AIR Summit Holdings, LLC
Introduction - Who we are
AIR Summit Holdings, LLC (“AIR Summit”, “we”, “us” or “our”) is an international community and information group focused on the asset management industry. The group runs a portfolio of events and websites that engage members and other participants around ideas, innovations, and practices that can help an investment manager increase investment performance.
AIR Summit and its group companies are committed to respecting the privacy of every person who visits, registers with or subscribes to our websites, publications, events and other products or services.
AIR Summit is the primary data controller of personal data collected through this website or that we may collect in different ways as described in this Privacy Notice. If you are contacted by our other group companies, they will also be controllers of your personal data. This means that they are responsible for how your personal data is used, just as we are.
You may contact any of these companies directly, or you can contact AIR Summit by emailing firstname.lastname@example.org or writing to AIR Summit Holdings, LLC, 2234 N. Federal Highway #1135, Boca Raton, Florida, 33431, USA
This Privacy Notice was updated on December 17, 2018
Our Approach to Your Privacy
This Privacy Notice outlines the information we may collect about you in relation to your use of our products and services (“personal data”). It also explains the legal rights that you have in relation to your data and how you may exercise these rights.
Some of our group companies may collect and use personal data for different purposes; those companies have their own websites and privacy notices.
We will process your data for the following lawful purposes: with your consent; to fulfil our obligations to you; and where there is a legitimate interest to do so.
When possible, we rely on your consent to use your data for the purposes described in this Privacy Notice. We also process personal data to fulfil our contractual obligations to you, for example, when you register for any of our services, subscribe to a publication, sign-up for an event or purchase a product from us, we will need to process some of your personal data. This will also include details of the person/people responsible for payment (if different).
We may determine that processing your personal data serves both of our legitimate interests. This is the case in relation to many of our research, customer survey, sales, marketing and advertising activities described in this Privacy Notice. These activities allow us to better understand your requirements, which in turn enables us to provide you with a better service. We review the bases for our processing decisions carefully and you can object to these activities at any time (see the “Your Rights” section of this Privacy Notice).
What Personal Data We Collect & Why
Our primary goal in collecting personal data from you is to give you a relevant customized experience of our products and services.
Registration, Free Trials & Subscriptions
When you register with our website and/or sign up for a free trial of our products or services, we may ask you to provide your name, address, email address and telephone number, and details relevant to your occupation or employer.
If you subscribe to one of our products or services, we will also ask for payment details. Credit/debit card payments are processed using a third party supplier and we do not retain the credit card data (see the Third Party Sites of this Privacy Notice). Address details may be shared with third party service providers engaged by us for order fulfilment, delivery and payment collection. This personal data is used by us to complete subscription requests.
Events & Conferences
If you have registered for an event through a group website we may collect personal data including: name, job title, company, address, telephone number and email.
This information is necessary so that we can complete your registration for the event and provide you with relevant event materials.
We may also provide delegate details (e.g. name, email) to event sponsors who, subject to your consent, may contact you for their own advertising and marketing purposes.
Advertising & Marketing
We use the personal data you provide us and which we collect from you to inform you about similar products and services which we provide. We may send you marketing communications that are sponsored by our partners and which are targeted to your interests based on information you have provided us such as job title, employer and/or industry. If you have consented to receive information from other AIR Summit companies, we may share your personal data with these companies so that they can fulfil your request to receive marketing materials in accordance with your preferences. We will not share your personal data with any third parties for their own marketing purposes unless you have provided your consent.
Each of the AIR Summit group companies that may contact you is a data controller in relation to the personal data that you have agreed to share with them. If you have any questions or concerns, you may contact the individual company, or us – using the contact details set out in the “Who We Are” section.
You can opt out from receiving such materials at any time.
The personal data we may use for advertising and marketing purposes includes your name, email address, job title, phone number, company name/employer, geo location, postal address and data collected using cookies and other similar technology.
Marketing materials are sent electronically, by post and we may occasionally call you.
Online Targeted Advertising
We may use targeted advertising on our websites to display advertisements that are relevant to what we believe are your interests. In order to deliver relevant advertisements, we use third parties to deliver cookies that collect information about your IP address and how you interact with our sites (e.g. browsing information, which articles you have read etc.). This data is used by the third parties to determine which advertisements may be of interest to you.
We may also share your personal data with third parties to deliver targeted advertising to you on other websites (e.g. Twitter Tailored Audiences or Facebook Custom Audiences). This could include your email address, cookie data, and information obtained from third parties. Third party cookies may also be used to enable us to target advertisements to you on other websites that you visit.
Lead Generation and Scoring
We may occasionally use the services of trusted third parties in order to ensure that the personal data we use for advertising and marketing purposes is accurate and up-to-date. To do this, we transfer personal data of individual leads (such as name, email, job title, location and phone number) to these third parties who conduct research to verify the data – primarily against public information.
We may also use algorithmic software technology to help us improve the quality and relevance of marketing activities. The personal data analyzed by the software includes email address, phone number, job title, address, purchase history and account information. This allows us to provide meaningful offers that are relevant to your specific profile.
Surveys, Market Research & Customer Feedback
We want to understand the needs of our readers and customers. We may therefore use the information you provide us – including your name and contact details – to contact you to request your feedback, or to participate in our customer and market research.
Public forums, message boards and blogs
Some of the pages on our group websites may include message boards, blogs or other facilities for generating content from users. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to post any personal data. User generated content is also subject to our site Terms and Conditions.
Business or Asset Sale
If we sell a business or assets we may need to disclose your personal data to the prospective buyer of such business or assets.
If AIR Summit, or any of our group companies is sold or sells our assets or is acquired by a third party, then personal data about our customers will be acquired by that third party. A transfer of your personal data in these circumstances would be necessary so that the services you have contracted for can still be delivered, or so that you can continue to enjoy the benefits of our free products and services. You will receive notice if a new controller assumes responsibility for your personal data.
Additional Third Party Disclosures
We may disclose your personal data to other third parties in the following situations:
To third party partners who help us by providing services such as technology, marketing, advisory or other services. These third parties only receive encrypted data and may only process personal data to provide those services to us.
Where we are required by law or regulation to do so. In each case we will seek, where practicable, to minimise the amount of data that is disclosed.
If required to protect the rights and interests of other users and/or AIR Summit and its affiliates (including our employees, agents and contractors), or as otherwise set out in our Terms of Service. This may include exchanging information with other companies and organizations for the purposes of fraud protection.
We may include small pixel tags (small image files) within the emails we send you in order to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. We may also collect browser, location and the device used to engage with our email communications. This information allows us to better understand whether we are meeting our users’ needs and how we can improve our communications. No other information is collected. You can opt out of receiving our direct marketing emails either by following the instructions in each email, or by contacting us (see the “Who We Are” section of this Privacy Notice).
We have a data retention policy that ensures we don’t use or store your personal data for longer than necessary. We consider the following issues to determine retention periods:
The business rationale for collection and expiry of the purpose for which personal data was collected;
Our ongoing ability to ensure the accuracy of the data; and
Legal and regulatory requirements.
We may occasionally need to keep personal data for either shorter or longer periods than specified in our retention policy. In such circumstances, application of the retention period to the data will be temporarily suspended. The suspension of an applicable retention period will be carried out in a manner that respects the rights and interests of all persons concerned.
How You Can Set Your Data & Privacy Preferences
You can use our Preference Centre to select the topics that are of interest to you so that we can send you publications and information about our products and services that are especially relevant to you. You can also choose the channels we use to contact you (email, phone, post, etc.) and can also opt-out of receiving marketing communications.
You have certain rights in relation to your personal data which include the following:
Access & Portability
You may request access to any personal data of yours for which AIR Summit is responsible as controller. Unless there are legal or regulatory reasons for not doing so, we will confirm whether we process any of your personal data and if we do, we will provide you with the following information: the purposes of the processing, the categories of personal data, any recipients of your personal data, the applicable retention period and the data source. Copies of your personal data will be made available to you in a structured, machine-readable format.
You may also request that we transfer the personal data that you have submitted to us, to another controller, where it is technically feasible for us to do so.
If you have consented to our processing of your personal data, or if we are processing your personal data in order to fulfil our contractual obligations to you, then you can submit a request that we transfer your personal data to another data controller.
Rectification, Restriction, Objection
You have the right to request that AIR Summit rectify any errors in the personal data that we process. In some circumstances, you may also be able to ask for the erasure of personal data, and/or request that the processing of your personal data be restricted. You may also object to the processing of your personal data for sales or marketing purposes.
How to Exercise Your Rights
To exercise any of these rights, please contact us by post or email at the following addresses:
AIR Summit Holdings, LLC
2234 N. Federal Highway #1135
Boca Raton, FL 33431 USA
We may need to check your identity prior to processing a request.
AIR Summit will do our best to respond to any questions and address any of your concerns.
Protecting Your Data
AIR Summit is committed to keeping your personal data secure and we will take appropriate technical and organizational measures to protect your personal data from loss, unauthorized use, disclosure or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk. We have therefore implemented information security policies and rules, staff training on information security, and technical measures to ensure the integrity of data that we have under our control.
All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.
Third Party Sites
Our site may contain links to other websites – including, for example, providers of payment processing services. AIR Summit is not responsible for the privacy and data collection practices of third party sites and we therefore recommend that you review the privacy policies and terms of service of each site you visit.