PRIVACY POLICY

 

IPath Consult Co., Ltd. and all its subsidiaries and affiliates around the world (hereinafter referred to as "IPath", "we", and "our") clearly understand how important privacy is for you and respect your privacy. Please carefully read this Privacy Policy before submitting your personal data to IPath.
The purpose of this Privacy Policy is to help you understand the following:
  • About this Privacy Policy
  • What Personal Data We Collect
  • Why and How We Collect and Use Your Personal Data
  • How We Disclose Your Personal Data
  • How Your Personal Data is Retained?
  • How to Access, Revise and Erase Your Personal Data
  • How We Protect Your Personal Data
  • Children’s Privacy
  • Third-party Providers and Their Services
  • How Your Personal Data is Transferred Across Border?
  • How This Policy Will Be Updated?
  • How to contact IPath
1. About this Privacy Policy
This Privacy Policy applies when you visit or use our websites, apps and other services, including events, that refer or link to this privacy policy (each, a "Service"). This privacy policy may be supplemented by additional privacy Policys, terms or notices provided to you. IPath company that owns or administers the Service, as identified therein, is the primary controller of your personal information provide to, or collected by or for, the Service.
We will indicate within the registration processes of our products and services and other registration forms what types of personal information are required and those that are requested. You may choose not to submit the requested information, but that may limit or prohibit the services that IPath is able to provide to you.
2. What Personal Data We Collect
We collect information about you in three ways: directly from your input, from third-party sources, and through automated technologies.
2.1 Data You Provide to UsThe types of personal information that we collect directly from you depends on how you interact with us and the Service, which may include:
  • Contact details, such as your name, email address, postal address, social media handle, and phone number;
  • Account login credentials, such as usernames and passwords, password hints and similar security information;
  • Other account registration and profile information, such as job title, educational and professional background and qualifications, and photo;
  • Payment information, such as a credit or debit card number;
  • Comments, feedback and other information you provide to us, including search query data and questions or information you send to customer support; and/or
  • Interests and communication preferences, including preferred language.
2.2 Data From Your Organisation
We may obtain personal information about you from the organisation with which you are employed or affiliated in order to activate and manage your access to and use of the organisation’s subscription to the Service, including:
  • Contact details, such as your name and organizational email address, postal address, and phone number;
  • Other account registration information such as job title; and/or
  • Organizational user ID
2.3 Data From Other Sources
We also may obtain contact details and other information about you from our affiliates and from other third parties, including:
  • Social networks when you grant permission to the Service to access your data on one or more networks;
  • Service providers that help us determine a location in order to customize certain products to your location;
  • Businesses with which we offer co-branded services or engage in joint marketing activities; and/or
  • Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.
2.4 Data From Service Use, Including Cookies
The Service may automatically collect information about how you and your device interact with the Service, including:
  • Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
  • Usage data, such as the features you used, the settings you selected, your URL click stream data, including date and time stamp and referring and exit pages, search terms you used, and pages you visited or searched for on the Service;
  • For educational Services, the course modules and test questions you view, answer or complete; and/or
  • For location-aware Services, the region, city or town where your device is located in order to provide you with more relevant content for where you are in the world.
We collect this data through our servers and the use of cookies and other technologies. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. We may use cookies and other technologies to store your preferences and settings, help you with signing in, provide targeted ads and analyse site operations. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the Service. For more details, see the cookie policy of the Service.
3. Why and How We Collect and Use Your Personal Data 
Depending on how you interact with us and the Service, we use your personal information. to:
  • Provide, activate and manage your access to and use of the Service;
  • Process and fulfil a request, order, download, subscription or other transaction;
  • Provide technical, product and other support and to help keep the Service working, safe and secure;
  • Enhance and improve the Service and our other products, events, and services and to develop new products, services and benefits;
  • Offer you customized content and other personalization to make the Service more relevant to your interests and geography;
  • Respond to your requests, inquiries, comments and concerns;
  • Notify you about changes, updates and other announcements related to the Service and our other products and services;
  • Deliver targeted advertisements, promotional messages, notices and other information related to the Service and your interests;
  • Provide you with promotional messages and other information about products, events and services of ours, our affiliates and third parties such as sponsors;
  • Invite you to participate in user testing and surveys as well as drawings, sweepstakes, competitions and similar promotions;
  • Identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance, or in other ways pursuant to a customer agreement; and/or
  • Comply with our legal obligations, resolve disputes, and enforce our agreements.
If you are an administrator of an organisation with a subscription to the Service, we will use your details to communicate with you about your organisation’s subscription and related services. If you supply us contact information of your colleagues, we may contact those individuals with communications about the Service that may include reference to you.
4. How We Process and Disclose Your Personal Data 
When we collect or otherwise process any personal information within the scope of European data protection laws, we do so:
  • where necessary to provide the Service, fulfil a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
  • where necessary for our compliance with applicable law or other legal obligation;
  • where necessary for the performance of a task carried out in the public interest;
  • where necessary to enable our customers to comply with their legal obligations;
  • where applicable, with your consent; and/or
  • where necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, or fulfil our other legitimate interests as described in sections 2-4 above, except where our interests are overridden by your privacy rights.
Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.
4.1 Your Organisation
If you access the Service through a subscription administered by your organisation, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorised by your organisation for the purposes of usage analysis, subscription management and compliance, training course progress, performance and remediation, cost attribution and departmental budgeting.
4.2 Application Licensor
If you access a third-party application on the Service through a license agreement with the licensor of that application, personal information relevant that third-party application may be shared with the licensor so that it can provide you access to the application, subject to the terms of its license agreement and privacy policy.
4.3 Our Group Companies and Service Providers
Dependent upon the Services provided, we share information with:
  • Our affiliates, trading names and divisions within the LexisNexis group of companies worldwide and certain RELX Group companies that provide technology, customer service and other shared services functions; and/or
  • Our service providers, suppliers, agents and representatives, including but not limited to, payment processors, customer support, email service providers, event venues and service providers, IT service providers, marketing service providers, research providers, mailing houses and shipping agents;
to process the information as necessary to provide the Service, complete a transaction or fulfil your request or otherwise on our behalf based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures.
4.4 Your Choices
We may share your personal information with our affiliates and with sponsors, joint venture entities and other third parties, including entities for which we are acting as an agent, licensee, application host or publisher, that wish to send you information about their products and services that may be of interest to you, as determined by your choices in managing your communications preferences and other settings.
The Service may let you post and share personal information, comments, materials and other content. Any such contributions that you disclose publicly may be collected and used by others. Please be careful when disclosing personal information in these public areas.
4.5 For Legal Reasons
We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:
  • meet any applicable law, regulation, legal process or other legal obligation;
  • detect, investigate and help prevent security, fraud or technical issues; and/or
  • protect the rights, property or safety of LexisNexis, our users, employees or others; and
  • as part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company
5. How Your Personal Data is Retained
IPath uses reasonable procedures to ensure that we archive or destroy personal data that is not required for the ongoing administration of the administrative services or the other purposes described in this Policy (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). Records will be periodically reviewed and archived or properly disposed of according to the I Path’s personal data retention policy for logistics services.
Personal data may be archived to meet legal requirements, for research purposes, or to facilitate long-term storage. 
6. How to Access, Revise and Erase Your Personal Data 
Please ensure that all personal data you submit is accurate. IPath will take reasonable and appropriate actions to ensure the accuracy and integrity of your personal data and to promptly update the data when necessary.
6.1 Your Account
The Service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is the responsibility of the user. Registered users may also close their account directly through the Service or by contacting the Service’s customer support.
6.2 Your Rights
You have the right under European and certain other privacy and data protection laws, as may be applicable, to request free of charge:
  • access to your personal information;
  • rectification or erasure of your personal information;
  • restriction of our processing of your personal information, or to object to our processing; and
  • portability of your personal information.
For security purposes, please note that any such communication should be in writing. When requesting access to your personal data, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal data that we hold about you. If we have a reasonable suspicion that a request is fraudulent, or would infringe the right to privacy of another individual, we may reject your request.
If allowed by applicable laws, you have the right to withdraw your consent at any time when IPath processes your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent, including the fact that the personal data may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal data, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions. 
7. How We Protect Your Personal Data 
IPath takes the security of personal data seriously. We take appropriate physical, organizational, and technical measures to protect your personal data from unauthorized access or use, improper disclosure, tampering, destruction, or loss. For example, for certain data, we use encryption to ensure data security; we take protective measures to prevent malicious attacks; we deploy access control mechanisms to ensure that only authorized persons can access your personal data. We also organize training on data security and privacy to help employees better understand the importance of protecting personal data. We will retain your personal data only for as long as necessary for the purposes described in this Policy, unless there is a legal basis for us to extend the retention period. We will do all we can to protect your personal data, but please be aware that no security measures can prevent all possible attacks.
8. Children’s Privacy
We do not knowingly collect information from children under the age of 13 or target the Service to children under 13.
9. Third-party Providers and Their Services 
You may receive content and links from IPath and third-party service partners ("Third Parties"), so that you can enjoy comprehensive services. IPath does not control content provided by Third Parties. You may choose whether to visit linked websites, content, products, and services provided by the Third Parties.
This Policy is not applicable to Third Parties, since IPath does not control their privacy/data protection Policies. Before submitting your personal data to any Third Party, please carefully read their privacy/data protection Policies. 
10. How Your Personal Data is Transferred Globally 
IPath is a global company, which means personal data collected by IPath for the purposes of internal management and offering you services may be processed by IPath, or an associated company, subsidiary, or service provider in another country or region; or may be accessed from other countries and regions. Data protection laws in other countries/regions may differ from the law of the country/region where your personal data originated. In this case, IPath will ensure that your data is adequately protected by all applicable legal and regulatory requirements and will take action to ensure that the data we have collected will be processed in compliance with this Policy and with local law. 
11. How This Policy Will Be Updated 
IPath reserves the right to update or amend this Policy as required. In the event of any changes, we will publish the up-to-date version of this Policy without delay. 
12. How To Contact Us 
Please contact us vis email support@pathlaw.net for any queries or problems.
 
Last updated: July 25, 2019.