SPIN/IDG Wakhan Media , publishing arm of the NCC-RP Group (SPIN,” IDG Pakistan/Wakhan,” “we,” “us,” or “our”) believes in the importance of earning and maintaining your trust. As such, we are committed to protecting your privacy rights. This Privacy Statement (“Statement”) provides notice of how we collect, use, share, or otherwise processed information relating to natural persons (“Personal Data”), and about how you may exercise your applicable rights regarding such Personal Data.
I. Scope and Applicability
This Statement applies to Personal Data processed by SPIN Media when you:
- Visit this website (www.smartpakistan.network) and/or any other SPIN Media website(s) which reference or link to this Statement (collectively, “Website”);
- Use, download, or access, as applicable, any of our various internet-based offerings, including any paid or non-paid subscriptions, newsletters, mobile platforms, webinars, briefings, programs, software, or applications (collectively, “Services”);
- Apply for a job with us;
- Engage with SPIN on or through social media sites;
- Communicate with us, including by email, phone, or other means
- Attend or register for any of our events, conferences, networking/community offerings, etc.; or
- Otherwise communicate or engage with us.
This Statement applies whether you have provided Personal Data to us directly or whether we have obtained Personal Data indirectly, including from a different source, such as a third party. This Statement may be supplemented by additional privacy notices provided to you.
Notwithstanding the foregoing, if you or your organization has previously entered into a separate, written agreement with SPIN Media governing your existing use of the Services (“Subscriber Agreement”), any conflicting privacy terms of the Subscriber Agreement shall control as set forth therein.
It is important to understand that the Website and the Services may contain links to sites or offerings operated by individuals or entities other than SPIN Media. Such links, where applicable, are provided for your reference and convenience only. We are not responsible for the content or operation of such sites or offerings, nor the security or privacy of any information collected by such third parties. You are solely responsible for determining the extent to which you may use any such content, and you should review the corresponding privacy policies applicable to these third-party sites or offerings.
II. Information We Collect
We may collect certain Personal Data directly from you (e.g., via web forms you complete or products or Services you access, download, or otherwise obtain). Such information may include:
- Name, job title, contact details, and company or organization;
- Your communications with SPIN personnel;
- Content you post on our social media pages;
- Information you provide on the Website, such as online questionnaires, or feedback forms;
- Information you provide when you subscribe to email newsletters such as your interest in specific SPIN research areas;
- Responses to surveys or other such best-practices studies;
- Information you provide when registering for a free trial account;
- Log-in credentials and information about your use of and preferences for the Services;
- Information provided or obtained in relation to a job application, including professional and education information; and
- Limited billing information, collected and used strictly for billing purposes only, is not shared or used for any other purposes, and is and will be processed in accordance with all applicable laws. To be clear, SPIN Media almost never collects billing information from individuals, as typically our offerings are paid by your company or organization (”SPIN Media Customer”).
Other information may be obtained indirectly from you via your use of the Website or the Services. Such information may include:
- Information regarding usage of the Website or Services via web logs collected automatically and passively using various technologies, which may or may not specifically identify you or other individuals. Examples may include IP addresses, browser types, domain names, and other anonymous statistical data regarding aggregate usage;
- Information provided by your employer or organization, such as name, email, other contact information, job title, etc., in order to activate and manage your access to and use of the organization’s subscription to the Services.
If you register for, or attend one of our events, conferences, networking/community offerings, we may:
- Scan an attendee badge or QR code, which will provide contact information such as your name, title, company name, and email address;
- Record or otherwise broadcast conference presentations or locations; and
- Collect information regarding dietary requirements or any reasonable accommodation needed to attend and enjoy the event.
Lastly, we may also collect Personal Data via other sources such as public records, publicly available sources or internet sites, vendors, data suppliers and service providers, commercially available marketing lists or registries, telephone directories, social networks (such as LinkedIn), news outlets and related media. Such Personal Data collected via these sources is typically limited to business contact information, such as names, contact information, job titles, and LinkedIn and other social media profiles.
III. Use of Cookies, Tracking Technologies, and other Electronic Tools
A “cookie” is a small text file with a unique identifier placed on a browser or online device, used to collect limited information about your online preferences and increase website efficiency. When you visit the Website, SPIN or one of our authorized third parties may place a cookie on your browser and/or device. We also use web beacons in some email communications. SPIN uses such cookies and other tracking technologies to manage your preferences, customize and deliver content and advertising, provide social media features, and examine usage information pertaining to Website visits.
We may use both “session cookies” (which disappear once the browser is closed or computer is turned off) and “persistent cookies” (which remain in operation until deleted). You may manage website cookies in your relevant browser settings or by adjusting your cookie preferences here or via the pop-up at the bottom of the Website, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain Website or Services functions and features will not work as intended.
The following describes how we may use different categories of cookies and similar technologies:
Required or essential cookies. These cookies are necessary for the Website’s basic operations and there are no options to disable. For example, session cookies needed to transmit the Website, authentication cookies, and security cookies.
Social media cookies. These cookies allow users to share our Website or materials on social media sites. Because these cookies are not within our control, you should refer to each social media site’s respective privacy policies to understand how they work.
Advertising cookies. These cookies track activity across websites in order to understand a viewer’s interests, and to direct specific marketing to them. SPIN Media may now or in the future elect to contract with third-party advertising networks that collect IP addresses and other information from web beacons on our websites, from emails and on third-party websites.
Analytics cookies. These cookies measure interactions and engagements with our Website and record information, such as page visits, time and approximate location of users, and user interactions with the Website, which allow us to better understand the use of our Website and make improvements.
Functional cookies. These cookies help us customize our website content based on a user’s preferences. They remember the user’s choices, their language, the country pages visited and any changes the user makes to text size or other parts of our website pages. The information these cookies collect may be anonymized and they cannot track browsing activity on other websites.
By using the Services, we may also receive certain third-party cookies located on your computer or device. Third party cookies are those placed by websites, services, and/or parties other than SPIN Media. Third party cookies may be used within the Services.
The Services use Google Analytics services and YouTube API Services. You may prevent your data from being used by Google Analytics/Youtube API Services by downloading and installing the Google Analytics Opt-out Browser Add-on. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data in connection with Google Analytics here.
IV. Use of Personal Data and Lawful Basis
In accordance with applicable law, we rely on the following lawful bases in processing your Personal Data for the purposes set out below.
- Necessity to perform a contract with you;
- Legitimate interests of SPIN Media or of a third party;
- Compliance with applicable laws, regulations, or legal process; and
- Explicit consent (where required under applicable law) to use your information (where we rely on your consent, you have the right to withdraw consent by contacting us as set forth below).
Such lawful bases are identified for the following common instances:
Administering our Website and Providing Services: Personal Data is processed to perform our contractual obligations, where applicable. In instances where we have not entered into a contract with you, such processing is based on our legitimate interest to manage and promote our business, operate and administer the Website, provide and improve the Services, and to provide requested content or materials (for example, when you request to download one of our reports from the Website or Services).
Customer Registration: In accordance with our contractual obligations or legitimate interest to provide Services, when you register for an account with SPIN Media (whether as a paying client or on a complimentary basis), we may process your Personal Data as needed to register and administer your account, provide technical and client support and training, verify your identity, and send important account, subscription, and Services information.
Support Requests: If you request that SPIN Media contacts you (for example, for free trial access or to learn about our offerings), or if you contact us by other means, we process your Personal Data to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you, or as is required by contractual obligations.
Recruiting and Job Applications: We may use Personal Data for talent acquisition and/or job application evaluation, selection, and processing.
Compliance; Security and Functionality of Website and Services: For our legitimate interests in ensuring adherence to relevant terms, we process your Personal Data to review compliance with the applicable usage. Personal Data is also processed by tracking use of the Website and Services, to perform our contractual obligations, where applicable, to provide a secure and functional experience. In instances where we have not entered into a contract with you, such processing is based on our legitimate interest in promoting the safety and security of the Website, Services, systems and applications and in protecting our rights and the rights of others, whereby we reserve the right to monitor, investigate and report any attempts to breach the security of the Website or Services, verify accounts and activity, and enforce our terms and policies.
Event Registration and Attendance: We process your Personal Data to plan and host events, conferences, networking/community offerings for which you have registered or attend, including sending related communications to you, to perform on our contract with you, or as part of our legitimate interest to operate and improve our events business, enable peer networking opportunities, promote our brand, and collect relevant information for hospitality and health and safety purposes.
Developing Website and Services; Developing Offerings: We process your Personal Data to analyze trends, usage, and interactions with the Website and Services to the extent it is necessary for our legitimate interest in improving the Website and Services, developing new offerings, and providing individuals with tailored content and to personalize your experience with our Services. In certain instances, we will process your Personal Data for such development by directly seeking your input (for example, through surveys).
Improving Services and Offerings: It is our legitimate business interest to improve our Services and offerings through an increase in data provided to our clients to meet their demands; as such, we may process limited Personal Data of business professionals (more specifically, names, professional titles, professional experience, investment details, contact information and educational history).
Identifying Client Interests and Opportunities: Because it is in our legitimate business interest to meet our client demands and ensure positive user experiences, we may process your Personal Data to assess new potential customer opportunities as relevant.
Marketing Communications; Advertising. It is our legitimate business interest to promote our Website and Services, grow our company, and advertise our offerings (whether via direct marketing or providing personalized content advertisements), and as such we will process your Personal Data by sending certain marketing information, product recommendations, custom research, and other communications (for example, newsletters, sales calls, or other electronic communications) solely as necessary to reflect such legitimate interests, or, if applicable, to the extent you have provided your prior consent.
Payments: In the rare instances where you have provided financial information to us, SPIN will process your Personal Data to verify such information and to collect payments solely as needed to complete a transaction and perform our contractual obligations.
Legal Obligations: We may be required to process Personal Data for legal and compliance reasons we believe to be necessary or appropriate under applicable law (which may include laws outside your country of residence). Such processing may be required to: respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities; enforce our terms of service or other terms and conditions; or protect our rights, privacy, safety, or property, or those of other persons.
V. Disclosure of Personal Data
SPIN Media may disclose Personal Data as follows:
Contracted Service Providers. As necessary to provide the Services, conduct our business operations, or when we believe that applicable law permits or requires disclosure, we may disclose Personal Data to contracted service providers, including entities which provide for hosting and system administration, payment processing, analytics, marketing, data enrichment, or client support. These service providers only receive Personal Data necessary to fulfill the services they provide to SPIN. Under no circumstances are such service providers permitted to use Personal Data for any purpose other than to provide SPIN with the designated services.
Your Employer or Organization. To the extent you are an authorized user of the Services or have otherwise registered for SPIN offerings using your corporate email address, we may share Personal Data with your employer or organization to the extent necessary to provide you with access, verify accounts and activity, investigate suspicious activity, or enforce our terms and policies.
Event Sponsors. If you attend a SPIN event, conferences, networking/community offerings, we may share limited Personal Data with certain event sponsors. If you do not wish for your information to be shared, you may choose not to participate in the event, may contact our events team as described in registration communications, or you may write to us as described below.
Mergers or Acquisitions. In the event of a merger, acquisition, consolidation, change of control, corporate divestiture or dissolution, or other corporate transaction where we sell all or a portion of our business or assets, we will disclose necessary Personal Data and such information will be governed by the privacy policies of acquiring entities. In accordance with applicable laws, we will notify you of any transfer of Personal Data to an unaffiliated third party.
Advertising Network Partners. We may disclose information collected automatically and passively using various technologies through our Website to advertising partners to target you with advertising.
Public Forums: If any part of the Website or SPIN branded social media sites permit public forum posting, the Personal Data you choose to post, share, upload, or make publicly available may be visible to others. You should never post or share any information that is confidential or about others unless you have permission to do so. We may use information you provide to personalize your experience and to make content recommendations.
Published Information: We may provide limited information of leadership teams and key personnel to other business professionals through our Services.
Legal and Compliance. We may disclose Personal Data to third parties in relation to compliance with laws, regulations, and legal processes.
VI. Location of Processing
SPIN Media is solely located in, and operates from, the United States. However, some of our service providers referenced above may process Personal Data outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator (including India and Ukraine), and that may not provide the same level of data protection as your jurisdiction. We ensure that Personal Data subject to transfers to third countries continues to be protected in a manner consistent with the standards of protection required under applicable law, for instance by entering into the appropriate standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR).
VII. Minors
SPIN Media Services are solely intended for business clients and are not directed at minors. We do not knowingly collect Personal Data from children under the age of 18. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us as set forth below in Section XI, and we will take steps to delete such Personal Data from our systems.
VIII. Retention Periods
SPIN Media retains Personal Data for a period commensurate with the purpose for which the Personal Data was obtained. In addition, retention periods may be determined by other criteria, such as the nature and sensitivity of the Personal Data, including any potential risk of harm which could arise out of unauthorized use or disclosure, as well as whether additional legal/regulatory obligations require us to retain it.
IX. Your Privacy Rights
Depending on the laws that apply to you, you may have certain rights regarding your Personal Data. These rights may include:
- Right to access your Personal Data and correct inaccuracies. You may have the right to access Personal Data we maintain about you and, in most circumstances, to be provided with a copy of this information. You may also have the right to correct any inaccuracies relating to your Personal Data within our control.
- Right to restrict use. To the extent permitted by applicable law, you may have the right to restrict our processing of Personal Data.
- Right to deletion. You may have the right to request that we delete Personal Data we maintain about you. Please note, if you prefer to only opt-out of marketing communications, then we may retain your Personal Data with a strict “do not contact” mark applied, to ensure we do not contact you in the future for marketing purposes.
- Right to object to processing. Where we process your Personal Data on the basis of our legitimate interests or the legitimate interests of a third party (e.g., direct marketing purposes), you may have the right to object to such processing without having to provide any specific reason for such objection. Where required by applicable law, we will stop processing your Personal Data until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms, or in limited cases, where we need to continue processing the data for the establishment, exercise, or defense of legal claims.
- Right to withdraw consent. To the extent we base the processing of your Personal Data on your consent, you may have the right withdraw consent without affecting the lawfulness of the processing based on such consent before its withdrawal.
- Right to data portability. In some instances, you may have the right to receive all Personal Data you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, to the extent such transfer is technically feasible.
How to exercise your rights
Any requests should include information to allow us to verify your identity (e.g., your name, address, email address, or other information reasonably required. We respond to any legitimate requests within one month. In the event we require additional information, we will contact you and specify what is needed. In certain circumstances, it may take longer than one month, for example if we receive overly complex or numerous requests or in the event we do not receive the required additional information.
Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Marketing Communication Preferences
Regarding electronic marketing communications, you may manage your receipt of the same by clicking on the “unsubscribe” or other equivalent link located on the bottom of any marketing or sales emails, visit the applicable email preference center, or contact us. As pertaining to sales calls, if you want your phone number to be added to our internal Do-Not-Call list, please contact us as described below in Section XI (please include your first name, last name, company and the phone number you wish to add to our Do-Not-Call list).
We will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
SPIN Media and its parent company, reserves the right to change this Statement at any time by posting revisions on the Website. Such changes will be effective upon posting. Where required by applicable law, we will obtain your consent prior to making material changes to the way your Personal Data is processed. We encourage you to regularly review this Statement to stay informed about our processing of your Personal Data.