Rest of World Privacy Policy
Table of Contents
- Information We Collect
- Information You Provide to Us
- Information Other People Provide About You
- Information We Collect Automatically
- Information We Obtain from Other Sources
- How We Use the Information
- If You Do Not Provide the Information Requested From You
- How We Share the Information
- FORTUNE Analytics (formerly known as FORTUNE Datastore)
- Fortune Live Media Conferences
- Collection of Information by Third Parties
- Links to Third Party Sites or Other Services
- Privacy Options
- Your Rights
- Retention of Personal Information
- Our Commitment to Security
- Cookies and Other Online Tracking Technologies
- Online Advertising
- Choices Related to Online Tracking and Advertising
- Special Note for Parents
- No Automated Decision Making
- Data Protection Officer
- Jurisdiction Specific Supplements
- Changes to this Privacy Policy
- How to Contact Us
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EEA, UK and Switzerland Privacy Policy
For individuals located in member countries of the European Economic Area, Switzerland, and the United Kingdom.
California Notice at Collection and Privacy Notice
For individuals who are residents of the State of California.
For individuals located in the United States of America.
For individuals who live in Canada.
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This FORTUNE Privacy Policy is delivered on behalf of Fortune Media (USA) Corporation and our affiliates (collectively referred to herein as “FORTUNE”, “us”, “we” or “our”) and governs the collection, use and disclosure of personal data of individuals in any country not covered by one of our jurisdiction-specific privacy policies (“you”). It applies to any website or mobile application on which a link to this Privacy Policy appears and any data we collect in connection with delivering the services to you, which may include providing you with online subscriptions and other product offerings whether online or offline (collectively, the “Services”).
Your privacy is important to us. We provide this Privacy Policy to explain our practices for collecting, sharing and using the information you provide to us via our website or mobile applications and by using the Services, and to tell you about the choices you may be able to make regarding the ways in which your information is collected, used and shared. Depending on how you interact with us and where, a Jurisdiction Specific Supplement as set forth in this Privacy Policy may also apply. Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use, and disclose your personal data.
This Privacy Policy also informs you about data we obtain about you from third parties.
We are the “controller” of your personal data, i.e., we decide on the means and purpose of the processing of your personal data and can be reached as set out in the “How to Contact Us” section below. Personal data is any information relating to an identified or identifiable living individual. Please note that the exact definition of and particular terms used may vary depending on the laws and regulations applicable in each jurisdiction. Where required by applicable law, we will first obtain your consent before we collect, use, or disclose your personal data.
Information We Collect
We collect information about you in various ways and from various sources. For example, you may provide personal data directly to us, we may receive personal data about you from someone else, we may collect certain information about you automatically through your use of the Services, or we may obtain information about you from third parties who are acting on our behalf or with whom we cooperate.
Information You Provide to Us
When you use the Services, you may, among other activities, order publications and products; subscribe to FORTUNE Newsletters; apply to attend or register for a FORTUNE conference; apply to become a member of one our membership communities; register to create an online account; subscribe for access to digital and other content; or send communications, post comments and other user-generated content including on communication platforms we may make available to you. The information that you provide to us and that we collect or receive depends on your relationship with us and your interaction with the Services but may include information such as your name, email address, year of birth, address, job title, professional information, telephone number or fax number, your assistant’s name and contact details, and the content of any communications or other content you send or post.. In addition, you may be asked to provide us or one of our third party providers with payment information, such as your credit card or debit card number, where needed, such as when completing a purchase.
We may also collect information about your personal or professional interests, your organization or industry and your use of, or opinions about, various products, programs and services. For instance, we may ask you to identify your job or industry to qualify you for free business magazines.
If you sign up for or participate in a communication platform that we make available to you, we receive the information you have provided about yourself, the content of any communications or other content you send or post in channels. In general, you can choose what information to include in your profile.
Additional information regarding data collection and use related to FORTUNE Live Media conferences appears in the “FORTUNE Live Media conferences” section below.
Information Other People Provide About You
Through some features of the Services, certain promotions, on various portions of the websites and applications on which a link to this Privacy Policy appears, and through correspondence with us, other people may be able to submit information about you to us. For example, someone might submit your name, mailing and/or email address or other information to send you a gift or to nominate you as a speaker at a FORTUNE Conference or to appear in a FORTUNE list, ranking or other publication. The types of personal information that people may provide about you may include your name, address, email address, telephone number, age, gender, professional information such as the organization you work at or your job title, and your achievements. We may use your personal data for the purposes described in the “How We Use the Information” section below. We will notify you of this Privacy Policy when we first contact you or as otherwise permitted or required by applicable law, such as upon our first disclosure of your personal data, or within 30 days from the date we collect your personal data. Where required under applicable law, our lawful basis for processing the personal data submitted to us by another person is performance of the contract with us or steps prior to entering into a contract with us or, as the case may be where permitted under applicable law, our legitimate business interests.
Information We Collect Automatically
We, our partners, advertisers, advertising networks or other third party service providers, as explained further in the “Cookies and Other Online Tracking Technologies” section below, may also automatically collect certain information when you visit our web pages, open our emails, use our applications, or otherwise use the Services. Such automatically collected information may include:
- The type of browser and operating system you are using.
- Your IP address or mobile device identifier.
- The domain name of your internet service provider.
- The date and time of a visit, information about the content you view and the features you access, the number of links you click within the website or applications as well as your activity and behavior on our websites or applications.
- Location-based information regarding the state or country from which you accessed our Services.
- Information regarding the advertisements you have interacted with, viewed, or accessed, such as the number of times you view an advertisement.
This information may be combined and linked with data relating to you from other sources, including personal data, in order to improve our Services and for advertising purposes. Where required and permitted under applicable law, our lawful basis is our legitimate business interest to constantly improve our Services to provide you with information relating to our offerings which might be of interest to you.
Information We Obtain from Other Sources
We may engage service providers to collect information about you on our behalf. For example, as described in the “Fortune Analytics” section below, we may engage third party service providers to collect publicly available information about certain individuals who work at companies that are included on various lists, such as the FORTUNE 500 list. We may also engage entities who assist us in identifying individuals whom we may invite to FORTUNE conferences. Depending on the length of time for which you have been a subscriber, we may have received information about you and your subscription history from entities with which the publication was previously affiliated. If you use certain third-party payment providers to purchase a subscription, we may receive information associated with your account (e.g., billing address) from that provider. We may also collect information from public websites, social media platforms, and business data platforms which collect information about you.
We also receive information from you when you interact with our pages, groups, accounts or posts on social media and other third party platforms. This includes aggregate data on our followers, data regarding how you engage with our content (such as likes, comments, and shares) and publicly available profile information.
If you sign up for or participate in a communication platform that we make available to you, we receive information about your registration for, attendance at and/or interaction with events, content and offerings, as well as information about your active days, how you engage with the platform (such as number of messages and reactions) and the date you were “last active” on the platform.
If you choose to log in to the Services through a social media or other third-party account, we will collect your login credentials and any other information that you permit these social media or other third-party platforms to share with us. You should review and, if necessary, adjust your privacy settings on the social media and other third-party platforms before linking or connecting them to the Services.
Where required by applicable law, our lawful basis is (where permitted under applicable law) our legitimate business interest to constantly improve our Services and to provide you with information relating to our offerings which might be of interest to you, or to perform a contract with you or take steps prior to entering into a contract with you.
How We Use the Information
We may use the information collected pursuant to this Privacy Policy in the following ways:
- To fulfill requests for our publications, products or services, including to send you FORTUNE newsletters, facilitate and complete your payments and transactions, and to respond to inquiries about offerings.
- To provide you with the Services.
- To evaluate your eligibility for certain products and Services.
- To market to you and offer other products, programs or services that may be of interest.
- To communicate with you, such as to notify you of new products and services, provide you updates and offers related to your account or subscription, when we make changes to subscriber agreements, to fulfill a request by you for an online newsletter, or to contact you or respond to you inquiries.
- To deliver targeted and other advertising to you. Please see the “Cookies and Other Online Tracking Technologies”, “Online Advertising” and “Choices Related to Online Tracking Technologies” sections below for further information about our and third parties’ use of cookies, web beacons, mobile ad identifiers, and other tracking technologies to provide you what are believed to be relevant ads, as well as information about how to disable cookies and make other choices related to targeted advertising.
- For attribution purposes. For example, when you click on a link, widget or application interface that appears on our Services that links to a third party site, product or service offer and/or purchase products or services or access discounts or coupons available there, we may enable marketing firms, affiliate marketing networks, merchants and other third parties to attribute your visit to those sites or offers and/or your product or service purchases to your use of our Services. This enables us to earn commissions on your visits to those sites or offers and/or your product and service purchases, and helps us better understand the content, products and services that interest our users.
- With respect to information collected in connection with our online forums and communities, to provide an interactive experience and facilitate participation in these online forums and communities and, from time to time, to offer you products, programs, or services.
- To improve the design and content of our publications and Services, which includes using analytics to develop new products and services.
- To conduct research and analytics.
- To enable us to customize your user experience and analyze site usage, including by tracking the online articles and digital content you have accessed and read.
- To offer you enhanced products, programs, or services.
- To permit third-parties to market and advertise to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and Fortune Media (USA) Corporation and/or one of our affiliates, including for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of the Services, its employees or agents, or other users or to comply with applicable law.
- For other uses that advance our commercial or economic interests.
- In any other way as we may describe when you provide the information or otherwise at your direction or with your consent.
- As permitted by law, including for auditing, fraud and security monitoring.
Please note that artificial intelligence (“AI”) may be used when processing your personal data. For example, we or service providers on which we rely may use AI tools to assist with the above uses, such as to improve service offerings and enhance user experience. We may also process your personal data in the course of assessing the performance of our AI tools.
Where required by applicable law, our lawful basis for processing your personal data is your consent or, as the case may be, performance of your contract with us, steps prior to you entering into a contract with us or (where permitted under applicable law) our legitimate business interest or the legitimate interest of our affiliates or other third party in the activity described above.
If You Do Not Provide the Information Requested From You
Some of the personal data requested from you is required in order for you to use our Services. If you do not wish to provide such personal data, you are not obligated to, but as a result we may not be able to provide the particular Service to you. However, some of the personal data requested from you is optional. This means that you can elect not to provide it to us and you will still be able to use the Service. If not all the personal data requested on a form is required, the required personal data may be identified to you such as by displaying an asterisk (*) next to the field where the required personal data is requested.
We may share the information we collect about you or that you provide to us, including any personal data, as follows:
- We may share your information with our service providers, business partners and vendors on which we rely to, for example, assist us in providing the Services to you. These third parties use your information as is necessary or appropriate for the performance of the services they provide to us, or as otherwise contractually permitted. We may also share your information with third parties via our Services such as in a FORTUNE list, ranking or other publication or we may share information about FORTUNE conference attendees with event organizers, exhibitors, sponsors, or other attendees as indicated to you or otherwise consented to by you at the time, such as by consenting to an exhibitor scanning your event badge to share your contact information, or sharing your information with other attendees of a conference through our mobile application.
- We may share your information with our service providers, business partners and vendors to enable the delivery of targeted and other advertising to you. We may also share your information with marketing firms, affiliate marketing networks, merchants and other third parties when you click on a link, widget or application interface that appears on our Services that links to a third party site, product or service offer and/or purchase products or services or access discounts or coupons available there. This enables us to earn commissions on your visit to that third party site or offer and/or your product or service purchases, and helps us better understand the content, products and services that interest our users. Please see the “Cookies and Other Online Tracking Technologies”, “Online Advertising” and “Choices Related to Online Tracking Technologies” sections below for more information, including about how to disable cookies and make other choices related to targeted advertising.
- We may share your information, including information that is combined with outside records, with third parties who provide services to us, such as direct marketing services, in order to enhance our ability to market to you those products or services that may be of interest to you.
- If you choose to submit content (e.g., a “letter to our editors”, an online review, or a public comment), we may publish your name, screen name and other information you have provided to us. You hereby consent to this. Please see our general Terms of Use for more information.
- If you sign up for or participate in a communication platform that we make available to you, the information you have provided about yourself in your profile, the content of any communications or other content you send or post in channels, and information about your registration for, attendance at and/or interaction with events, content and offerings , as well as your “online status” may be made available to all other participants. If your account expires, is revoked or otherwise becomes inactive, certain of your content, including posts, comments or other activity on the platform that are attributable to you, may remain visible.
- We may disclose information that we receive from you and from third party sources to third parties that want to market products or services to you and whose practices are not covered by this Privacy Policy (e.g., other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations). For example, if you are a print subscriber, we may share information about your subscription, such as your physical mailing address, with companies that want to market to you via mail.
- When you request a magazine, service, or other product, we will share your information to the extent necessary to fulfill your request. We may contact you with special offers of possible interest.
- Pursuant to applicable law, we may also have to share your personal data with regulators, public institutions, courts or other third parties.
- We may transfer your information to other offices of Fortune Media (USA) Corporation and our affiliates for internal management and administrative purposes on our behalf, and to enable Fortune Media (USA) Corporation and its affiliates to provide you content you may be interested in, or send you relevant marketing communications, subject to applicable legal requirements. Your personal data will also be transferred to other Fortune Media (USA) Corporation and our affiliates’ offices where necessary for the performance or conclusion of our contractual obligations to you or for your benefit or, as the case may be, (to the extent permitted under applicable law) our legitimate business interest or the legitimate interest of our affiliates. To the extent permitted under applicable law, transfers and disclosures of your information may also be made where necessary for the establishment, exercise, or defense of legal claims, to protect the rights and property of Fortune Media (USA) Corporation and its affiliates and their respective agents, customers, and others, including to enforce our agreements, policies, and terms of use; or to protect the personal safety of any person. Such transfers will not impact any rights you may have under applicable privacy laws.
In addition, please note that if Fortune Media (USA) Corporation or any of its affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, the relevant customer database and any information collected pursuant to this Privacy Policy, including personal data we may possess about you, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.
We process personal data in countries including in the EEA and the United States where we and our service providers and partners are based. If we transfer your data to a country outside of your jurisdiction, we will ensure that the transfer is permitted by applicable law and, if required, put in place a relevant safeguard method for such data transfer. If you require further information on our data transfers you can request this from us. Please reach us as set out in the “How to Contact Us” section below.
FORTUNE Analytics (formerly known as FORTUNE Datastore)
We or our affiliates may publish or offer for purchase data regarding companies or organizations that are selected to the FORTUNE 500, FORTUNE 1000, Global 500 and 100 Best Companies to Work For lists and other similar lists or rankings. If your company or organization is selected to be ranked on one of these lists, we may collect your name, business address, business contact details, additional information about your position in your company and information about your professional background and publish this together with the list or other publication. Such data is obtained solely from publicly available sources. Your data will be processed exclusively for the purpose of the FORTUNE 500 list or our other publications and you will be provided with information about the data collected and processed. Where required and permitted by applicable law, the lawful basis for collecting and processing your data is our legitimate business interest and the legitimate interest of third parties.
FORTUNE Live Media Conferences
When you register for one of our conferences we ask you to provide certain information, including your name, mailing address, e-mail address, telephone number, the company you work for, your assistant’s name and contact details, dietary restrictions and credit card or other payment information so that we can process and consider whether to approve your registration. We may also use this information to better assist you when you contact us in the future (e.g., regarding other conferences you wish to attend). In some cases, we may also ask you for passport details in connection with your travel arrangements or security clearances, or for date of birth or race/ethnicity details for statistical purposes. We may use your personal data to evaluate your registration application and to inform you about our services, upcoming conferences and marketing events. Where required by applicable law, our lawful basis for processing your personal data is the performance of your contract with us and (to the extent permitted under applicable law) our legitimate business interest in running and promoting our conferences, services and marketing events and tracking related statistics in the public interest.
When you are approved to attend one of our conferences, we upload the data you provide to us during the conference registration process, and other information that you may provide to us in connection with your attendance at one of our conferences, such as your photo and bio, into our mobile application for that conference. When you download and log in to use the app, you must provide your name and create a password and you may voluntarily provide certain additional data to us and other authorized users of the app, including your photo and bio to the extent not already provided. You may also choose to import data into the app from a social media profile, such as from your LinkedIn profile. The app enables you to network and interact with other conference attendees by, for example, sharing your agenda and profile with those attendees and enabling in-app messaging. You may adjust your privacy settings in the app. You may have the ability to make changes regarding the notifications you receive from the app. We and our service providers and other entities use certain technologies so that we can identify you when you use the app and collect user metrics such as how you use the app. We use the information we collect to operate and constantly improve our apps, to provide our services to you and other users and for promotional purposes. Where required and permitted by applicable law, our lawful basis for processing your data is our legitimate business interest.
Collection of Information by Third Parties
We sometimes may offer conferences, contests, sweepstakes, promotions, editorial features, or other activities or offerings that are sponsored, co-branded or co-sponsored by or presented with identified third parties. If you, or your company or organization, choose to participate in such activities or offerings, your IP address and the personal data that you voluntarily submit or that other people submit about you may be provided to us and our affiliates and such third parties. Such third parties will act as controllers of your personal data and we have no control over such third parties’ use of your personal data.
Links to Third Party Sites or Other Services
Our websites and mobile applications on which a link to this Privacy Policy appears, and some of the Services, contain links to third party sites and services whose privacy practices may be different than ours. We also allow you to connect with other third party sites and services. For example, some of our Services, such as our product guides, recommendations, brand reviews, comparisons and roundups, may embed content from, or include links to, other sites or services. In addition, in some cases we license FORTUNE branding to third parties, as disclosed on the relevant site or service, for use in connection with those third parties providing links to third party sites or services such as coupon offers. These third party sites and services are not operated or controlled by us, unless specifically stated otherwise thereon. The entities operating these sites and services may use cookies and other similar technologies to collect information including about your navigation from our Services to the relevant third party site or other service, which may be used for attribution purposes to enable us to earn commissions from your visit to that third party site or service and/or your product/service purchases on a third party site or service. We are not responsible for the privacy practices of third party sites and services and you should consult the other third party sites’ and services’ privacy notices in order to better understand their privacy practices.
Privacy Options
Email Marketing. We and our affiliates will only send you marketing emails in compliance with applicable law. If you prefer not to receive email marketing from us or our affiliates, you may opt out of receiving commercial email messages from us by clicking on the “unsubscribe” link that is contained in those email messages.
Telephone Marketing. We and our affiliates will only contact you by telephone in compliance with applicable law. Please email us at privacy@fortune.com if you do not wish to receive telephone calls from us.
Targeted Advertising and Product/Service Links (known as Affiliate Links). Please see “Choices Related to Online Tracking and Advertising” below for information about how to disable cookies and other choices that may be available to you regarding targeted advertising and to manage the information that may be collected from your device via cookies and other tracking technologies by us and/or third parties such as our affiliates and other marketing services.
Your Rights
Subject to applicable law, you may have certain rights as an individual which you can exercise in relation to your personal data that we hold. Your rights under applicable law may include rights to:
- request access to your personal data and request information in relation to its processing;
- request rectification of your personal data;
- request the erasure of your personal data;
- request the restriction of processing of your personal data
- object to the processing of your personal data.
You may also have the right under applicable law to receive your personal data in a structured, commonly used and machine-readable format and to have us transmit those personal data to another controller, if you have provided these personal data to us, if the processing is based on consent or on a contract you have entered into with us or if the processing is carried out by us by automated means, subject, however, to legal restrictions which may apply.
In case you have provided your consent to the collection, processing or transfer of your personal data, you may have the right under applicable law to fully or partly withdraw your consent. To withdraw your consent, please contact us as set out under “How to Contact Us” below. Once we have received notification that you have withdrawn your consent, subject to applicable law, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. In case we processed your personal data for promotional or direct marketing purposes, you have the right to object at any time, in which case we will no longer process your personal data for such marketing purposes.
If you want to exercise one of these rights please email us at privacy@fortune.com. Please note that all such rights are subject to a relevant law granting such rights being applicable and other legal restrictions which may apply. We may also ask you to verify your identity before we are able to respond to your request.
Depending on applicable law, you may also have the right to make a complaint to a relevant supervisory authority or other competent body.
You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Policy. However, subject to applicable law, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances (subject to applicable law).
Retention of Personal Data
We will retain your personal data as long as necessary to fulfil the purposes for which it was collected. Thereafter, we will either delete your personal data or anonymize it so that it cannot be attributed to your identity and therefore is no longer considered as personal data. Please note that we may continue to retain personal data in line with our data retention and routine business practices for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our claims.
Our Commitment to Security
We have put in place appropriate administrative, technical, and physical safeguards to help prevent unauthorized access, maintain data security and correctly use the information we collect from and about you. However, no system can be completely secure and we do not guarantee that unauthorized disclosures and access will not happen. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that your personal data or other information will never be disclosed in a manner that is inconsistent with this Privacy Policy.
Cookies, Software Development Kits and Other Online Tracking Technologies
We and service providers or partners we engage to provide content, advertising, functionality, product and service offers and other services or that measure and analyze ad performance, user behavior on the Services or product/service categories of interest to users, or attribute commission for affiliate links may use cookies, web beacons, software development kits and other similar technologies to understand usage of the Services and improve our content and offerings and to deliver advertisements in which you might be interested and to attribute commission for affiliate links. These technologies collect statistical and other information, including personal data, about you and your use of the Services. Some of the tracking technologies we and our service providers or partners may use include:
Cookies. Cookies are small text files that may be placed by us or our service providers and partners on your computer or device when you visit our websites or applications. A cookie assigns a unique numerical identifier to your web browser or device, and may enable us, our service providers or partners to recognize you as the same user who has used the Services, and relate your use of the Services to other information about you, such as your usage information and other personal data about you. We, our service providers and partners may use cookies in a variety of ways. For example, we our service providers and partners may use cookies to:
- Provide us with information about which portions of our websites and applications are the most popular by enabling us to see what web pages a user visits and how much time a user spends on each page.
- Personalize your experience on our Services (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, to enable shopping carts, or to tailor content, or product and service offerings).
- Help us understand which ads you have seen so that you don’t receive the same ad each time you access the Services.
Local Shared Objects. Local shared objects, such as “Flash cookies” also may be stored on your computer or device. Local shared objects operate a lot like cookies because they are stored on your device and can be used to store certain information about your activities and preferences; however, they cannot be managed in the same way as cookies. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, for example, see http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
HTML 5. HTML5, the language some websites are coded in, may be used to store information on your computer or device about how you use the Services. This information may be retrieved by us, our service providers or partners to help us manage the Services, and may give us information about how the Services are being used by our visitors, how they can be improved, and how we can customize the Services for users.
Cache Cookies. Cache cookies, such as eTags, may be used to identify your computer or device as the same computer or device that visited a Service or Services in the past.
Web Beacons. A web beacon is an electronic image called a single-pixel or “clear gif” that is a small piece of code that is used to collect anonymous and aggregate advertising metrics, such as the counting of page views, promotion views, or advertising responses. Web beacons can recognize certain types of information, such as a user’s cookie number, time and date of a page view, and description of the page where the web beacon is placed. These web beacons may be used to deliver cookies that conform to our cookie policy above.
Mobile Device IDs and Location-Based Information. Certain mobile devices, including smart phones and tablet devices, contain unique device IDs that can be used to identify their physical location. Some mobile device IDs are permanent, while others may be changed by accessing the device’s privacy settings. Mobile devices also typically transmit caller ID data (which may include a phone number) when used to transmit a telephone call or text message. When you use mobile devices to access our Services, we may collect and transmit unique device IDs and collect caller ID data, as well as other information about your device, including without limitation, your wireless carrier, the make, model, operating system, capacity and settings of your device, the names, package IDs and versions of other software you have downloaded to your device and information about how you interact with and navigate within our Services.
These tracking technologies may be deployed by us and/or our by our service providers or partners on our behalf. These technologies enable us to assign a unique number to you, and may allow us to relate your use of the relevant Services to other information about you, including your usage information and personal data. We may match information collected from you through different means or at different times and combine such information with information obtained from other sources (including third parties), such as demographic information and updated contact information (where that information has been lawfully disclosed to us), for the purposes of learning more about you so we can, for example, provide you with relevant content, and in connection with affiliate links, as explained in this Privacy Policy.
Where required and permitted by applicable law, the lawful basis for collection of your personal data via cookies or other tracking technologies and further processing of these data is our legitimate business interest or the legitimate business interest of our service providers and partners. The lawful basis for processing your location data is your consent.
Online Advertising
When you use the Services, FORTUNE, its service providers or third parties, such as ad technology, ad servers, ad networks or any other nonaffiliated third parties, may place cookies on your computer or use other online tracking technologies to collect or receive certain information about you and/or your use of the Services. Such information may include information about your visits to, and activity on, this website or application and other websites or applications, the number of times you have viewed an advertisement and other information. The information may be used to provide content, advertising, or functionality or to measure and analyze ad performance on the Services or other websites or platforms. For example, we may use third parties to present or serve advertisements, including online targeted advertisements that you may see on the Services. Third parties may also conduct research about the advertisements, or the Services themselves, and may place and use tracking mechanisms (e.g., tracking pixels) in the emails we may send to you. This information may be combined with information collected across different websites, online services, and other linked or associated devices. Where required by applicable law, our lawful basis is your consent and/or (to the extent permitted by applicable law) our legitimate business interest to constantly improve our Services and to provide you with information relating to our offerings which might be of interest for you. This Privacy Policy does not cover any use of information that such third parties may have collected from you for their own purposes or the methods used by the third parties to collect that information.
Choices Related to Online Tracking and Advertising
Most browsers automatically accept cookies. You can set your browser options so that you will not receive cookies and you can also delete existing cookies from your browser. Most devices and browsers allow you to set your cookie preferences. These settings are typically found in your browser’s “Options” or “Preferences” menu. For more information, you can refer to your browser’s “Help” or “Settings” section.
In addition, we will only use cookies that are not strictly necessary if we have obtained your consent. However, you may find that some parts of the site will not function properly if you have refused cookies or similar tracking technologies and you should be aware that disabling cookies or similar tracking technologies might prevent you from accessing some of our content. Also, you may still receive advertisements even if you do not opt-in to targeted advertising. In that case, the ads will not be tailored to your perceived interests.
For more information on advertisements and your targeted advertising options, please manage your cookie preferences.
Special Note for Parents
The Services are not intended for use by children, especially those under the age of 16, and we do not knowingly collect personal data from children under the age of 16. If you are a parent or guardian and believe we have collected information from your child, please contact us as set out under “How to Contact Us” below.
No Automated Decision Making
We do not apply automated decision making techniques.
Data Protection Officer
We have appointed a data protection officer. If you wish to contact our data protection officer, please email us at privacy@fortune.com or contact us as set out under “How to Contact Us” below.
Jurisdiction Specific Supplements
These supplements contain additional disclosures required by certain privacy laws. If you are located in one of the jurisdictions set forth below, the relevant section for that jurisdiction applies in addition to the other sections of this Privacy Policy.
Australia
Complaints. Please contact us (using the contact details at the end of this privacy policy) if you have any concerns or complaints about the manner in which we have collected or handled your personal information. We will inquire into your complaint and respond to you in writing within 30 days. If you are not satisfied with our response, you can contact us to discuss your concerns or lodge a complaint with the Australian Privacy Commissioner (www.oaic.gov.au).
Third party marketing. We and our affiliates will only share your personal data with third parties for marketing purposes in compliance with applicable law. If you wish to request that we do not disclose your personal data to third parties that want to market products or services to you, please email us at privacy@fortune.com.
Your rights. Your rights under applicable law may include rights to:
- request access to your personal data;
- request correction of your personal data;
If you want to exercise one of these rights please email us at privacy@fortune.com. Please note that all your rights are subject to legal restrictions which may apply. We may also ask you to verify your identity before we are able to respond to your request.
Hong Kong
Definitions. References to “data controller” in this Privacy Policy shall be understood to refer to “data user” under Personal Data (Privacy) Ordinance (chapter 486 of laws of Hong Kong) (“Ordinance”), i.e., “the person or organization who, either alone or jointly with others, controls the collection, holding, processing or use of the data”. References to “personal data” in this Privacy Policy shall be understood to refer to any data “relating directly or indirectly to a living individual, from which it is possible and practical to ascertain the identity of the individual from the said data, in a form in which access to or processing of the data is practicable”, as defined under the Ordinance.
Lawful basis. If any “lawful basis” described in this Privacy Policy is not applicable under the Ordinance, the following are our lawful bases for processing your personal data:
- appropriate notice has been provided to or made available to you;
- you have provided consent to the processing for the identified purposes; or
- there are exemptions to the requirement of notice or consent.
Certain information. When personal data are collected from you directly, we will provide you with the following information (unless the purpose for collection is exempt from the Ordinance), which includes:
- the purpose for which the data are to be used;
- the classes of persons to whom the data may be transferred;
- whether it is obligatory or voluntary for you to supply the data;
- the consequences arising if you fail to supply the data; and
- you have the right to request access to and correction of the data.
Marketing. For conducting direct marketing activities, we will obtain your consent or an explicit indication of no objection before using any of your personal data in direct marketing under the Ordinance. We will not provide your personal data to other third parties for use in direct marketing unless we have obtained your written consent which is given upon receipt of the following information in writing:
- whether the data is to be provided for gain;
- the kinds of personal data to be provided;
- the classes of persons to whom such personal data is to be provided; and
- the classes of marketing subjects.
New purposes. We will obtain your consent before using your personal data for any new purpose which is not or is unrelated to the original purpose when collecting your personal data.
Sensitive personal information. We only process sensitive personal information if and to the extent permitted or required by applicable laws. We will ensure sensitive personal information is collected for specified and necessary purposes, with stringent protective measures, and obtain your explicit consent for processing sensitive personal information, unless an exception applies.
Data sharing. When necessary for the purposes described in this Privacy Policy, subject to your consent in writing where required by applicable law, your personal data may be shared to third parties located outside Hong Kong as specified in the section “How We Share the Information”. We take reasonable precautions and exercise due diligence to ensure that your personal data will not be handled in a manner that would be a contravention of the Ordinance. We have effective data transfer arrangements for cross-border transfer of personal data which include the following:
- use of the model data transfer clauses to develop an enforceable contract for the cross-border transfer;
- ensure the transfer is only to the recipients which offer sufficient guarantees in respect of the technical competence and organizational measures governing the use and processing of personal data, and with a good track record on data protection; and
- where it is an intra-group transfer, implement adequate internal safeguards and policies as well as procedures which apply to the group as a whole.
Rights. In addition to any relevant rights outlined in the section “Your rights”, you may have certain additional rights related to your personal data. Subject to applicable laws, these rights include the right to, at any time, require us to cease to use your personal data in direct marketing.
Macau
Definitions. References to “data controller” in this Privacy Policy shall be understood to refer to “controller” under the Personal Data Protection Act of Macau (Act 8/2005) (“PDPA”), i.e., “the natural or legal person, public entity, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data”. References to “personal data” in this Privacy Policy shall be understood to refer to “any information of any type, irrespective of the type of medium involved, including sound and image, relating to an identified or identifiable natural person (‘data subject’)”, as defined under the PDPA.
Certain information. When personal data are collected from you directly, we will provide you with the following information (unless the purpose for collection is exempt from the PDPA), which includes:
- the identity of the controller and of the representative, if any;
- the purposes of the processing;
- other information such as:
- the recipients or categories of recipients;
- whether replies are obligatory or voluntary, as well as the possible consequences of failure to reply;
- the existence and conditions of the right of access and the right to rectify.
Marketing. For conducting direct marketing activities, we may use some of the personal data we collect, but only in accordance with the PDPA. If we intend to use your personal data for direct marketing purposes or provide your personal data to third parties for direct marketing purposes, we will inform you of that at the time we collect your personal data. We will provide you an opportunity to opt out of receiving direct marketing materials at that time. If you don’t opt out at that time but later decide you no longer wish to receive direct marketing, you may ask us to further cease any direct marketing by contacting us at privacy@fortune.com or by contacting us as set out under “How to Contact Us”.
New purposes. We will obtain your consent before using your personal data for any new purpose which is not or is unrelated to the original purpose when collecting your personal data.
Sensitive personal information. We only process sensitive personal information if and to the extent permitted or required by applicable laws, including after obtaining your separate consent if required. We will seek to protect such information strictly using the security measures required by the applicable laws and, therefore, your sensitive personal information should not be processed in a way that will result in negative implications to your personal rights, e.g. harm to your reputation, physical or mental health, personal or property security.
Data sharing. When necessary for the purposes described in this Privacy Policy, subject to your consent where required by applicable law, your personal data may be shared to third parties located outside Macau as specified in the section “How We Share the Information”. In any case, we only engage in transferring personal data to places outside Macau if the recipients provide an adequate level of protection for your personal data, and provided that appropriate technical and organizational security measures are in place to protect your personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Where it is an intra-group transfer, we implement adequate internal safeguards and policies as well as procedures which apply to the group as a whole.
Rights. In addition to any relevant rights outlined in the section “Your rights”, you may have certain additional rights related to your personal data. Subject to applicable laws, these rights include:
- the right to obtain from us a notification to third parties to whom the data have been disclosed of any rectification, erasure or blocking in which case the third parties are required to rectify, erase or block the data accordingly, unless this proves impossible, or would involve a disproportionate effort.
- the right to obtain from us, without constraint at reasonable intervals and without excessive delay or expense, the rectification, erasure or blocking of data, the processing of which does not comply with the provisions of the PDPA, in particular because of the incomplete or inaccurate nature of the data;
Indonesia
For Indonesia-specific privacy policies, the following clauses or amendments apply:
- For the section titled “Information Other People Provide About You”, the existing clause on lawful basis at the end of that section is hereby repealed and replaced with the following: “Our lawful basis for processing personal data submitted to us by another person is the performance of a contract with us, steps taken prior to entering into such a contract, or, as the case may be, our legitimate business interest or your consent.“
- For the section titled “Information We Collect Automatically”, the existing clause on lawful basis at the end of that section is hereby repealed and replaced with the following: “Our lawful basis is our legitimate business interest in continually improving our services and providing you with information about our offerings that may be of interest to you, or, as the case may be, your consent.”
- For the section titled “Information We Obtain from Other Sources”, the existing clause on lawful basis at the end of that section is hereby repealed and replaced with the following: “Our lawful basis is our legitimate business interest in continually improving our services and providing you with information about our offerings that may be of interest to you; performing a contract with you; taking steps prior to entering into a contract with you; or, as the case may be, relying on your consent.”
- For the section titled “How We Use the Information”, the existing clause on lawful basis at the end of that section is hereby repealed and replaced with the following: “Our lawful basis for processing your personal data is your consent or, as the case may be, the performance of your contract with us; steps taken prior to entering into such a contract; compliance with legal obligations applicable in the country where you reside; our legitimate business interest; or the legitimate interest of our affiliates or other third parties in the activities described above.”
- For the section titled “How We Share the Information”, the following clauses or amendments apply:
- The existing clause beginning with “Your personal data will also be transferred to other Fortune Media (USA) Corporation …”, as provided in the last bullet point under that section, is hereby repealed and replaced with the following: “Your personal data may also be transferred to other offices of Fortune Media (USA) Corporation and our affiliates where necessary for the performance or conclusion of our contractual obligations to you or for your benefit, or, as the case may be, based on our legitimate business interest or that of our affiliates. Where required under applicable laws and regulations, including those of the country where you reside, we will obtain your consent prior to any international transfer of your personal data. To the extent not prohibited under applicable law, transfers and disclosures of your information may also be made where necessary for the establishment, exercise, or defense of legal claims; to protect the rights and property of Fortune Media (USA) Corporation, its affiliates, and their respective agents, customers, and others—including to enforce our agreements, policies, and terms of use—or to protect the personal safety of any individual, or as otherwise permitted or required by applicable laws and regulations.”
- At the end of the existing clause on corporate actions (e.g., mergers, acquisitions, divestitures, sales, dissolutions), as provided toward the end of that section, the following clause is added: “In the event of a corporate action (e.g., merger, consolidation, sale, or divestiture of assets) involving Fortune Media (USA) Corporation, we will update this Privacy Policy to reflect any changes in how your personal data is processed. Any updates related to the corporate action will be communicated to you via our website, email, and/or other appropriate communication channels;”
- Under the sub-section “FORTUNE Analytics”, the existing clause on lawful basis at the end of that sub-section is hereby repealed and replaced with the following: “The lawful basis for collecting and processing your data is our legitimate business interest and the legitimate interest of third parties, or, as the case may be, your consent;” and
- Under the sub-section “FORTUNE Live Media Conferences”, the existing clause on lawful basis at the end of that sub-section is hereby repealed and replaced with the following: “The lawful basis for collecting and processing your data is the performance of a contract or steps taken at your request prior to entering into a contract. Any use of your personal data for marketing, promotional activities, or statistical analysis will be carried out with your consent and, as the case may be, based on our legitimate business interest or the legitimate interests of third parties.”
- For the section titled “Privacy Options”, the following clauses or amendments apply:
- Under the sub-section “Email Marketing” the existing clause is hereby repealed and replaced with the following: Email Marketing. We and our affiliates will only send you marketing emails where we have obtained your consent. If you have provided your consent but no longer wish to receive marketing emails from us or our affiliates, you may withdraw your consent at any time by clicking the “unsubscribe” link included in those messages;” and
- Under the sub-section “Telephone Marketing” the existing clause is hereby repealed and replaced with the following: Telephone Marketing. We and our affiliates will contact you by telephone where we have obtained your consent. If you have provided your consent but no longer wish to receive telephone calls from us or our affiliates, you may withdraw your consent at any time by contacting us at privacy@fortune.com”.
- For the section titled “Your Rights”, the following rights are added: these rights include the right to:
- request the destruction of your personal data; and
- delay or refuse automatic decision-making, including profiling, which produces legal effects or significantly affects you.
- For the section titled “Cookies, Software Development Kits, and Other Online Tracking Technologies”, the existing clause on lawful basis at the end of that sub-section is hereby repealed and replaced with the following: “For the collection and use of more sensitive or persistent identifiers, including mobile device IDs, caller ID data, and location-based information, the lawful basis is your consent.”
- For the section titled “Online Advertising”, the existing clause on lawful basis provided towards the end of that section is hereby repealed and replaced with the following: “Our lawful basis is our legitimate business interest in continually improving our services and providing you with information about our offerings that may be of interest to you, or, as the case may be, your consent.”
- For the section titled “Special Note for Parents”, the existing age of majority (i.e., 16) is hereby repealed and replaced with 18 years old.
- In this section, the following clause is added: “Any local language translation (e.g., the Indonesian language) of this Privacy Policy exists for reference purposes only, and only the English version shall take precedence. If there is any inconsistency between different versions, the English version will prevail.”
- For the section titled “Change to this Privacy Policy” below, the existing clause is hereby repealed and replaced with the following: “This Privacy Policy may be changed by Fortune Media (USA) Corporation or its affiliates at any time. Prior to any changes becoming effective, we will notify you by posting a notice on the relevant sections of our websites or mobile applications and/or by contacting you directly through the contact details you have provided. The revised Privacy Policy will indicate the date of the most recent update at the bottom of the document. We encourage you to review this Privacy Policy periodically so that you remain informed about what information we collect, how we use it, and with whom we share it. If any changes to this Privacy Policy will materially affect how we handle your personal data or impact you directly, we will provide sufficient notice to enable you to exercise your rights under applicable laws and regulations on data protection, including the right to object to such changes where relevant.”
Japan
This Japan section applies to our handling of “personal information” and “personal data” as defined in and subject to the Act on the Protection of Personal Information of Japan (“APPI”), in precedence to the other portions of the Rest of World Privacy Policy.
A. Data Sharing.
We may share your personal data, as set forth in this Privacy Policy, with affiliates of Fortune Media (USA) Corporation in the framework of joint-use (kodo riyou in Japanese) for the following purposes: internal management and administration, provision of contents you may be interested in, and sending you relevant marketing communication subject to applicable legal requirements. In such case, Fortune Media (USA) Corporation is primarily responsible for managing the personal data that is jointly used.
B. International Data Transfer.
The personal data you provide to us will be transferred to countries other than Japan, including the United States. If we transfer your data to the United States or to any other country which is not designated by the Japan’s Personal Information Protection Commission, we will always ensure that a relevant safeguard method for such data transfer is implemented (such as a data transfer agreement that comply with the APPI), unless we obtain your consent in advance.
C. Your Rights.
In addition to Section “Your Rights”, you also have a right to access to a record of provision of personal data to a third party.
Malaysia
A. Your Rights
The following right is added:
“These rights are to:
request the transmission of your personal data (subject to technical feasibility or compatibility of format).”
B. Special Note for Parents
The age number is replaced with: “…especially those under the age of 18, and we do not knowingly collect personal data from children under the age of 18...”
C. How To Contact Us
The existing clause is replaced with:
“If you have any questions or concerns about this Privacy Policy or its implementation, please contact our Data Protection Officer at (646) 437 6608 or via email at privacy@fortune.com or by writing to:
Fortune Media (USA) Corporation
40 Fulton Street
New York, NY 10038”
D. The following section and clause are added:
“Language
Pursuant to the local language requirements under the personal data protection laws of certain jurisdictions, this notice may be issued in multiple languages in addition to the English version. In the event of any inconsistencies or discrepancies between the different language versions, the English version shall prevail.”
Singapore
Definitions. The purpose of this Privacy Policy and supplement is to inform you of how we handle or process your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) of Singapore. In accordance with the PDPA, personal data means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access.
Precedence. This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us nor does it affect any rights which we may have at law in connection with the collection, use, or disclosure of your personal data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your personal data. This includes any of the terms and conditions you have accepted related to use of our Services. In the event of any conflict, inconsistency or conflict between this Privacy Policy and such terms and conditions, the Privacy Policy shall prevail.
Consent. In addition to the matters set forth above in this Privacy Policy, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your personal data, and disclosing such personal data to our authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy:
a) where in response to a request for your personal data in connection with identified purposes, you voluntarily provide such personal data to us for such purpose(s);
b) where the collection, use or disclosure of your personal data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your personal data not indicated in this privacy policy; and/or
c) where we have brought to your attention our intention to collect, use or disclose your personal data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via the FORTUNE website, or via other forms of communication (e.g. SMS or email) based on the contact particulars that we may have of you in our records from time to time.
Data transfers. The personal data you provide to us may be transferred and processed in countries outside of Singapore. Where we transfer your personal data to a country or territory outside Singapore, we will take appropriate steps to ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection to your personal data that is comparable to the protection under thePDPA. These obligations may be imposed by law, contract, binding corporate rules, or other legally binding instruments. In specific situations, such as where you have provided your consent, where the transfer is necessary for the performance of a contract with you or for your benefit, or where required for responding to emergencies, your personal data may be transferred in accordance with the requirements of the PDPA.
Rights. Under and subject to the PDPA, you may have rights as an individual which you can exercise in relation to your personal data that we hold. These rights are to:
- request access to your personal data and request information in relation to its processing;
- request correction of your personal data;
- withdraw your consent for us to collect, use, or disclose your personal data; and
- request that we transfer your personal data to another organization in a commonly used and machine-readable format.
You may contact us in Singapore at +852 352 30023601.
Saudi Arabia
Under applicable law in Saudi Arabia, you also have the right to request to know the legal basis for collecting your personal data.
Changes to this Privacy Policy
This Privacy Policy may be changed by Fortune Media (USA) Corporation or its affiliates at any time. If we make any substantial changes in the way we use your personal data, we will take reasonable steps to notify you. The revised Privacy Policy will be posted on the appropriate portion(s) of our websites or mobile applications and will indicate at the bottom when it was most recently updated. We encourage you to periodically check back to review this policy so that you know what information we collect, how we use it and with whom we share it.
How To Contact Us
If you have any questions or concerns about this Privacy Policy or its implementation please contact us via email at privacy@fortune.com or by writing to:
Fortune Media (USA) Corporation
40 Fulton Street
New York, NY 10038
This Privacy Policy was last updated on October 13, 2025.
Prior Versions of This Policy
None