Last Modified: September 15, 2021
1. What Information We Collect About You
Our Use of the Subscription Service
When You Visit our Website
You are free to explore the Website without providing any Personal Information about yourself. When you visit the Website or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.
We collect personal information from you when you submit web forms or interact with our Website, for example: subscribing to a London blog, signing up for a webinar, or requesting customer support. We also collect personal information when you sign up for a London account.
"Personal Information" refers to any information that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Website, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.
Personal Information includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.
Navigational information refers to information about your computer and your visits to the Websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Use of Navigation Information" section below.
Payment information includes information we collect and process from you when you subscribe to the Subscription Service, including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect other Sensitive Information from you.
This refers to credit or debit card numbers, financial account numbers or wire instructions, government issued identification numbers (such as Social Security numbers, passport numbers), biometric information, personal health information (or other information protected under any applicable health data protection laws), personal information of children protected under any child data protection laws, and any other information or combinations of information that falls within the definition of “special categories of data” under GDPR or any other applicable law relating to privacy and data protection.
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by London to provide general statistics regarding use of the Website. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.
Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.
Information About Children
The Website is not intended for or targeted at children under 16, and we do not knowingly or intentionally collect personal information about children under 16. If you believe that we have collected personal information about a child under 16, please contact us so that we may delete the information.
2. How We Use Information We Collect
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
improve your browsing experience by personalizing the Website;
develop and improve our products and services;
send information or London content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
provide other companies with statistical information about our users -- but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis;
contact you about billing, account management, and other administrative matters;
investigate and help prevent security issues and abuse; or
meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor located in the European Economic Area ("EEA"), London is the data controller of your personal information. London's Data Protection Officer can be contacted directly at the below address:
London Consulting Group Inc., Torre Cytrus, Av. Roble 660 suite 403, Valle del Campestre, Garza García Nuevo León, Mexico 66265.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Website and to provide you with a better experience when you interact with London. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about London. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
You may disable the collection and use of your location data through browser-, operating system- or device-level settings. Consent concerning location data may be withdrawn at any time.
Customer Testimonials and Comments
We post customer testimonials and comments on our Website, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.
Use of Payment Information
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Social Media Features
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in "To Unsubscribe from Our Communications" below.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the "How to Access & Control Your Personal Data" below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your London account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
The data our customers collect by using the Subscription Service is retained according to the relevant agreements with our customers.
3. How we Share Information we Collect
We employ other third-party service providers to provide services on our behalf to visitors to our Websites and our customers and users of the Subscription Service and may need to share your information with them to provide information, products or services to you. We might also share data with third parties but only if the data has been de-identified in a way so it cannot be used to identify you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis on your use of the Subscription Service or interactions on our Website, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and data protection policies and standards.
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by London on the Websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
4. How We Transfer Data We Collect Internationally
International Transfers within London’s Partner Entities
To facilitate our global operations, we transfer information to each related country and allow access to that information from countries in which the London partner entities have operations for the purposes described in this policy.
International transfers to third parties
London Consulting Group Inc. is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf.
5. Cookies and Similar Technologies
Last Modified: September 15, 2021
What are cookies?
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page.
Cookies set by the website owner (in this case, London) are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.
We use first party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Website and Subscription Service. For example, London keeps track of the Websites and pages you visit within London, in order to determine what portion of the London Website or Subscription Service is the most popular or most used. This data is used to deliver customized content and promotions within the London Website and Subscription Service to customers whose behavior indicates that they are interested in a particular subject area. Third parties serve cookies through our Website for advertising, analytics and other purposes. This is described in more detail below.
What types of cookies do we use and how do we use them?
The specific types of first and third-party cookies served through our Website and the purposes they perform. These cookies include:
Essential website cookies: These cookies are strictly necessary to provide you with services available through our Website.
Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Website but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Website are being used or how effective our marketing campaigns are, or to help us customize our Websites for you.
Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
- Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Website through third party social networking and other websites. These cookies may also be used for advertising purposes too.
How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided below.
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit www.aboutads.info/choices/ or http://www.youronlinechoices.com.
You may opt out by clicking here: http://optout.aboutads.info/ or http://optout.networkadvertising.org/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.
Essential website cookies: Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them. You can block or delete them by changing your browser settings however, as described above.
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to a website. We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the Website and Subscription Service by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs or pixels in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers' Personal Information.
Do you use Flash cookies or Local Shared Objects?
The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as "Flash cookies." London Consulting Group Inc. does not use Flash cookies.
Do you serve targeted advertising?
Third parties may serve cookies on your computer or mobile device to serve advertising through our Website. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.
Where can I get further information?
Navigational Information Collected by Our Customers
Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on the Subscription Service. HubSpot does not control our customers' use of these tools, nor do we control the information they collect or how they use it.
Flash Cookies and Other Third-Party Tracking Technologies
Third Party Tracking Technologies
6. How to Access & Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
You can request access, correction, updates or deletion of your personal information.
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
To exercise any of these rights, please contact us here or by mail to London Consulting Group Inc., Torre Cytrus, Av. Roble 660 suite 403, Valle del Campestre, Garza García Nuevo León, Mexico 66265, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
Our Acceptable Use Policy, applies to us and to our customers and, among other things, prohibits use of the Subscription Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service of an "opt-out" mechanism and other required information. We require all of our customers to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a customer can result in immediate suspension or termination of the Subscription Service.
To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by contacting us here or postal mail to London Consulting Group Inc., Torre Cytrus, Av. Roble 660 suite 403, Valle del Campestre, Garza García Nuevo León, Mexico 66265, Attention: Privacy.
Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.
7. California Privacy Rights
This section applies only to California consumers. It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act ("CCPA") requires businesses to disclose whether they sell Personal Data. London is a business, and does not sell Personal Data. We may share Personal Data with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data.
For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act (“CCPA”).
How We Collect, Use, and Share your Personal Information
We have collected the following statutory categories of Personal Information in the past twelve (12) months:
Identifiers, such as name, e-mail address, and phone number. We collect this information directly from you or from third party sources.
Commercial information, such as subscription records. We collect this information directly from you.
Internet or network information, such as browsing and search history. We collect this information directly from your device.
Geolocation data, such as IP address. We collect this information from your device.
Financial information, such as Payment Information or financial account numbers in the process of providing you with a subscription. We collect this information from you.
Other personal information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Subscription Service.
Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
How to Exercise your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information.
Please use the contact details below, if you would like to:
- Access this policy in an alternative format;
- Exercise your rights;
- Learn more about your rights or our privacy practices; or
- Designate an authorized agent to make a request on your behalf.
8. Data Protection Officer
Data Protection Office
London Consulting Group Inc.
Torre Cytrus, Av. Roble 660 suite 403,
Valle del Campestre, Garza García
Nuevo León, Mexico