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Scope and who we are

This Privacy Policy explains how Further Markets Technologies Ltd (“FurtherMarkets”, “we”, “us” or “our”) processes personal data through furthermarkets.com (the “Site”).

Further Markets Technologies Ltd is a private company incorporated in the Dubai International Financial Centre (“DIFC”) under the DIFC Companies Law, registration number 11741. Our office is at DIFC Innovation Hub, Innovation One Building, 3rd Floor, Dubai AI Campus, Dubai, United Arab Emirates. We are the controller of the personal data described in this Policy.

You can contact us about privacy in any of these ways: (a) email privacy@furthermarkets.com; (b) use www.furthermarkets.com/contact and select “Privacy request”; or (c) write to the postal address above.

We process personal data under DIFC Data Protection Law No. 5 of 2020 and other data-protection law that applies to a particular processing activity.

Personal data we collect

We collect personal data directly from you when you request a paper, subscribe or contact us, and automatically when your device requests a page or file.

Sensitive and unsolicited information

We do not ask you to provide special-category personal data, financial account information, investment holdings or risk profile through the Site. Please do not include such information, confidential material or another person’s personal data in a message unless it is necessary and you are authorised to provide it. If we receive unsolicited sensitive information, we will limit access and delete it when it is not necessary to keep it or where the law requires deletion.

Purposes and legal bases

We use personal data only where we have a lawful basis. The principal purposes and bases are set out below.

Where we rely on legitimate interests, we consider the purpose, necessity and impact on you and use safeguards appropriate to the risk. You may object as explained in section 11. We do not use Site data to make decisions about you based solely on automated processing that produce legal or similarly significant effects, and we do not build advertising profiles.

New-paper emails

We send new-paper emails only after you select the separate optional subscription choice and complete the confirmation process. Each message includes an unsubscribe method. We will action an unsubscribe promptly and retain limited suppression information so that we do not add the address again by mistake.

The Briefing. If you subscribe to The Briefing, we use the countries, regions and sectors you choose to select which stories and papers each Briefing contains. Every Briefing carries a private link to change those choices and a link to unsubscribe. We do not use your choices for anything else, and we do not sell or share them.

Requesting or downloading a paper does not subscribe you. A consent given to another platform or brand, including FurtherAfrica, is not treated as consent to FurtherMarkets unless the notice and choice expressly covered FurtherMarkets.

Cookies and similar technology

The Site itself does not set any cookies. It uses your browser’s local storage for one purpose only, described in the next paragraph. The language you read in is set by the address you visit (for example, /fr/ for French). Apart from the films described below, the Site loads no scripts, fonts or media from third parties, and we count visits using our own server logs.

Remembering you on this device. After your first download, your browser stores a signed record of the name, work email and organisation you gave us, for up to 12 months, so you do not have to register again. It stays on your device; remove it at any time with “Not you? Use another name” or by clearing this site’s data in your browser.

Films on paper pages. Some paper pages offer a short film hosted on YouTube, a service of Google. Nothing is loaded from YouTube until you press play. When you do, the film plays from youtube-nocookie.com, YouTube’s privacy-enhanced mode, and Google receives technical information such as your IP address and browser details and may store cookies or similar technology on your device under its own privacy policy (policies.google.com/privacy). If you do not press play, nothing is sent to YouTube.

Before adding analytics, advertising pixels, embedded third-party media, third-party fonts or other non-essential technology, we will assess whether consent is required and update this Policy and any consent tool before deployment.

Recipients and service providers

We do not sell or rent personal data. We disclose it only as reasonably necessary to the following recipients:

1. SiteGround, our website hosting provider, which hosts the Site, its forms and records on servers in London, United Kingdom, and whose mail service delivers the paper links, confirmations and replies you request, together with its security and technical services;
2. Brevo (Sendinblue SAS) and its approved sub-processors, when we send new-paper emails, The Briefing, subscription confirmations and unsubscribe handling through its service;
3. Google (YouTube), only when you choose to play a film on a paper page, as described under “Cookies and similar technology”; Google acts as an independent controller of that processing;
4. professional advisers, including lawyers, accountants, auditors and insurers, where reasonably necessary and subject to professional or contractual confidentiality duties;
5. courts, regulators, law-enforcement bodies and other public authorities where disclosure is required or permitted by applicable law and appropriately assessed; and
6. a buyer, investor or successor in connection with a genuine corporate transaction, subject to appropriate confidentiality and data-protection measures.

Where a provider processes personal data on our instructions, we use a written data-processing agreement and require appropriate confidentiality, security, assistance and deletion obligations. Professional advisers and public authorities may act as independent controllers under the law that applies to them.

International transfers

Personal data may be processed outside the DIFC and the United Arab Emirates. The Site’s servers are in London, United Kingdom. We may transfer personal data to a jurisdiction recognised by the DIFC Commissioner of Data Protection as providing adequate protection, or use an available mechanism under Article 27 of the DIFC Data Protection Law, such as appropriate standard contractual clauses and supplementary safeguards.

Brevo is established in France, which is recognised by the DIFC as adequate, but Brevo and other providers may use sub-processors in other jurisdictions. We review the relevant processing locations and transfer mechanism for the service used. You may contact us for further information about the transfer safeguard relevant to your personal data, subject to confidentiality and security restrictions.

Retention

We keep personal data only for as long as reasonably necessary for the stated purpose, including legal, security and record-keeping needs. Unless an exception is documented:

1. paper-request records are kept for up to 24 months from the request;
2. contact messages and related correspondence are kept for up to 24 months after the enquiry is closed;
3. subscription and consent records are kept while you subscribe; after unsubscribe, we keep only the minimum suppression and consent evidence reasonably necessary to honour the request and demonstrate compliance;
4. ordinary server logs are kept for up to 90 days, but a security record may be kept longer where needed to investigate or evidence an incident; and
5. records that become part of a separate working relationship are kept under the agreement, legal requirements and retention schedule that apply to that relationship.

When the applicable period ends, we delete or irreversibly anonymise the personal data, subject to proportionate backup cycles and a lawful hold.

Security and breaches

We use technical and organisational measures that are appropriate to the nature and risk of the processing. These include encrypted transmission, access controls, account protection, provider due diligence, patching and backup or recovery measures where appropriate. No internet service is completely secure, and we cannot guarantee absolute security.

We assess a suspected personal-data breach promptly. Where the DIFC Data Protection Law requires it, we notify the DIFC Commissioner as soon as practicable and notify affected people as soon as practicable where the breach is likely to result in a high risk to their security or rights.

Your rights

Depending on the circumstances and applicable law, you may have the right to: (a) be informed about processing; (b) obtain confirmation and access to your personal data; (c) correct inaccurate or incomplete data; (d) request deletion; (e) request restriction; (f) object to processing based on legitimate interests; (g) object at any time to direct marketing; (h) receive data you provided in a portable format where the legal conditions apply; (i) withdraw consent at any time, without affecting earlier lawful processing; and (j) not be subject to a decision based solely on automated processing that has a legal or similarly significant effect, subject to legal exceptions.

These rights are not absolute. An exemption or the rights of another person may affect our response. To make a request, use any route in section 1. We may ask for proportionate information to verify identity and authority. We normally respond within one month and may extend the period where the law permits because a request is complex or numerous; if so, we will tell you. We do not normally charge a fee, but the law may allow a reasonable fee or refusal for a manifestly unfounded or excessive request.

You may complain first to us using section 1. You may also complain to the DIFC Commissioner of Data Protection through www.difc.com/business/registrars-and-commissioners/commissioner-of-data-protection, or to another competent data-protection authority where applicable.

Children

The Site is intended for business and professional readers and is not directed to anyone under 18. We do not knowingly seek personal data from a child through the Site. If you believe a child has provided it, contact us so that we can assess and take appropriate action.

Other websites

Our regional platforms and third-party websites have their own privacy notices. This Policy does not govern their processing merely because the Site links to them. Review the relevant notice before providing personal data.

Changes to this Policy

We may update this Policy to reflect changes in law, technology or our processing. We will publish the revised version and last-updated date on the Site before or when it takes effect. Where appropriate, we will provide an additional notice for a material change.

Contact and complaints

For a privacy request, question or complaint, email privacy@furthermarkets.com, use www.furthermarkets.com/contact and select “Privacy request”, or write to Further Markets Technologies Ltd, DIFC Innovation Hub, Innovation One Building, 3rd Floor, Dubai AI Campus, Dubai, United Arab Emirates.