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Siberia, LLC Privacy Policy

At Siberia, LLC (“Siberia”) we are committed to protecting and respecting your privacy. We hold, as with most businesses, personal information about our customers and people who may be interested in our services.

This privacy policy explains the type of information we Process, how that Processing may affect you and your rights.

We will occasionally update this privacy policy. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. We encourage you to periodically review our policies to be informed of how we may use your information.

Our Data Protection Officer can be contacted at DPO@ascential.com. Any questions regarding this policy and our privacy practices should be sent using www.ascential.com/data or by writing to Vice President, Business and Legal Affairs, Siberia, c/o Ascential Group Limited, The Prow, 1 Wilder Walk, London, United Kingdom, W1B 5AP.

If you wish to make a complaint about how we use your information, please contact us using www.ascential.com/data and we will do our best to help. If you are still unhappy, you can contact the appropriate data protection supervisory authority.

Please see the Definitions section for definitions of terminology used in this privacy policy.

About Us

Siberia collects or receives your data under this privacy policy as a Data Controller for the purposes of EU Data Protection Legislation. Siberia is an Ascential plc group company.

Information we collect

Collection directly from you

Most of the Personal Data we process about you comes directly from you. For example:

  • when you meet or contact us (by email, phone, mail or in person); or
  • when you express an interest in our services.

Automatic collection when you contact us or visit our website

We automatically collect information about you as follows:

  • our websites automatically log web log server information (please see the table below); or
  • we may collect data through cookies. Cookies are small pieces of information which are issued to your computer or any similar device you use to access the internet, e.g., smartphone, tablet or other mobile device when you visit a website and which store and sometimes track information about your use of the website. Please see our Cookies Policy.

Information obtained from other sources

We may be introduced to you by a current or former client or by someone who feels you would benefit from our services. We may also obtain publicly-available professional information about you (as detailed in the Data Processed section below) from third parties or online publications. This information is used in the following ways:

  • to ensure that the information we hold about you is accurate and up to date;
  • to ensure that we have all the information we need to provide or offer you or another client a service; and
  • to help us to provide the best service possible, in the most efficient manner.

Why we process your data

This section details the information what we collect, the purpose for its collection and use, and the legal basis for the Processing.

PurposePersonal DataProcessing ground
To provide you with our services
  • First Name
  • Last Name
  • Job Title
  • Company Name
  • Business Email address
  • Telephone Number
  • Resume and career history
Performance of a Contract
To respond to your communications and to retain a record for quality and training purposes
  • First Name
  • Last Name
  • Job Title
  • Company Name
  • Business Email address
  • Telephone Number
  • Country
  • Industry
Legitimate Interest;
or Consent
To ensure network and information security.Web log server information:
  • IP address
  • Browser type and operating system
  • Pages visited during your visit
  • source of your access to our website (e.g., the website or URL which referred you to our website)
Legitimate Interest
To monitor the performance of our website and improve user experience.Web log server information (see above)Legitimate Interest
To contact you or to stay in touch with you about our products and services.
  • First Name
  • Last Name
  • Job Title
  • Company Name
  • Business Email address
  • Telephone Number
  • Country
Legitimate Interest;
Consent;
or Soft opt-in
To register you for an event or training, and to send you confirmation and further event information. We will also use your name at the event to confirm attendance and ensure your health and safety when you attend in person.
  • First Name
  • Last Name
  • Job Title
  • Company Name
  • Business Email address
  • Telephone Number
  • Country
Performance of a Contract;
Legitimate Interest;
or Protection of vital interests
Informing our product and services strategy to enhance and personalize our customer experience and offerings, or informing our marketing strategy to ensure our communications with you are relevant.
  • First Name
  • Last Name
  • Job Title
  • Company
  • Business Email address
  • Telephone Number
Legitimate Interest

Special Categories of Personal Data

We do not knowingly or intentionally collect Special Categories of Personal Data from individuals and we request that you please do not submit Special Categories of Personal Data to us.

How we share your data

We share your data in the manner and for the purposes described below:

  • Siberia is part of Ascential Plc. Siberia shares information with Ascential-controlled affiliates and subsidiaries, where such disclosure is necessary to provide you with our services or to manage our business. It is our Legitimate Interest to process your Personal Data for these purposes;
  • with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and compliance with all applicable data privacy regulations, and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include: IT service providers, customer relationship management services and marketing automation, solutions and analytics providers;
  • with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
  • we may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our partners or affiliates; and
  • if, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third-party purchaser of our business or assets.

Explaining more about direct marketing and profiling

How we use personal information to keep you up to date with our products and services

We may use personal information to let you know about our services that we believe will be of interest to you. We may contact you by email, mail, telephone, or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

How you can manage your marketing preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

  • we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
  • you can ask us to stop direct marketing at any time. You can ask us to stop sending email marketing by following the 'unsubscribe' link you will find on all the email marketing messages we send you. Alternatively, you can contact us at www.ascential.com/data. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email); and
  • you can change the way your browser manages cookies by following the settings on your browser as explained in our Cookies Policy.

Data Retention

We retain your information for no longer than necessary for the purpose for which it was collected. In determining how long your information will be stored, we will consider:

  • the purpose(s) and use of your information both now and in the future;
  • what information we need to:
    • best provide you with products and services;
    • manage your relationship with us;
    • meet our statutory obligations;
    • develop our products and services; and
    • meet our customers’ and previous customers reasonable expectations.

Geographic Data Transfers

As a global organization, and as an Ascential plc group company with a presence in more than 150 countries, we may transfer your Personal Data outside the EEA to provide the best service possible to our customers and in the most efficient manner. In all instances, we take steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests, and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:

  • we ensure inter-company transfers are covered by appropriate agreement(s) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within the Ascential plc group;
  • where we transfer your personal information outside the Ascential plc group or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU-US Privacy Shield for the protection of personal information transferred from within the EU to the United States; or
  • where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information is disclosed.

Data Subjects' Rights within the EEA

In the EEA, data subjects have the following rights:

  • to request access to your information and information related to our use and Processing of your information;
  • to request the correction of your information (we may seek to verify the accuracy of the personal information before rectifying it);
  • in certain situations, to ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information;
  • in certain situations, you can also ask us to send the personal information you have given us to a third party;
  • to ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA;
  • to withdraw your Consent to our use of your information at any time where we rely on your Consent to use or process that information. This will not affect the lawfulness of our Processing of your data prior to your withdrawal; and
  • to object to the Processing of your information for certain purposes, namely:
    • to us using or Processing your information where we use or Process it in order to carry out a task in the public interest or for our Legitimate Interest;
    • to object to us using or Processing your information for direct marketing purposes. You may also exercise your right to object to us using or Processing your information for direct marketing purposes by clicking the unsubscribe link contained at the bottom of any marketing email we send to you and updating your preferences.

For more information on how to object to our use of information collected from cookies and similar technologies, please see our Cookies Policy.

You can exercise your rights by writing to us at Vice President, Business & Legal Affairs, Siberia, c/o Ascential Group Limited, The Prow, 1 Wilder Walk, London, United Kingdom, W1B 5AP or by sending using www.ascential.com/data.

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are Processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

Data Subjects' Rights in California

If you are a resident of California you may have a right pursuant to Section 1798.83 of the California Civil Code to obtain certain information about the types of Personal Data that we have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.

Please contact using www.ascential.com/data if you would like to exercise any of your rights explained above in relation to your Personal Data.

Do not Track

Some browsers offer a “do not track” (“DNT”) option. For information about Do Not Track, please visit www.allaboutdnt.org.

At this time, we do not respond to DNT signals. For information on how to block and opt out from tracking technologies used on our website, please see our Cookies Policy.

Third Party Websites

Please be aware that we do not control and are not responsible for websites that are referred to, or linked from, our own websites and that use of your personal information on these websites is not subject to this Privacy Policy.

Persons 18 or under

We are concerned to protect the privacy of children. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

If you believe that we have received information pertaining to, or from, persons under the age of 18 please contact us using www.ascential.com/data. If we become aware that a person under the age of 18 has provided us with personal information, we will take steps to delete such information.

Definitions

“Consent” means the specific consent you have given to allow for the Processing of your Personal Data.

“Data Controller” means the entity that determines the purposes and means of Processing Personal Data.

“EEA” means the European Economic Area which comprises countries that are members of the European Union and Norway, Iceland, and Liechtenstein.

“Identifiable Natural Person” means a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Legitimate Interest” means such Processing that is necessary for our or a third-party’s legitimate interests in carrying on, managing and administering our respective businesses effectively and properly (except where our or the third-party’s interests are overridden by your own interests, rights and freedoms).

“Performance of a Contract” means the necessary Processing to carry out our contractual duties, exercise our contractual rights or otherwise perform our contract with you, or to take steps at your request to enter a contract.

“Personal Data” means any data relating to an identified or Identifiable Natural Person.

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Special Categories of Personal Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data processed for the purpose of uniquely identifying a natural person, data concerning vital interests, i.e., Processing necessary protect an interest which is essential for the life of the data subject or that of another natural person.