Last updated May 2018

Introduction & General Terms

Who we are

What data we collect

How we use your data

How we keep your personal data secure

Who we share your personal data with

How long we keep your data

Personal Data – Your rights

Contact our Data Privacy Team

Introduction & General Terms

This document (“Privacy Policy”), in combination with the Cookies Policy make up our commitment to protecting personal information we hold about our regular readers, website visitors, newsletter subscribers or any other data subject whose personal information we hold. Personal information as outlined in this policy is being processed by Expatra (UK) Ltd (“we” “our”, “us”, “Expatra”, “Expat Savings Review”). You can find out more about us and the Expat Savings Review website by visiting http://expatsavingsreview.com/about/.

In the event of Expatra being sold or going into receivership, we reserve the right to continue to share your data to third parties in accordance with the latest preferences that you have provided. You will be informed should any change of ownership occur, and the new owner will manage your personal information preferences.

Our Commitment to you

We are committed to managing & safeguarding your personal information in accordance with current legislation and best practices.Our aim is to be responsible, relevant and secure when using your data.

Whenever you provide personal information, we will treat the information in accordance with this Privacy Policy.

We will process the personal information that you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure experience. These are what we consider to be our ‘Legitimate Interests’. We will endeavour at all times to keep your data accurate and secure, and to honour your data preferences with regard to the receipt of direct marketing, for example, email messaging and telephone calls.

Our website contains hyperlinks to websites that are owned and operated by third parties. These third-party websites have their own privacy policies, and are also likely to use cookies, and we therefore urge you to review them. They will govern the use of personal information you submit when visiting these websites, which may also be collected by cookies.

We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.

We may use third-party suppliers to provide part of our service to you. In some circumstances these providers may be based in countries outside of the European Economic Area whose laws provide for a different standard of protection for your personal information than that provided under UK Law. In such circumstances:

a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

b) When we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details see European Commission: Model contracts for the transfer of personal data to third countries.

c) Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the European Union and the US. For further details, see European Commission: EU-US Privacy Shield.

If you would like further information about the specific mechanism used by us when transferring your personal data out of the EEA please contact: enquiry@expatsavingsteam.com.

Your personal data will not be disclosed to state institutions and authorities except if required by law or regulation. Before were lease data on this basis, we will ensure that the information is being provided to a genuine and properly authorised investigation.

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to email all of our registered readers to make sure that they are informed of such changes. However, it is your responsibility to check this Privacy policy before each use of this website.

Who We Are

Expatra are an online publishing and marketing company that specialises in expatriate overseas lifestyle and personal finance with two primary online publications.

The online publication Expat Savings Review – Publishes news, stories and information about personal finances, savings and investment and financial news orientated to professionals living and working abroad.

The Website Expatra – Publishes news, stories and information for retirees living abroad.

Our publications also contain marketing content from our primary sponsor Abbey Wealth, a whole of service financial advisory who specialise in expatriate wealth management and financial advice for retirees abroad.

What Data We Collect

When you send us information, talk to us over the phone, submit an online form or when you visit one of our websites, we may collect both personal and pseudonymous data about you.

Data you provide to us

Data we collect through your use of our websites

When we talk about personal data we mean information that can identify you as an individual, such as your name and email address.Pseudonymous data doesn’t identify you as a person, but it might be used in aggregate data, for instance when you participate in a survey or when we analyse reader interaction with our websites or email marketing campaigns.

Data you provide to us

When you participate in, access, or sign up to any of our information services or online content, such as guide downloads or newsletters,we receive personal information about you. This can consist of information such as you name, email address and phone number as well as information we may collect about your use of the service (such as which page you entered our site from, how long you spent on the site, other pages you may have looked at).

Data we collect through your use of our websites

We may collect information about how you use our websites or other online content and the devices that you used to access our services. This includes collecting unique online identifiers such as your IP address, this number can be used to identify a specific computer or other device that has connected to the internet.

Anonymous data will be recorded for the purpose of reporting website statistics, advertisement ‘click-throughs’, and/or other activities on our websites. We may receive information about you from any third parties we may partner with through the use of cookie technologies to personalise advertisements for goods and services (please see Online Advertising below for further information).

To opt out of receiving advertisements tailored to your interests by our partners, visit the European Interactive Digital Advertising Alliance at http://youronlinechoices.eu

For detailed information on Cookies we use please see Cookies and how we use them as well as our Cookie Policy.

How We Use your Data

We may use the information you share with us and the information we collect through your use of our sites in the ways described below and as described at the time of capture.

Newsletters

Events

Research

Direct Marketing

Cookies and how we use them

Analytics

Online Advertising

Links to third party websites

Using our websites from outside of the UK

Newsletters

We will use the details that you have shared with us to send you the newsletter to which you have subscribed. We will not add them to any marketing lists unless you have consented to this. We will provide a way for you to unsubscribe on every newsletter we send to you. Details you share with us for the purpose of the newsletter subscription will never be shared with a third party.

Events

We will use the details you have shared to manage your registration and entry into our event. This may include contact via telephone,email, SMS and post with information relating to the event you have registered to attend.

Your data will not be added to any marketing lists unless you have consented to this, and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data, or where they are a third party who we have appointed to manage delivery of the event.

Research

We may use the information you provide to invite you to participate in surveys and focus groups about our products, advertisers and their services. Participation will always be voluntary and the answers that you provide will be anonymous and aggregated to support our learning and to help inform changes that we can make to improve our products and services.

Your data will not be added to any marketing lists unless you have consented to do this and were informed at the point of data capture and will only be shared with third parties where we have appointed them to manage research activity on our behalf.

Direct Marketing

We may use the details that you share with us to send you offers and promotions by email, telephone or SMS wherever we have legitimate grounds to do so and where you have not objected. We will provide a way for you to opt out of receiving marketing promotions both at the time of data capture and every time we contact you thereafter.

You can also email enquiry@expatsavingsteam.com to request that your details are supressed from all promotional campaigns.

We won’t use your personal data for marketing purposes at all if you’ve told us not to.

Legitimate Interest

We may process your personal data on the basis of a legitimate interest which may include promoting similar services or products via direct marketing activity, to manage suppression and unsubscribe requests received from you, to identify and prevent fraudulent behaviour, maintain security of our systems, data analytics, enhancing, modifying or improving our service, identifying usage trends and determining the effectiveness of our campaigns.

Whenever we process data for these purposes we will ensure that we always keep your personal data rights in high regard and take account of these rights. Find out more about your rights and how to exercise them here.

“Cookies” are small text files which our website Expat Savings Review may put on your computer or mobile device when you visit a site or a page. The cookie will help the website to recognise your device the next time you visit.

Cookies serve multiple functions. For example, they can help us to remember your username and any personal preferences that you have set up.They also enable us to analyse how the website is performing. If any pages carry advertising space, cookies can help us to display ads that are more relevant to you.

Certain cookies may record personal information – for example, if you click “Remember Me” when logging in, a cookie will store your username. We don’t use any cookies that specifically collect information that could be used to identify you. Instead we collect more general information such as the page that a visitor first arrives on when they come to our site, how long they spend on the site, any other pages they may read and finally the last page they were on when they exited the site.

The Types of Cookies We Use

1: Essential Cookies – These cookies are essential in order for you to move around the site and use all of the site’s features without problem. An example of this type of cookie use is if we need your consent before showing content.  Also, when you have a shopping cart this type of cookie is essential to maintain the cart’s accuracy.

2: Performance Cookies – These cookies allow us to collect information about how visitors interact with the website, for instance which pages visitors read most often, or any error messages that visitors get when they visit pages. These cookies do not hold any personal information that would enable someone to identify the visitor. All information from these cookies is aggregated and anonymous. The data collected is only used to improve website performance and functionality.

By using the Expat Savings Review website, you agree we may place this type of cookie on your device unless you have disabled them.

3: Functionality Cookies – These cookies enable the website to remember choices that a visitor has made, such as your user name,locality, or when applicable the preferred language. The cookie can also remember if you’ve made specific changes to the content layout, for example increasing font size.

By using the Expat Savings Review website, you agree we may place this type of cookie on your device unless you have disabled them.

4: Targeting or Advertising Cookies – These cookies are used to deliver adverts that are more relevant to you and your interests.They are also used to limit the number of times that you see any particular advertisement as well as to measure the effectiveness of individual advertising campaigns. Normally these cookies are placed by advertising networks with our permission to do so. They will remember that you have visited our website and will share that information with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

By using the Expat Savings Review website, you agree we may place this type of cookie on your device unless you have disabled them.

5: Third Party Cookies – Advertisers sometimes use their own cookies to provide you with targeted advertising. For example,advertisers may use a visitor profile they have built on sites that you have visited previously to present you with more relevant advertisements during your visit to the Expat Savings Review website.  We believe that it is more useful to our visitors to see advertisements that are more relevant to their interests and needs. If you are based in the European Union and would like to learn more about how advertisers use these types of cookies, please visit www.youronlinechoices.com. If you are based in the United States and would like to learn more, please visit www.aboutads.info/choices.

We also allow third parties to serve cookies that fall into the four categories discussed above. For example, we use Google Analytics to help us monitor our website traffic. We may also use third party cookies to help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions and copyright policy. If you click on a hyperlink from Expat Savings Review to any other third-party website,you may be sent cookies from these third-party websites. Please check the third-party websites’ own privacy and cookie policies to learn about how they manage them.

Can I block Expat Savings Review cookies?

As explained above, cookies help you to get the most out of our website. The first time you access our website, you should see a banner which explains that by continuing to access our sites, you are consenting to our use of cookies.

However, if you wish to disable our cookies then please follow the instructions on www.aboutcookies.org.

Please remember that if you disable cookies, you may find that parts of the Expat Savings Review website do not function properly.

For more information on how we use cookies please read our Cookie Policy.

Analytics

The Expatra portfolio of websites uses Google Analytics as its primary solution for tracking website visits, interaction and events. Expatra uses website analytics data to help improve the way we deliver content and online experiences to visitors.

For full details of how Google process your data please visit:

https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008

Online Advertising

Some of the Expatra portfolio of websites show advertising to users. A certain amount of this advertising is tailored to the individual user,a practice known as “Online Behavioural Advertising” which uses cookies to discover general information about the pages that you visit. This keeps our websites and many services you use free of charge. Our advertising delivery systems and partners use the limited information available to it to serve adverts to you, which it believes are relevant.  It does not collect personal information such as your name, email address or phone number.

From time to time, Expatra may share this aggregated data with our advertising partners. This could mean that when you are on other websites you are served advertising based on your behaviour across Expatra publications or you may be served advertising based on your behaviour on other sites.

Behavioural retargeting is another form of Online Behavioural Advertising that enables us and our advertising partners to show you adverts based on your browsing patterns and interactions on our sites and away from our sites.  For example, if you visited a holiday booking website you may start seeing adverts for that holiday site on Expatra publications showing the same destinations that you read about on the holiday booking website. This allows companies to advertise to website visitors who left their website without making a purchase.

If you want to opt out of receiving Online Behavioural Advertising this does not mean that you will no longer receive advertising when you visit our sites. It just means that the advertising will not be adapted for you. If you would like more information about online behavioural targeting and how to opt out of it, please visit http://www.youronlinechoices.com/.

When you click on advertisements or outbound links on any of our sites, you will leave that site and go to a third-party site which is outside of our control. When we place an advertisement on one of our sites, it does not signify that we are endorsing that advertiser’s product or service.

We do not accept responsibility for content that we have no control over and our Privacy policy does not apply to these companies, sites or content and if such third-party sites collect personal data, we cannot control how that data is processed, stored or used. We advise you to read their privacy policy and associated data collection statements before you submit any personal information.

Using our websites from outside the UK

We use servers that are located in the EEA to store data.When you submit your details in whichever country you are situated, you agree to the data being transferred to the EEA and processed under the terms of Regulation (EU) 2016/679 (GDPR) including any implementing data protection legislation in the UK.

If you are not in agreement, please do not add any personal details to the website. Expatra make no representation or warranty that the content and other media objects on the Website are appropriate or available for use in locations outside of the United Kingdom.  Those who choose to access the Website or use the services from other locations do so at their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent applicable.

How we keep your data secure

Expatra’s security policies, rules and technical measures have been implemented to protect your personal information from unauthorised or improper use and from accidental loss.

All our employees and data processors that have access to and are associated with the processing of your personal information are legally obliged to respect the confidentiality of your data are bound by contract to do so.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Who we share your personal data with

Expatra have formed partnerships with various carefully selected companies that we share data with in order to carry out the activities described in the section How we use your data. Below is a non-exhaustive list of our primary partners.

Fulfilment Partners: Barclays Bank, Paypal, MailChimp

Marketing Partners: Facebook, Twitter, Google

Advertising Technology Partners: Google, Crazy Egg, Matamo, Instapage, Unbounce

We may also have to share your personal data with third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

How long we keep your personal data for

We will hold your personal information on our systems for as long as required to provide you with the products/services that you have requested.

Where you sign up to receive email marketing from us we will retain your email address after you ‘opt-out’ of receiving emails in order to ensure that we continue to honour and respect that request. To unsubscribe from email marketing at any time, please click the unsubscribe link at the bottom of any marketing email and update your account preferences.  You may also contact us to inform us if you do not wish to receive any marketing materials from us.

In some circumstances you can ask us to delete your data:see ‘Your rights’ below for further information.

In some circumstances we may anonymise your personal data(so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Personal Data – Your Rights

Under the GDPR including any implementing data protection legislation in the UK you have the rights shown below: –

1) Your right to be informed

2)Your right of access

3)Your right to rectification

4) Your right to erasure

5)Your right to restrict processing

6)Your right to data portability

7)Your right to object

8)Your rights in relation to automated decision making and profiling

Right of Access

You may at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of a request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right which is described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data that you have supplied us with is correct.  Further, we are always obliged to erase personal data when asked to do so. If for any reason we believe that we have good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time that we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the How we use your data section of this Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful, but you do not want us to erase it (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party, you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to stop receiving communications

For details on your rights to ask us to stop sending you various kinds of communications, please contact us .

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved,as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

If you wish to exercise any of these rights or simply wish to find out what information, if any, we hold that relates to you, you must make your request in writing by sending an email to enquiry@expatsavingsteam.com.

You can help us to process your request quickly by providing us with information that will help us identify records we hold that relate to you. For example your name, address, email address, telephone number,subscriber id or in the case of information captured via cookies, the IP address of the device you have used.

Contact our Data Privacy Team

If you have an enquiry or concern about the contents of our Privacy Policy or our handling and use of our data, please email our Privacy Team enquiry@expatsavingsteam.com . If you are not satisfied with our response to your enquiry or concern, you may wish to contact the Information Commissioner via their website.

If we decide to change our Privacy Notice we will post these changes on this page so that you are always aware of the information that we collect, how we use it and in what circumstances we disclose it.