and
- (vi) Your browsing activity on our website.
WHEN DO WE COLLECT DATA?
All data that we receive is obtained directly or indirectly from you when you choose to use our services. This includes the following situations:
- (i) When you register on our website;
- (ii) When you subscribe to our newsletter;
- (iii) When you pay for premium services or donate;
- (iv) When you browse our website;
- (v) When you share content from our website or when you comment on our articles; or
- (vi) When you interact with us via social media platforms.
WHO DO WE SHARE PERSONAL DATA WITH?
In order to provide you with the services you request, your personal data may be provided to:
- (i) Selected employees of Project Syndicate;
- (ii) Service providers – those ensuring provision of the services provided by Project Syndicate, in particular software services providers, marketing providers, customer service providers, and distributors of marketing and other materials such as newsletters, including employees of such entities;
- (iii) Tax advisors, professional advisers (e.g. auditors, lawyers), including employees of such entities;
- (iv) Entities providing payment services; and
- (v) Social media providers – using the services of Project Syndicate together with a social network may require Project Syndicate to share your personal data with social media providers.
HOW LONG ARE YOUR DATA RETAINED?
We keep your data for the period of time necessary to fulfill the purposes of processing as defined above; however, this data will be erased after the deletion of your user account or, if you do not have a user account, when you stop interacting with Project Syndicate (i.e. after delivery of a particular service or after a reasonable expiration period that is no longer than three years, unless Project Syndicate has a legitimate interest in keeping the personal data longer (for example to protect Project Syndicate’s legal claims). This would be the case if Project Syndicate had a legal obligation to keep your data for a longer period of time (for example, based on applicable accounting rules), or in cases where applicable law obliges us to keep such records for a longer period.
ARE YOUR PERSONAL DATA SECURED?
We store electronic and in some cases physical copies of your personal data. In accordance with best practices, we maintain security safeguards that protect your data. We strictly limit who is allowed to access the information and we keep this number to a minimum. In addition, we maintain physical and cyber safeguards, such as partial anonymization of data, server protection devices, and software to minimize possible loss, misuse, or alteration of your data.
Your personal data may be stored and processed in countries where Project Syndicate carries out business or where its service providers are located. These countries may apply different privacy rules than the State of New York, the European Union, or the European Economic Area (EEA). Project Syndicate has put in place appropriate contractual and other measures to protect your personal data when personal data are transferred to related parties or third parties located in other countries.
In the case of cross-border transmission of data from the EEA to countries where the European Commission recognizes an insufficient level of protection of personal data, the controller ensures that appropriate measures are taken, including ensuring that data recipients are bound by EU standard contractual clauses to protect your personal data. A copy of these measures can be requested from the administrator via email at: [email protected]. To learn more about such contractual clauses, please visit the European Commission information website.
WHAT ARE YOUR RIGHTS?
You have the following rights in relation to your data:
- (i) To request access in order to correct or delete your personal data, as well as to restrict its processing; however, your right to delete or restrict processing is applicable only if Project Syndicate is not required to process it on another legal basis (i.e. compliance with a legal obligation);
- (ii) Depending on the extent of processing of your data in order to manage your user account and comply with purchase or other contracts, you are entitled to the portability of your personal data; and
- (iii) To object to the processing of your personal data processed with a legitimate interest, as well as against processing for marketing purposes.
If you wish to exercise your rights above or have any questions regarding the processing of your personal data, please contact the administrator by email at: [email protected]. You are also entitled to file a complaint with the Division of Consumer Protection, which is the relevant data protection authority in the State of New York.
The information that Project Syndicate is required to provide to you regarding the processing of your personal data may change over time or become outdated. For this reason, Project Syndicate reserves the right to modify and change these conditions at any time. If these conditions are changed, Project Syndicate will alert you, e.g. by a general announcement on this website, by email, or through your user account.
