Our Privacy Commitments
Navigate Commodities Pte. Ltd. (“we”) respect the privacy of every person who visits, registers with or subscribes to our websites and online publications (“you”), and are committed to ensuring a safe online experience.
This Privacy Statement outlines the information we may collect about you in relation to your use of our websites and related publications and services and how we may use that personal data. It also outlines the methods by which we and our service providers may (subject to necessary consents) monitor your online behaviour in order to deliver customised advertisements and marketing materials and other tailored services.
This Privacy Statement applies to all websites operated by us (as indicated on the relevant website) (” Sites “). For the purpose of this Privacy Statement, “group company” shall mean Navigate Commodities Pte. Ltd. and any of its subsidiary companies. Please note that the Sites may contain links to external sites and may contain advertisements for, and/or the opportunity for you to purchase products or services from third parties. This Privacy Statement does not cover the activities of such third parties, and you should consult those third-party sites` privacy policies for information on how your data is used by them.
By accessing and using the Sites you are agreeing to the terms of this Privacy Statement.
Information about us
Our principal business activities are:
- Business-to-Business Commodity & Financial Publishing. We provide a range of products and services focused on international finance, metals, commodities, telecoms and emerging markets including magazines, newsletters, electronic information and data
- Organisers of Seminars, Conferences, Training Courses and Exhibitions for the commodities & financial markets industry
Navigate Commodities Pte. Ltd.
Level 6, Republic Plaza,
9 Raffles Place,
Name of the Data Controller
The Data Controllers are Navigate Commodities Pte. Ltd.
Collection of Personal Data
Our primary goal in collecting personal data from you is to give you an enjoyable customised experience whilst allowing us to provide services and features that most likely meet your needs.
We collect certain personal data from you, which you give to us when using our Sites and/or registering or subscribing for our products and services. However, we also give you the option to access our Sites` home pages without subscribing or registering or disclosing your personal data.
We also collect certain personal data from other group companies to whom you have given information through their websites (including, by way of example, Navigate Commodities Pte. Ltd., in accordance with the purposes listed below).
Please note that we do not intend to collect any personal data from children under thirteen years of age and no child under thirteen should submit any personal data to any of the Sites. Should we discover that any such personal data has been delivered to any of the Sites, we will remove that information as soon as possible.
Purpose of Data Collected
We set out in the table below all the ways we plan to use your personal information and the legal basis we rely on to do so. We also explain what our legitimate interests are where appropriate:
|Purpose||Lawful basis for processing including our legitimate interests||Processing necessary to achieve purpose|
|To on-board you as a new customer||
To fulfil our contract with you
To fulfil our legal obligations to prevent financial crime
|To monitor your use of the Subscription Service and your license(s) on an on-going basis||
Necessary for our legitimate interests – for billing purposes
To fulfil our contract with you
|To contact you about other services or products via promotional materials or other media||Necessary for our legitimate interests – to develop our products and services and grow our business||
|To notify you about changes to our Sales Order, Terms of Business or Privacy Statement, and to communicate with you in response to any of your queries or requests||
To fulfil our contract with you
To fulfil our regulatory obligations
Types of Personal Data Held and its Use
- Customer Services and Administration
At some Sites, Navigate Commodities Pte. Ltd. collects personal data such as your name, job title, work and/or home address, and telephone number and email address in order to register you for access to certain content and subscriptions. This information may be supplemented with demographic information from your use of our Sites such as your postal area, age, gender, purchasing preferences and interests.
At other Sites, Navigate Commodities Pte. Ltd. may only collect broad demographic information for aggregate use.
- Monitoring use of our Sites
Where, as part of our Site services, we enable you to post information or materials on our Site, we may access and monitor any information which you upload or input, including in any password-protected sections. Subject to any necessary consents, we also monitor and/or record the different Sites you visit, and actions taken on those Sites, e.g. content viewed or searched for. If you are a registered user (e.g. a subscriber or taking a trial), when you log on, this places a cookie on your machine. This enables your access to content and services that are not publicly available. Once you are logged on, the functional actions you take – for example, viewing an article – may be recorded.
- Cookies and similar technologies
Cookies are pieces of information which include a unique reference code that a website transfers to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer. Cookies cannot be used to run programs or deliver viruses to your computer. They are uniquely assigned to you and can only be read by a Web server in the domain that issued the cookie.
– remember that you have used the Site before; this means we can identify the number of unique visitors we receive to different parts of the Site. This allows us to make sure we have enough capacity for the number of users that we get and make sure that the Site runs fast enough;
– remember your login session so you can move from one page to another within the Site; or store your preferences or your user name and password so that you do not need to input these every time you visit the Site;
– customise elements of the layout and/or content of the pages of Site for you;
– record activity on our Sites so that we understand how you use our Sites enabling us to better tailor our content, services and marketing to your needs;
– collect statistical information about how you use the Site so that we can improve the Site;
– gather information about the pages on the Site that you visit, and also other information about other websites that you visit, so as to place you in a “market segment”. This information is only collected by reference to the IP address that you are using, but does include information about the county and city you are in, together with the name of your internet service provider. This information is then used to place interest-based advertisements on the Site which it is believed will be relevant to your market segment. Some of the cookies used by our Sites are set by us, and some are set by third parties who are delivering services (such as interest-based advertising directed at your market segment) on our behalf.
Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies in general by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking, deleting or turning off cookies used on the Site you may not be able to take full advantage of the Site.
So that we can better understand our users` needs, we track responses to our emails – for example, to see which links are the most popular in newsletters, and to log and follow up responses to our marketing messages. To do this, we use pixel GIFs, also known as “pixel tags” – these are small image files that are placed within the body of our email messages. They enable us to tell if a message has been opened and to track click-throughs on links within the message.
Consents and opt-outs
You can give your consent to or opt out of particular uses of your data as indicated above by:
- Indicating at the point on the relevant Site where personal data is collected;
- Informing us by email, post or phone; or
- Updating your preferences on the applicable Site;
We, our group companies or other third-party service providers may send you marketing communications if you have agreed to receive such communications and in each case you have not opted-out of receiving such communications, or you have asked for information about us and requested we keep you updated about our business and services. We believe as a commercial enterprise we do have a legitimate interest in contacting you about our products or services by utilizing your personal data, and we will only do so if we decide it would be of interest or beneficial for you.
Information collected at one Site may be shared between Navigate Commodities Pte. Ltd. and other group companies for the purposes listed above (“purposes of data collected”).
We may also disclose your personal data to other third parties, including, without limitation, professional advisers, or governmental or State institutions or regulatory authorities, where necessary in order to exercise or defend legal rights or where required by law.
Public forums, message boards and blogs
Some of our Sites make message boards, blogs or other facilities for user generated content available and users can participate in these facilities. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to disclose your personal information.
Confidentiality and Security of Your Personal Data
We are committed to keeping the data you provide us secure and will take reasonable precautions to protect your personal data from loss, misuse or alteration.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features described above to try to prevent unauthorised access.
We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:
- unauthorised access
- improper use or disclosure
- unauthorised modification
All our employees, contractors and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of your personal data, are obliged to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.
We also give you the option of using a secure transmission method to send us personal data identifiers, such as credit card details and bank account number.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including in order to meet any legal, accounting, or regulatory requirements.
Your Rights and Your Personal Data
- Postal mail to this address: Data Protection Officer, Navigate Commodities Pte. Ltd., Level 6, Republic Plaza, 9 Raffles Place, Singapore, 048619
- Telephone: +65 8318 2835
- Email: [email protected]
In accordance with the relevant jurisdictional and EU data protection laws, subjects have the right in relation to personal data that includes the right to request access to your personal data, to correct it, have it erased, restrict it from being used, object to it being processed, to the portability of data and to withdraw consent at any time. You can request such rights by mailing, dialling or emailing to the above address, telephone number or email address respectively. We may also need to seek further information from you to confirm your identity before we release any personal information.
Any other purposes for which Navigate Commodities Pte. Ltd. wishes to use your personal data will be notified to you and your personal data will not be used for any other such purpose other than as informed in this Privacy Statement, either by notifying you by an update of this Privacy Statement or by obtaining your prior consent.
We reserve the right to transfer, sell or assign any of the information described in this policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.
Changes to this Privacy Statement
We will occasionally update this Privacy Statement to reflect new legislation or industry practice, group company changes and customer feedback. We encourage you to review this Privacy Statement periodically to be informed of how we are protecting your personal data.
This Privacy Statement was last updated in April 2020.