Privacy Policy
Privacy Policy For foreignpolicy.com
Effective date: December 20, 2023
Foreign Policy, (“FP”, “we” or “us,”) is committed to protecting the privacy of our subscribers and visitors to the website foreignpolicy.com (the “Site”). Visitors to the Site may view certain limited content without providing any personal information. Visitors who wish to view or subscribe to additional content may voluntarily register or subscribe as described on the Site and in this Privacy Policy.
Contact Information
If you have any questions about this Privacy Policy, questions or complaints about the collection, use and processing of your personal information, please contact us by postal mail or email at:
Foreign Policy, 655 15th St NW, Suite 300, Washington, DC 20005
What is Covered by this Privacy Policy
This Privacy Policy applies to users of this Site (“users”), which includes any person who accesses our Site. Users may be referred to in this Policy as “user,” “you” or “your.” The Terms of Use for the use of our Site are posted at https://foreignpolicy.com/termsofuse. The Site is operated by Foreign Policy, a division of Graham Digital Holding, LLC. This Privacy Policy applies to the use of personal information collected by us online, and offline if you subscribe offline, as described in this Policy.
Purposes of Processing
FP processes personal information to: (i) process your registration or subscription and enter into a contract, (ii) when you provide your explicit consent, (iii) for our legitimate business interests such securing and protecting the integrity of this Site, and for Site and product development; and as permitted to meet by applicable legal requirements.
Registrations
The minimum information we need to register you to our Site is name, email address, login ID, and password. Registering for the Site and subscribing to our content are completely voluntary. If you do not provide the required information, we may not be able to process your registration or subscription. During the registration process, you will have the ability of choosing to opt-in to receiving promotional emails, e-newsletters, and to access certain content on the Site. At any point in time, you can choose to unsubscribe to these email communications by contacting us at the location in the Contact Information section.
Subscriptions
When you subscribe to FP online, we collect the same information required for registered users (items are listed in the Registration section of this Privacy Policy). You may also be asked for additional information such as your postal address in order to deliver the requested items in our FP subscription and to manage your account. We also request information such as your job title and company in order for us to learn more about our customer base and to tailor our offerings. During the subscription process, you choose the level of access you want to our Site and are given the ability to choose to opt-in to receiving e-newsletters. By choosing to purchase a subscription you are entering into a contract with us.
How We Collect and Use Your Personal Information
Credit or debit card information and personal financial account information is considered “Sensitive Information.” We do not directly collect credit card, debit card or personal financial account information when you subscribe to our content, because we use a third-party vendor, Braintree Payment Services, via a third-party fulfillment vendor to process our subscription billing. When you provide payment information to subscribe to our content you provide it directly to Braintree Payment Services and not to foreignpolicy.com. Braintree Payment Services is a third-party vendor and has its own privacy policy, which may be different from ours. This Privacy Policy does not cover Braintree Payment Services and foreignpolicy.com is not covered by Braintree Payment Services privacy policy. To learn about Braintree Payment Services privacy practices, please read their privacy policy at https://www.braintreepayments.com/legal/braintree-privacy-policy.
When you register for the Site or subscribe to our content, we collect your IP address for analytic purposes. If you have access to the Site through a business or employer account, we use your IP address to identify you with the account so you may access the Site.
We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site if you connect to our Site through that site.
Our collection of your personal information is limited to the collection of necessary and adequate information required to accomplish the purposes described in this Privacy Policy.
When you provide personal information, it is being provided directly by you to us, unless we receive it from publicly available sources such as a social media site.
If we are involved in a reorganization, merger, acquisition, bankruptcy or sale of our assets, your personal information may be transferred as part of that transaction. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.
Marketing Communications
You may receive marketing emails from us, only if you agree to do so. Before sending any marketing communications we will make it clear to you during the registration or subscription process to check boxes or otherwise to “opt in” to receiving marketing emails and providing you the ability to change your preferences if you no longer want to receive them. We also may email you occasionally with information or questions about your registration or your subscription account with reminders, warnings, or other types of requests. We will collect and use individual user details if we have your permission or we have a legitimate interest for doing so, for example, collecting enough information to manage your subscription.
How do we Protect Your Personal Information?
We implement a variety of security measures to maintain the safety of your information when you enter, submit, or access your information online. We implement reasonable technical and organizational measures designed to protect your personal information against accidental or intentional destruction or loss, and unauthorized disclosure or access.
Product, content, and subscription purchases made on foreignpolicy.com are directed through a secure transaction server to protect your personal and financial information.
International Transfers of Personal Information
Please be aware that the personal information we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store personal data in the United States. Foreign Policy has executed standard contractual clauses to legitimize these data transfers.
Data Storage and Retention
Your personal information is stored on our servers and on the servers of database management service providers that we have engaged which are located in the United States. We retain data for the duration of the relationship you have with us.
Third Party Sites and Links
Our Site may contain links to or features of other websites that are independent, are not owned or operated by us and which may incorporate Third Party Information. The collection of information by third party websites is not covered by this Privacy Policy and such third-party websites may have their own separate and independent privacy policies. If you access other sites or features using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours. We therefore have no responsibility or liability for the content and activities of other websites, even if they are linked to our Site. In addition to collecting information directly from you, these third-party businesses may use tracking technology to measure the effectiveness of their ads, personalize or optimize advertising content, and track users who click on the links made available through the Site. When you use or interact with our Site, these third-party businesses may collect information about you, including your online activities over time and across third-party websites or online services. We are not responsible for the privacy practices of these third parties and we encourage you to read their privacy policies, which may apply to these third-party programs.
Use of Cookies
When you visit our Site, you will be provided with a notice of our use of cookies while you visit the Site. We use cookies — a piece of information stored on your computer — to allow us to uniquely identify your browser while you are logged in and to enable us to process your online transactions. Cookies also help us confirm your identity and are required in order to login into your account. Users who disable their web browsers’ ability to accept cookies will be able to browse our Site, but they may not be able to access all or parts of our Site. There are also other reasons we use cookies on our site:
- For statistical purposes. For example, we track how many users we have and how often they visit the Site and which pages are the most frequently visited.
- We sometimes use other organizations to collect anonymous user information through cookies and web beacons (information embedded in images which allow them to analyze how the website is being used and the number of visitors).
- We and other advertisers use cookies to track who has seen an advertisement and clicked on it.
- Placing cookies on your computer so we can show you advertisements you might be interested in, allowing us to control the number of times you see them and measure how effective the advertising campaign has been.
- Using cookies to suggest and deliver content which we believe may interest you.
The use of cookies by our partners is not covered by our Privacy Policy. We do not have access or control over these cookies. For more information about cookies and managing them, including how to turn them off, please visit https://foreignpolicy.com/cookie-management/ or contact us at [email protected].
We currently use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit www.google.com/policies/privacy/partners/.
Advertisement Choices
Online advertising for our Site is delivered by multiple third-party vendors. For example, one of these types of vendors is Google’s DoubleClick. DoubleClick places cookies on your browser to facilitate serving particular ads. For instance, to help determine whether you have seen a particular advertisement before, to tailor ads to you if you have visited our Site before, and to avoid sending you duplicate advertisements. You can opt out of these vendors use of cookies for these purposes by contacting them directly. To receive a list of the third party vendors that deliver online advertising to our Site, please contact [email protected].
In some cases, we and advertisers on our Site and other sites work with other third-party vendors to help deliver advertisements tailored to your interests. These vendors include ad networks and audience segment providers, and they place cookies on your browser to collect information about your online activity (e.g., the sites and pages you have visited) in order to help advertisers deliver particular ads on our Site and other sites that they believe you would find most relevant. You can opt out of those vendors’ use of cookies to tailor advertising to you by visiting http://www.aboutads.info/.
Website Log Files
As is true of most Websites, we and our third-party utility-tracking partners gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and click stream data.
We use this information to analyze trends, to administer the Site, to track users’ movements around the Site and to gather demographic information about our user base as a whole.
Sharing of Your Personal Information
We do not sell, share or disclose your personal information to third parties other than those parties necessary to fulfill your registration or subscription. These include trusted third parties that provide services on our behalf, including Site development, maintenance and support, fulfillment, payment processing, and email distribution.If you have registered for or attended one of our in person or virtual events, we may share your name and company name – but never your email or contact info – with our event partners.
Children under the age of 16
Our product and services are not directed to, and we do not knowingly collect personal information from, individuals under the age of 16. If a child is accessing services without your consent, please contact us by using the information provided in the Contact Information section of this Privacy Policy so that we can remove any personal information provided.
Social Media
Please be aware that any information that you submit to a social media site such as Facebook, Instagram or Twitter is done at your own risk and without any expectation of privacy. Foreign Policy cannot control the actions of social media site users and is not responsible for any content or submissions contained on such sites. You should always review the privacy policy of any third-party site or application.
By using any functionality that permits submissions to social media sites, you are indicating that you have reviewed the applicable privacy policy and terms of use of that site. While we offer functionality through our Site that permits the posting of content on social media, please be aware that these sites may allow you to publicly post and share this content. Foreign Policy cannot guarantee the privacy and safety of these sites and is therefore not responsible for any content you post. Use these features at your own risk.
Accuracy of Personal Information
While we take various steps to ensure the accuracy and completeness of your personal information, we rely upon you to provide accurate and complete Information when interacting with us.
Your Rights in Connection with Your Personal Information
If you are in the European Union (EU), European Economic Area (EEA), Switzerland or the UK, under certain circumstances, and as required by applicable law you have the right to:
- Request access to your personal information. This enables you to receive a copy of the personal information we hold about you.
- Request correction of any incomplete or inaccurate personal information that we hold about you.
- Request erasure of your personal information when there is no need for us continuing to process it or you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information to suspend the processing, for example if you want us to verify its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to exercise any of these rights, please contact the Data Protection Officer in writing per the ‘Where to turn with questions’ section of this Policy. Valid requests will be honored within 30 calendar days of request. This 30-day period may be extended for another 2 months for complex requests with notification of the reasons for the extension to you. Any such requests should be submitted using the information listed in the Contact Information section.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. In addition, there may be requests that we are unable to process because of other EU/EEA/Swiss legal requirements. If a request is denied, we will notify you of the reason.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you are located in the EU, EEA, Switzerland or UK you have the right to lodge a complaint with an EU or the UK Supervisory Authority. However, if you have a complaint regarding the processing of your personal information we request that you first contact us and we will reply on timely basis.
If you have a rights request, please contact us using the information in the “Contact Information” section of this Privacy Policy.
Data Controller
As it pertains to users of this Site located in the EU, the controller of your personal information is Foreign Policy.
Data Protection Representative Contact Information
If you are located in the EU, EEA or Switzerland:
Kaplan Ireland Education Limited
Attn: EU/EEA Data Protection Representative
13/14 Aungier Street, Dublin 2, D02 WC04 Ireland
If you are located in the UK:
Kaplan UK Limited
Attn: UK Data Protection Representative
Palace House, 3 Cathedral St, London SE1 9DE, England
Your California Privacy Rights
This Privacy Notice and Policy is provided by Foreign Policy and applies solely to residents of the State of California. Any terms defined in the CCPA and the proposed regulations have the same meaning when used in this disclosure.
Information We Collect
We collect personal information that you provide us. Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. (“personal information”, “PI”).
We have collected the following categories of personal information within the last twelve (12) months and may use or disclose the personal information for one or more business or commercial purposes:
- Identifiers and personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). We collect your name, email address, login ID, password, and country from you to register for the Site and subscribe to our content.
- Internet or other similar network activity. When you register for the Site or subscribe to our content, we collect your IP address for analytic purposes. If you have access to the Site through a business or employer account, we use your IP address to identify you with the account so you may access the Site. We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site if you connect to our Site through that site. We use cookies — a piece of information stored on your computer — to allow us to uniquely identify your browser while you are logged in and to enable us to process your online transactions. Cookies also help us confirm your identity and are required in order to login into your account. There are also other reasons we use cookies on our site:
- For statistical purposes. For example, we track how many users we have and how often they visit the Site and which pages are the most frequently visited.
- We sometimes use other organizations to collect anonymous user information through cookies and web beacons (information embedded in images which allow them to analyze how the website is being used and the number of visitors).
- We and other advertisers use cookies to track who has seen an advertisement and clicked on it.
- Placing cookies on your computer so we can show you advertisements you might be interested in, allowing us to control the number of times you see them and measure how effective the advertising campaign has been.
- Using cookies to suggest and deliver content which we believe may interest you.
As is true of most Websites, we and our third-party utility-tracking partners gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and click stream data. We use this information to analyze trends, to administer the Site, to track users’ movements around the Site and to gather demographic information about our user base as a whole.
- Professional or employment-related information. We collect your job title and job industry from you to register for the Site and subscribe to our content in order for us to learn more about our customer base and to tailor our offerings.
We do not collect the following categories of personal information: Protected classification characteristics under California or federal law, commercial Information, biometric information, geolocation data, sensory data, non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) or inferences drawn from other personal information.
If we are involved in a reorganization, merger, acquisition, bankruptcy or sale of our assets, your personal information may be transferred as part of that transaction. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.
Sharing Personal Information
We may disclose your personal information to a third party or service providers for a business purpose as described above. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except for fulfilling requirements and services being performed under contract. If you have registered for or attended one of our in person or virtual events, we may share your name and company name – but never your email or contact info – with event partners.
We do not sell personal information and in the preceding twelve (12) months we have not sold any personal information.
Your Rights
Under certain circumstances, and as required by the CCPA you have the right to:
- Request to Access Your Personal Information (Right to Know)
- You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information over the past 12 months.
- To submit a request, please click on the following link and complete the form – https://foreignpolicy.com/ccpa, or send an email to [email protected].
- As part of our verification process of your request we ensure reasonable measures are in place to detect fraudulent requests and prevent unauthorized access to your personal information.
- We are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent by associating the information provided in the request to any personal information previously collected by us or use a third-party identity verification service.
- To verify your identity to process the request, you must provide your full name, email address, and account number.
- Once we confirm your verifiable request we will disclose to you, consistent with your request:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- Specific pieces of personal information we collected about you, if requested.
- Requests to Delete Your Personal Information (Right to Request Deletion)
- You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
- If we deny your deletion request, we will notify you in writing of the reason.
- To submit a request, please click on the following link and complete the form – https://foreignpolicy.com/ccpa, or send an email to [email protected].
- Non-discrimination to exercise your Consumer Privacy Rights.
- You will not be discriminated against Foreign Policy for exercising your privacy rights granted under the
- Designate an authorized agent to make a request granted under CCPA on your behalf.
- If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code sections 4000 to 4465 so that we can verify the identity of the authorized agent.
- Responding to Requests.
- Upon receiving your request to know or a request to delete, we will process your request or notify you if the request requires an extension or will be denied. If we only comply with your response in part, we will explain the reasons why. We attempt to process requests within 45 days after receipt. If we require additional time beyond 45 days, we will inform you of the reason and the extension period. If you have an account with us, we may deliver our response to that account. If you do not have an account with us, we will deliver our response by mail or electronically, at your option. Generally, we do not charge a fee to process or respond to your requests. However, if we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Changes and Updates to the Privacy Policy
We reserve the right to update or change our privacy policy and terms of use at any time. We will post the amended privacy policy and terms of use on this Site. Please check our Site frequently to see the current privacy policy and terms of use that are in effect and any changes that may have been made. The effective date of the Privacy Policy will be posted at the top of the Privacy Policy.
