Privacy Policy

Important Information and Who We Are

With this Privacy Policy Argus Media Germany GmbH (“Argus” and “we”, “us” or “our”) would like to inform you about the scope and purposes of the Processing of your Personal Information by Argus and other companies within Argus Group, and the rights you have with regard to such Processing of your Personal Information. Argus Group is made up of different legal entities, details of which can be found here.

To ensure that Personal Information is managed responsibly, Argus Group employs a Data Protection Officer. If you have any questions about this Privacy Policy please address our Data Protection Officer by email to: DPO@argusmedia.com or by writing to Data Protection Officer, Argus Media Ltd, Lacon House, 84 Theobald's Road, London, WC1X 8NL, UK.

If you live in the EU, you have the right to raise a complaint with a supervisory authority, e.g. the data protection authority responsible for your place of residence, your workplace or the place of data protection violation.

If you live outside of the EU, privacy laws in your country may also you give this right. A list of national data protection authorities is available here.

The Purpose of this Privacy Policy

Argus Group recognises the fundamental importance of privacy, security and data protection to our customers and partners worldwide. As a global organisation, with legal entities, business processes, management structures and technical systems that cross international borders, Argus Group strives to provide information protection across all operations and deploy consistent, rigorous policies and procedures.

The purpose of this Privacy Policy is to provide you with transparency of Argus’ Processing operations, and it is designed to help you understand how we use and safeguard the Personal Information we hold about you, including information that may be collected from your online activity with us. This Privacy Policy also informs you about your rights in relation to our Processing of your Personal Information.

In particular, Argus may use your Personal Information in accordance with this Privacy Policy to form a view on what products, services and offers we think you may want or need, or what may be of interest to you. We will usually process your Personal Information for marketing purposes on the basis that we have a legitimate interest to retain our existing clients and to attract new clients.

You can manage your marketing preferences at any time (including by letting us know the industry sectors in which you are most interested in or by unsubscribing from marketing communications) hier.

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. To see when this Privacy Policy was last updated, please see the “Last Updated” section below.

Defined terms used in this Privacy Policy are set out in the Definitions section below.

Please see the sections below to learn more about specific elements of our Privacy Policy. In particular, the rights you have with regard to Processing of your Personal Information, including the right to object to profiling, are described in section 8 of this Privacy Policy.

Last Updated: This Privacy Policy was last updated on 17.12.2020.

1. Where we get your Personal Information

We collect Personal Information:

1) Through our websites, our mobile device or desktop applications, our program add-ins, or any other Argus Group tools or delivery platforms through which we make our content available (the “Content Platforms” );

2) When you interact with us through social media websites and other websites and apps;

3) As a result of your subscribing to or contracting for our services;

4) As a result of your attendance at our conferences, webinars and other events, or at events not organised by us where you interact with our staff;

5) When you communicate with our staff, including, for example, through instant messaging applications and email;

6) When you visit our premises and your Personal Information is recorded for building security purposes; and/or

7) Through our own research, through our partnerships and from third parties that provide it to us (e.g., your employer, where appropriate in the context of providing services; credit reference agencies to the extent necessary to detect and prevent fraud; law enforcement authorities to the extent necessary to investigate actual or suspected criminal activity).

2. Types of Personal Information Processed by us

The categories of Personal Information we Process are as follows:

1) Personal contact information, such as name, address, telephone number and email address, country of residence;

2) Business contact data such as your employer’s name, your employer’s address, your job role, your business telephone number and your business email address;

3) Financial information, such as your bank account, credit/debit card number or other billing information;

4) Information necessary for providing services to you, such as your contact preferences, user IDs and passwords;

5) Geo-location data such as your IP address or physical location;

6) Details of the services you have purchased from us or which you have enquired about including: contracted services, subscriptions, conferencing events, consulting and other services. together with any additional information necessary to deliver those services and to respond to your enquiries;

7) Any additional information relating to you that you provide to us directly through Content Platforms; and

8) Information you provide to us through our customer surveys.

3. Grounds on which we Process your Personal Information

We will only Process your Personal Information in a fair, lawful and transparent manner. The purposes for which we Process Personal Information and our legal basis are set out in the appendix below.

We may combine Personal Information you give to us and other information we collect about you. When combined, this will be treated as Personal Information and we will only use it in accordance with this Privacy Policy.
.

4. Matomo and the use of cookies

In addition to the purposes listed in section 3 above, Argus Processes your Personal Information in connection with the tool Matomo. Matomo is an open source software tool for web analysis. Web analysis means the Processing of data in order to analyse the behavior of website visitors. For such purposes, Argus Processes information relating to which website you were directed from (so-called referrer), which subpages of the Site you have accessed, how often and for how long a subpage was viewed, and so on. We use such web analysis mainly to optimise our Sites and to analyse costs and benefits of internet advertising.

Matomo is hosted on our own server, so that all of your Personal Information that is processed in connection with Matomo is stored exclusively on our server. Argus uses Matomo to analyse the flow of visitors on our Sites, in particular to evaluate the use of the Sites in online reports showing the activities on our Sites.

For such purposes, Matomo places cookies. Cookies are small text files that may be stored on your computer or other device when you visit a website. They are generally used to make websites work, to keep track of your movements within the website, to remember your login details, and so on. With the cookies placed by Matomo, we are able to analyse the use of our Sites. Each time one of the subpages of the respective Site is accessed, the Matomo tool automatically prompts your internet browser to transmit data to our server for online analysis. As part of this process, we process your Personal Information, such as your IP address, which we use inter alia to track the origin of visitors and clicks.

The cookie is used to process Personal Information, such as the access time, the location from which an access originated and the frequency of visits to our Sites. Each time you visit our Sites, this Personal Information, including your IP address is transferred to our server. We do not share this Personal Information with third parties.

You can disable the setting of cookies by us at any time by changing your internet browser settings. You can also delete any cookies placed by Matomo in your browser settings at any time. To object to the setting of cookies by Matomo in connection with our Sites, please activate the “Do not track” option in your browser. It is however possible that the Sites are not fully functional without the use of cookies.

Further information and the privacy policy of Matomo can be found at https://matomo.org/privacy/.

Please also see our cookie policy for further information on how we use cookies on our Sites.

5. Transfer of Personal Information to Affiliates

Argus Group is an international group and in order to operate our business your Personal Information may be shared with other companies of the Argus Group and stored and Processed in any country where we have operations. Details of our group companies may be found here and the Privacy Policy of the Argus Group is available here.

Argus may share Personal Information with other Argus Group companies for the purposes set outin the appendix below. In particular, Argus shares Personal Information with other Argus Group companies based on our legitimate interests for administrative purposes, and to enable individuals working in different Argus Group companies to communicate and collaborate with one another, in order to provide a full Argus Group service to clients.

Argus Group often administers its direct marketing efforts centrally at Argus Media Ltd., Lacon House, 84 Theobald's Road, London, WC1X 8NL, UK. For such purpose, we may share your Personal Information with Argus Media Ltd. Please find more information on the Processing of your Personal Information for marketing purposes, please see the Appendix below.

Where we transfer your Personal Information from Argus to Argus Group companies located outside the European Economic Area (“EEA”) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You may request a copy of the Standard Contractual Clauses by contacting our Data Protection Officer. Please find the contact details on the first page of this Privacy Policy.

6. Other third parties we share your Personal Information with

We may also share your Personal Information with third parties as set out in this section 6. Please note that we will only share your data with third parties who will process your Personal Information in a manner consistent with this Privacy Policy and subject to appropriate safeguards.

Sharing your Personal Information with such third parties may involve transferring your Personal Information to the countries in which these third parties are based. These companies may be based within or outside of the EEA and, in some cases, in countries which do not afford the same level of Personal Information protection as may be found, for instance, in EU countries.

Whenever we transfer your Personal Information to third parties outside of the EEA, we will ensure that appropriate safeguards are in place, such

The third party is located in an Adequate Jurisdiction; or
We may enter into Standard Contractual Clauses with the third party

Please contact us through the details provided on the first page of this Privacy Policy if you would like further information on the specific mechanism used by us when transferring your Personal Information to third parties outside the EEA.

Service providers and partners

We retain service providers and partners to manage or support certain aspects of our business operations for the purposes set out in the Appendix below. These service providers may be located in the EEA, US or in other locations and may provide services such as service delivery, report personalisation, advertising and marketing activities (including digital and personalised advertising), IT services, email service providers, data hosting, and management or support of our websites. Our service providers are required to safeguard any Personal Information they receive from us and are prohibited from using the Personal Information for any purpose other than to perform the services as instructed by us. We may also share your Personal Information with accountants, auditors, lawyers and other outside professional advisers to Argus Group, subject to binding contractual obligations of confidentiality. We also take steps to provide adequate protection for any transfers of your Personal Information in accordance with applicable law.

Compliance with law and protection of people and property

We may, for compliance with a legal obligation, share your information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. We may also, to protect the vital interests of data subjects, or for the performance of a contract, share your information in situations involving potential threats to the physical safety of any person, violations of this Privacy Policy, or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of Argus Group, our employees, users, or the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organisations.

Business Transactions

As we develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets or the assets disclosed in connection with the due diligence for any such transaction. This may be necessary for the performance of a contract or may be necessary in our legitimate interest to progress such transactions.

7. How we protect your Personal Information

We employ physical, electronic and managerial control procedures to safeguard and help prevent unauthorised access to your information. We choose these safeguards based on the sensitivity of the information that we collect, Process and store and the current state of technology. Our outsourced service providers who support our operations are also vetted to ensure that they too have the appropriate organisational and technical measures in place to protect your Personal Information. You can request a copy of the technical and organisational measures employed by us by contacting us through the contact details shown on the first page of this Privacy Policy.

8. Your rights

This section sets out the legal rights you may have, subject to applicable law, in respect of your Personal Information that we Process.

To exercise any of the rights below, please email or write to us through the contact details shown on the first page of this Privacy Policy.

8.1 Right to object to Processing

You have the right to object to the Processing of your Personal Information where we have exercised the right to Process on the grounds of our legitimate interest, including profiling, and there is something about your particular situation which makes you want to object to Processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Information which override your rights and freedoms.

You also have the right to object where we are Processing your Personal Information for direct marketing purposes. Marketing emails you receive from us include an unsubscribe instruction (usually found at the bottom of the email) that you may use to stop receiving future marketing-related emails. Alternatively, you can contact us through the details provided on the first page of this Privacy Policy.
.

8.2 Right to withdraw your consent

Where we are relying on your consent to Process your Personal Information you may withdraw your consent at any time, free of charge, with effect for the future and without stating reasons. However, this will not affect the lawfulness of any Processing carried out before you withdraw your consent.

For example, you may withdraw your consent from marketing emails by unsubscribing using the unsubscribe link usually found at the bottom of the email. Please note that we may be unable to provide you with the full benefit of our Sites, or services, if you choose to withdraw your consent or object to Processing for marketing and communication purposes.
.

8.3 Correction of errors in information

You can ask us to correct any errors in your Personal Information that we hold and Process. If you are unable to update your Personal Information through Content Platforms, please make a request by email or write to us using the contacts details shown on the first page of this Privacy Policy.

8.4 Right to erasure

If you request us to do so and there is no valid reason for us to retain it, we will erase your Personal Information without undue delay.

8.5 Right to restriction

You are entitled to seek the restriction of Processing if there is a disagreement between us as to whether the right of erasure applies. You may seek this right:

(a) for the time needed to verify whether information is accurate if you have contested its accuracy; or
(b) where you feel that we no longer need the data but you do for the purposes of a legal claim; or
(c) you have objected to the Processing but we seek to establish that we have compelling legitimate grounds for overriding your objection.

Where this right applies we will temporarily remove the data from our systems so as to avoid further Processing and we will flag the restricted data in a way that makes it clear that Processing is restricted.

8.6 Recht auf Datenübertragbarkeit

Where we Process your Personal Information by automated means and the Processing is either based on your consent or a contract with you, you can request that we transfer your Personal Information in a commonly used machine-readable form to a third-party system.

We are not responsible if the Processing systems are incompatible such that your Personal Information cannot be read by the third-party system.
.

9. Access to your Personal Information

You have the right to access your Personal Information that we maintain about you and is held by us in paper records or electronic systems. You can make a request by email or write to us using the contact details on the first page of this Privacy Policy.

10. How long will we keep your Personal Information?

We will only retain your Personal Information for as long as is necessary to fulfil the purposes for which it is collected. This may vary according to the purposes of the Processing and the nature of your relationship with us. The following criteria are used to determine the relevant retention periods:

When using the online services provided via the Content Platforms, your Personal Information will be stored as long as it is necessary for the fulfilment of the respective purpose, or until you object to its use for this purpose, or if the Processing is based on consent until you withdraw your consent.
Where we process your Personal Information for the purpose of managing a contractual relationship, we will store your Personal Information for the duration of the contractual relationship
Where we process Personal Information in connection with anticipated legal disputes, we will store the data until the court proceedings have been completed or until the claims at issue have become time-barred in accordance with the applicable civil-law provisions. The general limitation period is three years.
In addition, we are subject to various record retention and documentation obligations imposed by, inter alia, the German Commercial Code (Handelsgesetzbuch – HGB) and the German General Fiscal Code (Abgabenordnung – AO). The record retention and documentation periods provided for by these acts are six to ten years.

11. Definitions

“Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information.
“Controller” means the entity that decides how and why Personal Information is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
“EU” means the European Union.
“EEA” means the European Economic Area.
„“Personal Information” is any information that personally identifies you or from which an individual is identified or identifiable. This may include your name, address, telephone number, email address and profession or occupation.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means any person or entity that Processes Personal Information on behalf of the Controller (other than employees of the Controller).
“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Supervisory Authority and approved by the European Commission.
“Site” means any website(s) operated, or maintained, by us or on our behalf.
“Supervisory Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

Appendix – Grounds on which we process your Personal Information

Processing activity	Legal basis for Processing
Provision of Sites, Content Platforms and services: providing our Sites, Content Platforms or services; and performing our obligations to you or your employer, ensuring that the Content Platforms are presented in the best manner for you; and for any other purpose connected with your or your employer’s agreement(s) with us.	The Processing is necessary in connection with any contract that you (Art. 6 (1)(b) EU General Data Protection Regulation - GDPR), or your employer have entered into with us (Art. 6 (1)(f) GDPR), or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Content Platforms or services to you where you are a client, customer or user of our Sites, platforms and services and where your Personal Information is used to provide, manage or monitor such use (Art. 6 (1)(f) GDPR); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way) (Art. 6 (1)(a) GDPR).
Compliance checks: fulfilling our regulatory compliance obligations; ‘Know Your Client’ checks; confirming and verifying your identity; use of credit reference agencies; and screening against government and/or law enforcement agency sanctions lists and other legal restrictions or requirements.	The Processing is necessary for compliance with a legal obligation (Art. 6 (1)(c) GDPR); or The Processing is necessary in connection with any contract that you (Art. 6 (1)(b) GDPR), or your employer have entered into with us (Art. 6 (1)(f) GDPR), or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of fulfilling our regulatory obligations including compliance with sanctions placed against particular countries, organisations or specific individuals and for fraud prevention (Art. 6 (1)(f) GDPR); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way) (Art. 6 (1)(a) GDPR).
Marketing including Direct Marketing: providing you with information about other products and services we offer: keeping you informed about industry developments that we think are relevant to you; notifying you of industry conferences, events and training courses; offering you additional products and services provided by us or our third-party partners; optimising the content of our websites and advertising it; web traffic reporting and analysis to optimise website content and provide cost-benefit analysis of Internet advertising.	We have a legitimate interest in carrying out the Processing of Personal Information for direct marketing to past, current and potential future clients or customers. We may do so where there is a relevant and appropriate relationship between “you” and “us” or where we believe our products and services, or those of our partners are likely to be of interest to “you” (Art. 6 (1)(f) GDPR); or We have obtained your prior consent to process your Personal Information for marketing or direct marketing purposes (Art. 6 (1)(a) GPDR).
Communications: communicating with you, or your employer, in relation to Sites, Content Platforms or services we provide to you or your employer including notification of changes to any of our Sites, Content Platforms or services; to receive and respond to your enquiries, questions or complaints; communicating with you through any means (including by email, telephone, text message, social media, post or in person) news and analysis that we believe may be of interest to you, telling you about changes to Argus services, Sites, Content Platforms and their functionality; keeping you informed about industry developments; notifying you of industry conferences, events and training courses; maintaining and updating or verifying your contact information where appropriate; and communicating with you to request your prior consent to process your Personal Information if required.	The Processing is necessary in connection with any contract that you (Art. 6 (1)(b) GDPR), or your employer have entered into with us (Art. 6 (1)(f) GDPR), or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of contacting you based on an existing or developing relevant and appropriate relationship (Art. 6 (1)(f) GDPR); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way) (Art. 6 (1)(a) GDPR).
Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).	The Processing is necessary for compliance with a legal obligation (Art. 6 (1)(c) GDPR); or We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (Art. 6 (1)(f) GDPR).
Investigations: detecting, investigating and preventing breaches of contract terms including the misuse of services, policy, and criminal offences, in accordance with applicable law.	The Processing is necessary for compliance with a legal obligation (Art. 6 (1)(c) GDPR); or We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (Art. 6 (1)(f) GDPR).
Legal proceedings: establishing, exercising and defending our legal rights, including protecting, exercising or enforcing our rights under our agreement(s) with you or your employer.	The Processing is necessary for compliance with a legal obligation (Art. 6 (1)(c) GDPR); or We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (Art. 6(1)(f) GDPR).
Legal compliance: compliance with our legal and regulatory obligations under applicable law.	The Processing is necessary for compliance with a legal obligation (Art. 6 (1)(c) GDPR). We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (Art. 6(1)(f) GDPR).
Improving our Sites, Content Platforms and services: identifying issues with our Sites, Content Platforms or our services; planning improvements to our Sites, Content Platforms or our services; and creating new Sites, Content Platforms or services.	We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, or our services (Art. 6 (1)(f) GDPR); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way) (Art. 6 (1)(a) GDPR).
Fraud prevention: detecting, preventing and investigating fraud.	The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law) (Art. 6 (1)(c) GDPR); or We have a legitimate interest in carrying out the Processing for the purpose of detecting and protecting against fraud (Art. 6 (1)(f) GDPR).

¹ Where we refer to our “legitimate interest” as the basis for Processing your Personal Information, we will only seek to rely on our “legitimate interest” to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms.