Privacy Policy for Disrupt Mag and Disrupt Symposium

WHO WE ARE

We are Disrupt MAG and Disrupt Symposium, Registered under company name Kolata Un Limited. We’re a company registered in England and Wales with company number 10663591, whose registered address is at 71-75 Shelton Street, WC2H 9JQ, London.

You can get hold of us in any of the following ways:

by emailing us at sara@disruptmag.com; or

by writing to us at 71-75 Shelton Street, WC2H 9JQ, London

Kolata Un Limited. (“Company”, “we”, or “us”) respects your privacy and is committed to protecting it through this Privacy Policy.

This Privacy Policy governs your access to and use of disruptmag.com and disruptsymposium.com, including any content, functionality and services offered on or through disruptmag.com and disruptsymposium.com (the “Website”), whether as a guest or a registered user.

When accessing the Website, the Company will learn certain information about you, both automatically and through voluntary actions you may take, during your visit. This policy applies to information we collect on the Website and in email, text, or other electronic messages between you and the Website.

We take the privacy, including the security, of personal information we hold about you seriously.

We do not have a Data Protection Officer, but if you have any questions about this privacy notice or issues arising from it then you should contact us at sara@disruptmag.com to discuss any matters in this privacy notice. You can also contact us using the details set out above.

We may issue you with other privacy notices from time to time, including when we collect personal information from you. This privacy notice is intended to supplement these and does not override them.

We may update this privacy notice from time to time. This version was last updated on 25th Feb 2024.

Please read the Privacy Policy carefully before you start to use the Website. By using the Website or by clicking to accept or agree to the Terms of Use when this option is made available to you, you accept and agree to be bound and abide by the Privacy Policy. If you do not want to agree to the Privacy Policy, you must not access or use the Website.

KEY DEFINITIONS

The key terms that we use throughout this Privacy Policy are defined below, for ease:

Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.

Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer-base.)

Personal Information: in this privacy notice we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information which has been anonymised.

Special Information – certain very sensitive personal information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life and sexual orientation and also includes genetic information and biometric information.

CHILDREN UNDER THE AGE OF 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at sara@disruptmag.com.

INFORMATION WE COLLECT ABOUT YOU

When you access the Website, the Company will learn certain information about you during your visit.

Information You Provide To Us. The Website provides various places for users to provide information. We collect information that users provide by filling out forms on the Website, communicating with us via contact forms, responding to surveys, search queries on our search feature, providing comments or other feedback, and providing information when ordering a product or service via the Website.

We use information you provide to us to deliver the requested product and/or service, to improve our overall performance, and to provide you with offers, promotions, and information.

DETAILS OF PERSONAL INFORMATION WHICH WE COLLECT AND HOLD ABOUT YOU

Set out below are the general categories and details of retention periods in relation to those categories (see below for more details about retention) and in each case the types of personal information which we collect, use and hold about you:

General Category	Types of Personal Data in that category	Retention Periods
Identity Information	This is information relating to your identity such as your name (including any previous names and any titles which you use)	One year after last action.
Contact Information	This is information relating to your contact details such as e-mail address, addresses, telephone numbers	One year after last action.
Account Information	This is information relating to your account with us (including username and password)	One year after last action.
Payment Information	This is information relating to the methods by which you provide payment to us such as [bank account details, credit or debit card details] and details of any payments (including amounts and dates) which are made between us.	Three years after last action.
Transaction Information	This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details.	Three years after last action.
Survey Information	This is information which we have collected from you or which you have provided to us in respect of surveys and feedback.	Three years after last action.
Marketing Information	This is information relating to your marketing and communications preferences.	Three years after last action.
Website, Device and Technical Information	This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device)	Six years after last action.

The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.

DETAILS OF SPECIAL INFORMATION WHICH WE COLLECT AND HOLD ABOUT YOU

Special information is explained in the section above. We do not collect or hold any special information about you.

We do not collect information from you relating to criminal convictions or offences.

INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGY

As you navigate through our Website, we may use automatic data collection technologies including Google Analytics to collect certain information about your equipment, browsing actions, and patterns. This will generally include information about your location, your traffic pattern through our website, and any communications between your computer and our Website. Among other things, we will collect data about the type of computer you use, your Internet connection, your IP address, your operating system, and your browser type.

The information we collect automatically is used for statistical data and will not include personal information. We use this data to improve our Website and our service offerings. To the extent that you voluntarily provide personal information to us, our systems will associate the automatically collected information with your personal information.

USE OF COOKIES AND PIXELS

Similar to other commercial websites, our website utilises a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.

THIRD PARTY USE OF COOKIES

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW DO WE USE THE INFORMATION THAT YOU PROVIDE TO US?

We use personal information for purposes of presenting our Website and its contents to you, providing you with information, providing you with offers for products and services, providing you with information about your subscriptions and products, carrying out any contract between you and the Company, administering our business activities, providing customer service, and making available other items and services to our customers and prospective customers.

From time-to-time, we may use the information you provide to us to make offers to purchase products and services provided by third parties in exchange for a commission to be paid to us by such third parties. Should you opt to take part in such promotions, the third parties will receive your information.

From time-to-time, we may use the information you provide to us to display advertisements to you that are tailored to your personal characteristics, interests, and activities.

We are only able to use your personal information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below, but in most cases, we will use your personal information for the following legal reasons:

Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you.

Legitimate Interests Reason: this is where the use of your personal information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests.

Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and

Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons.

As explained in section above, there are more sensitive types of personal data which require higher levels of protection. Where we process such sensitive types of personal data we will usually do this in the following circumstances:

We have your explicit consent;
Where it is necessary in relation to legal claims;
Where you have made the personal data public.

So that we are able to provide you with goods and services, we will need your personal information. If you do not provide us with the required personal information, we may be prevented from supplying the goods and services to you.

It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know. If you do not do this then we may be prevented from supplying the goods and services (for example, if you move address and do not tell us, then your goods may be delivered to the wrong address).

Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information, in which case, we will confirm that reason to you.

We have explained below the different purposes for which we use your personal information and, in each case, the legal reason(s) allowing us to use your personal information. Please also note the following:

if we use the Legitimate Interests Reason as the legal reason for which we can use your personal information, we have also explained what that legitimate interest is; and
for some of the purposes we may have listed more than one legal reason on which we can use your personal information, because the legal reason may be different in different circumstances. If you need confirmation of the specific legal reason that we are relying on to use your personal data for that purpose, please contact us using the contact details set out at the start of this privacy notice.

Purpose	Legal Reason(s) for using the personal information
To enrol you as a customer	Contract Reason. Legitimate Interests Reason (in order to offer you other goods, services and/or digital content which is relevant)
To process your order, which includes taking payment from you, advising you of any updates in relation to your order or any enforcement action against you to recover payment.	Contract Reason. Legitimate Interests Reason (in order to recover money which, you owe us)
To manage our contract with you and to notify you of any changes	Contract Reason. Legal Obligation Reason.
To comply with audit and accounting matters	Legal Obligation Reason
For record keeping, [including in relation to any guarantees or warranties provided as part of the sale of goods, services and/or digital content]	Contract Reason. Legal Obligation Reason.
To improve the goods, services, and/or digital content which we supply	Legitimate Interests Reason (in order to improve the goods, services, and/or digital content for future customers and to grow our business
To recommend and send communications to you about goods, services, and/or digital content that you may be interested in. More details about marketing are set out in section 11 below	Legitimate Interests Reason (in order to grow our businessConsent Reason
To ensure the smooth running and correct operation of our website	Legitimate Interests Reason (to ensure our website runs correctly)
To understand how customers and visitors to our website use the website and interact with it via data analysis	Legitimate Interests Reason (to improve and grow our business, including our website, and to understand our customer’s needs, desires and requirements)

Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together with other personal information and you are not identifiable from that combined data we are able to use this.

Under data protection laws we can only use your personal information for the purposes we have told you about, unless we consider that the new purpose is compatible with the purpose(s) which we told you about. If we want to use your personal information for a different purpose which we do not think is compatible with the purpose(s) which we told you about then we will contact you to explain this and what legal reason is in place to allow us to do this.

DETAILS OF HOW WE COLLECT PERSONAL INFORMATION AND SPECIAL INFORMATION

We usually collect Identity Information, Contact Information, Payment Information, Transaction Information, Survey Information, directly from you when you fill out a form, survey or questionnaire, purchase goods, services and/or digital content from us, contact us by email, telephone, in writing or otherwise. This includes the personal information which you provide to us when you subscribe to our mailing list, or enter a competition or survey.

We may receive some of your personal information from third parties or publicly available sources where there is legitimate reason to do so. This includes:

Contact Information and Payment Information from our selected third-party suppliers;
Identity Information and Contact Information from selected data brokers;
Identity Information and Contact Information from publicly available sources such as Companies House;
Website, Device and Technical Information from third parties such as analytics providers (like Google);

We may also receive Website, Device and Technical Information automatically from technologies such as cookies which are installed on our website. To find out more about these please see our cookie policy above.

DETAILS ABOUT WHO PERSONAL INFORMATION MAY BE SHARED WITH

As a general rule, we do not sell, rent, lease or otherwise transfer any information collected whether automatically or through your voluntary action.

We may disclose your personal information to our subsidiaries, affiliates, and service providers for the purpose of providing our services to you.

We may disclose your personal information to a third party, including a lawyer or collection agency, when necessary to enforce our terms of service or any other agreement between you and the Company.

We may provide your information to any successor in interest in the event of a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of the Company’s assets and/or business.

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights or when compelled by a court or other governmental entity to do so.

We may need to share your personal information with other organisations or people. These organisations include:

Third parties who may include:

Suppliers: such as IT support services, payment providers, administration providers, marketing agencies;
Government bodies and regulatory bodies: such as HMRC, fraud prevention agencies;
Our advisors: such as lawyers, accountants, auditors, insurance companies;
Our bankers;
Credit Reference Agencies;
E-mail platforms;
Our Sponsors on Specific Events we organise through Disrupt Symposium. When you sign up to a Sponsored Event, you will be notified that your information will be shared with the Sponsor company prior to sharing your data with us.
Any Organisations which propose to purchase our business and assets in which case we may disclose your personal information to the potential purchaser.

We do not sell or trade any of the personal information which you have provided to us.

EMAIL INFORMATION

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail, and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site. For further information see the email policies below.

EMAIL POLICIES

We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Disclosure of Your Information.

We will maintain the information you send via email in accordance with applicable federal law.

In compliance with the CAN-SPAM Act, all e-mails sent from our organisation will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.

Our emails provide users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any email they receive from us at any time.

Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the email.

HOW AND WHY WE COLLECT INFORMATION

The Company collects your information in order to record and support your participation in the activities you select. If you register to download a book or resources, sign up for our newsletter, and/or purchase a product from us, we collect your information. We use this information to track your preferences and to keep you informed about the products and services you have selected to receive and any related products and/or services. As a visitor to this Website, you can engage in most activities without providing any personal information. It is only when you seek to download resources and/or register for services that you are required to provide information.

If you are outside the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any products sold by the Company on this Website, we will automatically enrol you to receive our free email newsletter. If you do not wish to receive this newsletter, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to team@disruptsymposium.com requesting to unsubscribe from future emails.

If you are in the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any products sold by the Company on this Website, we will only enrol you to receive our free email newsletter if you affirmatively consent to it. If you do not wish to receive this newsletter, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to team@disruptsymposium.com requesting to unsubscribe from future emails.

HOW DO WE PROTECT YOUR INFORMATION AND SECURE INFORMATION TRANSMISSIONS?

We employ commercially reasonable methods to ensure the security of the information you provide to us and the information we collect automatically. This includes using standard security protocols and working only with reputable third-party vendors.  Email is not recognised as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information is never transmitted via email.

The Company may use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.

For site security purposes and to ensure that this service remains available to all users, the Company uses software programs to monitor network traffic to identify unauthorised attempts to upload or change information, or otherwise cause damage.

POLICY CHANGES

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the bottom of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

VISITORS’ GDPR RIGHTS

If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Those rights include:

We will retain the any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) the Company decides that the value in retaining the data is outweighed by the costs of retaining it.

You have the right to request access to your data that the Company stores and the rights to either rectify or erase your personal data.

You have the right to seek restrictions on the processing of your data.

You have the right to object to the processing of your data and the right to the portability of your data.

To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.

You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.

We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.

Under data protection laws you have certain rights in relation to your personal information, as follows:

Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information which we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.
Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
Right to erasure: (this is often called the “right to be forgotten”). This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
Right to data portability: this right allows you to request us to transfer your personal information to someone else.
Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section above) and there is something about your particular situation which means that you want to object to us processing your personal information. In certain circumstances you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing).

In addition to the rights set out in this section, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent.

If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. If you do make a request then please note:

we may need certain information from you so that we can verify your identity;
we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and
if your request is unfounded or excessive then we may refuse to deal with your request.

DETAILS ABOUT TRANSFERS TO COUNTRIES OUTSIDE OF THE EEA

If any transfer of personal information by us will mean that your personal information is transferred outside of the EEA then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information, as is given to it within the EEA and that the transfer is made in compliance with data protection laws (including where relevant any exceptions to the general rules on transferring personal information outside of the EEA which are available to us – these are known as ‘derogations’ under data protection laws). We may need to transfer personal information outside of the EEA to the third parties listed above who may be located outside of the EEA.

The safeguards set out in data protection laws for transferring personal information outside of the EEA include:

where the transfer is to a country or territory which the EU Commission has approved as ensuring an adequate level of protection;
where personal information is transferred to another organisation within our group, under an agreement covering this situation which is known as “binding corporate rules”;
having in place a standard set of clauses which have been approved by the EU Commission;
compliance with an approved code of conduct by a relevant data protection supervisory authority (in the UK, this is the Information Commissioner’s Office (ICO);
certification with an approved certification mechanism;
where the EU Commission has approved specific arrangements in respect of certain countries, such as the US Privacy Shield, in relation to organisations which have signed up to it in the USA.

DETAILS ABOUT HOW LONG WE WILL HOLD YOUR PERSONAL INFORMATION

We will only hold your personal data for as long as necessary. How long is necessary will depend upon the purposes for which we collected the personal information (see section above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). We may also need to keep personal information in case of any legal claims, including in relation to any guarantees or warranties which we have provided with the goods, services or digital content.

We have set out above the details of our retention periods for different types of data. You can find them described in sections above.

AUTOMATED DECISION MAKING

We do not carry out automated decision making.

COMPLAINTS

If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.

THIRD PARTY WEBSITES

Our website may contain links to third party websites. If you click and follow those links then these will take you to the third party website. Those third party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them.

CONTACT US

Kolata Un Limited welcomes your questions or comments regarding the Privacy Policy:

Kolata Un Limited

71-75 Shelton Street

WC2H 9JQ

London.

Email Address: sara@disruptmag.com, team@disruptsymposium.com

Effective as of Feb 25, 2024