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Effective: October 8, 2020

Welcome to the Cit Journal website (the “Site”), owned and operated by the Manhattan Institute for Policy Research, Inc. (“Manhattan Institute,” “we,” “us,” or “our”). The Site is designed to serve as an online magazine resource for parties interested in City Journal and the Manhattan Institute.

The following Privacy Policy describes how we collect, use, and share information you provide to us through your use of the Site or any other Manhattan Institute apps or websites linking to this Privacy Policy  (collectively, the “Services”), when you attend our events or otherwise interact with us. By using or visiting the Services, you acknowledged and agree to be bound by this Privacy Policy.

We reserve the right to change this Privacy Policy at any time, effective immediately upon posting on the Services. Please check this page of the Services periodically for such changes. Your continued use of the Services following any changes to this Privacy Policy will constitute your acceptance of such changes. You agree that the information that we gather now will be subject to the Privacy Policy in effect at the time of use.

The Manhattan Institute for Policy Research, Inc. is the controller for the purposes of applicable data protection law and is responsible for the personal information collected and used as described in this Privacy Policy. We are headquartered at 52 Vanderbilt Avenue, 2nd Floor, New York, NY 10017.

If you have any questions regarding this Privacy Policy, please send an email to legal@manhattan-institute.org or write to 52 Vanderbilt Avenue, 2nd Floor, New York, NY 10017.

Information We Collect

Both information you provide and information collected automatically can be used in marketing communications. You can ask us to stop sending you marketing communications at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Information You Provide.

“Personal information” (as the term is used in this Privacy Policy) means any information about an individual from which that person can be identified and includes information such as your name, mailing address, phone number or email address.

We collect personal information that is provided to us by our members, event attendees, donors, Service users and others, which may include:

  1. Contact information, including name, alias, email address, telephone or mobile phone number, or address.
  2. Sign-in information, including email and password, account name, account number.
  3. Membership information and survey responses, including your interests, preferences, demographic information, feedback, educational or professional information, employment, employment history, marital status, date of birth, age, national origin, sex, medical condition, military/veteran status.
  4. Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  5. Geolocation data.
  6. Transaction and billing data, including bank account and payment card details, (credit card number, expiration date, and credit card security code, where needed to complete a transaction), billing address, delivery address, signature, and transaction history.
  7. Correspondence you send to us, including but not limited to contact information, photographs, and videos.
  8. Event information, such as the contact data you provide when you register for an event, and a record of your participation in our events as an attendee, presenter or a member of the press.
  9. Candidate information, such as employment history, qualifications, academic qualifications and education records, and any other information that you provide to us when applying for a role, for example in your curriculum vitae, a covering letter, on an application form or during an interview, or that we have received from a recruitment agency or background check provider.

In addition, we collect personal information from publicly available sources, such as corporate and industry websites, social media platforms (such as LinkedIn), press releases and other news outlets. When new staff members join the Manhattan Institute, they may also have contacts from their previous employment. Personal Information relating to these contacts will be processed in line with this Privacy Policy.

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

Information Collected Automatically

We also may collect certain information automatically when you visit the Services, including:

  • Your browser type and operating system;
  • Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
  • Sites you visited before and after visiting the Services;
  • Pages you view and links you click on within the Services;
  • Information collected through cookies, web beacons, and other technologies;
  • Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded; and
  • Standard server log information.

We may use cookies, pixel tags, and similar technologies to automatically collect this information. Cookies are small bits of information that are stored by your computer’s web browser. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Services, you consent to our use of cookies and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services, or features on the Services.

We also may allow third parties to place and read their own cookies, web beacons, Local Shared Objects, and similar technologies to collect information through the Services. For example, our third-party service providers may use these technologies to collect information that helps us with traffic measurement, research, analytics, and/or advertising.

How We Use Personal Information

We process your personal information for the purposes set out in this Privacy Policy only where we have a valid legal ground for doing so under applicable data protection law.  The legal ground will depend on the purpose for which we process your personal information.

We will process your personal information for the following purposes as is necessary for the performance of our obligations under a contract with you, or to answer questions or take steps at your request prior to entering a contract:

  1. to answer your questions, provide you with the information, products and services that you request from us;

  2. to allow you to participate in interactive features of our Services, when you choose to do so;

  3. to manage accounts, membership or donations;

  4. to administer registration, payments and your attendance to our events;

  5. to manage our relationship with you; and

  6. to notify you about changes to our terms or this Privacy Policy.

We will process your personal information for the following purposes as is necessary for certain legitimate interests, or pursuant to your consent to the extent required by applicable law (such consent can be withdrawn at any time):

  1. to administer our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes;

  2. to make suggestions and recommendations to you about things that are similar to those that you have enquired about or may otherwise be of interest to you;

  3. to send promotional materials from us or by our affiliates and trusted business partners;

  4. to tailor the Services to you and for internal purposes such as analytics to improve the Services;

  5. to improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device;

  6. to keep our Services, business and users safe and secure;

  7. to comply with applicable laws and regulations; and

  8. to protect or exercise our legal rights or defend against legal claims.

If you apply to work for Manhattan Institute, we will use your personal information in the following ways as necessary in our legitimate interests, and to decide whether to enter into a contract with you:

  1. to assess your skills, qualifications, and suitability for the role you have applied for;

  2. to carry out background and reference checks, where applicable;

  3. to communicate with you about the recruitment process;

  4. to keep records related to our hiring processes; and

  5. to comply with legal or regulatory requirements.

Except as described below (see “Information We Share”), we do not share your personal information with any third parties except (1) if we determine that an applicable law, regulation or legal process requires it; (2) in response to a request from law enforcement personnel; or (3) if we determine that we need to share such information with others to protect the Services and/or to protect or enforce our rights.

Information We Share

Personal Information. We may share your personal information with our corporate parents, subsidiaries, or other affiliated entities, as well as with service providers that perform certain functions or services on our behalf (such as hosting the Services, managing our databases, or performing analysis). In addition, if we sell all or part of the Manhattan Institute, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, we may transfer your information — including personal information — to one or more third parties as part of that transaction. In addition we may share your personal information (1) if we determine that an applicable law, regulation or legal process requires it; (2) in response to a request from law enforcement personnel; or (3) if we determine that we need to share such information with others to protect the Services and/or to protect or enforce our rights.

Aggregated Information. We do not link our cookies or your IP address to any of your personal information. We may aggregate this information, and/or other information that does not describe or identify individual users, with that of other users and analyze it to improve the Services. We may share aggregated information with potential partners, advertisers, investors, content providers and customers in connection with the promotion of our services. However, this aggregated information does not include personal information.

Sharing on Social Networks. We have worked with certain third-party social media providers to offer you their social networking services through our Services. For example, you can use third-party social networking services, including but not limited to Facebook, Twitter, and others, to share information about your experience on our Services with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Services. These third-party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.

Social media

Manhattan Institute and its brands utilize social media channels as an open communication platform through which users can learn more about our work, our scholars, our values and our ideas. Social media is a vital part of promoting the Institute’s research and engaging with other researchers, journalists, and policymakers. Our goal is to provide content that is valuable, relevant, and timely.

Please note: external blogs, newsletters, social media posts, etc. that do not fall within an MI scholar’s issue portfolio are independent products and are therefore not connected with or affiliated with the Manhattan Institute.

External outlets, when mentioning or alluding to work produced by the Manhattan Institute, should tag, cite, or reference the original source. External outlets may be asked to edit or change content that falsely or inaccurately depicts scholarly thoughts or work posted in this space. 

How Long We Retain Personal Information

We will store your personal information, in a form that permits us to identify you, for no longer than is necessary for the purpose for which the personal information is processed.  We store your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically and reasonably feasible to remove it.  Otherwise, we will seek to delete your personal information within a reasonable timeframe upon request.

Other Practices

No Absolute Safeguards. Although we will use reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Accordingly, we assume no responsibility or liability for disclosure of your information (personally identifiable or otherwise) due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.

Children. We will not knowingly collect personally identifiable information from children under age 13.

Third Parties. We do not control the privacy policies of third parties that have websites linked to the Services. For instance, we may provide tools allowing you to share articles on the Services, or to support Manhattan Institute financially, through services such as Facebook or Twitter. If you click on a link or use such tools, the privacy policies of the website that you link to will govern the use of your information by that website’s operator. We assume no responsibility or liability for the actions of third parties with respect to their use of your information. Accordingly, make sure you are aware of, and comfortable with, the privacy policies of any third-party websites you link to.

International UsersThe Manhattan Institute is headquartered in New York.  Where you provide your personal information from locations outside of the United States, it will be transferred and stored on our servers in the United States.  In addition, we employ third-party vendors, consultants, and other service providers to store and process personal information on our behalf. These companies may be based in the United States or around the world.  United States data protection and other relevant laws may not be equivalent to the laws in your country of residence. By using the Services, or otherwise providing your personal information to us, you acknowledge and agree to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States, as described in this Privacy Policy.

European Residents.  If you are a resident of the European Economic Area or the United Kingdom,  we will only process your personal information for a purpose described in this Privacy Policy if (1) you have provided your consent (which can be withdrawn at any time), (2) the processing is necessary for the performance of a contract we are about to enter into or have entered into with you, (3) we are required by law, or (4) the processing is necessary for the purposes of our legitimate commercial interests (except where such interests are overridden by your rights and interests).

In certain circumstances you have the right to access, correct, restrict the processing of, delete or transfer the personal information we hold about you.  Where you believe that we have not complied with our obligations under this Privacy Policy or European privacy law, we ask that you contact us first to see if we can resolve the issue. However, you have the right to make a complaint to an EU supervisory authority, such as the UK Information Commissioner’s Office.

Correct/Update Personal Information. If you would like to review, update, change, or delete information that we have collected from you, please send an email to legal@manhattan-institute.org or write to: 52 Vanderbilt Avenue, 2nd Floor, New York, NY 10017.

 

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