This event ('EU MDR & IVDR True Quality Summit Series') has 'Additional Privacy Statements'
The following Additional Privacy Statements (the "Additional Statements") have been added by the Event Organiser and are specific and in relation to this Event ("EU MDR & IVDR True Quality Summit Series") only. These set out additional Promotion and Insight activities that are being conducted by the Event Organiser and sets out additional data processing that they expect to do:
GREENLIGHT GURU PRIVACY POLICY
Updated Wednesday, August 29, 2018
Greenlight Guru, together with its parents, subsidiaries and affiliates (collectively, “Greenlight Guru,” “us,” “we,” or “our”) respects your privacy, and takes the responsibility of protecting the Personal Information (as defined herein) that you provide to us very seriously. This Privacy Policy describes how we collect, use, and disclose Personal Information we receive about individuals (collectively, “you” or “users”) using our products and/or services (our “Services”) and/or using our websites or online features (each a “Site” or collectively, our “Sites”).
We have adopted this Privacy Policy to explain what Personal Information may be collected in connection with the use of our Sites and/or Services, the purposes for which we may use that Personal Information, and under what circumstances we may disclose Personal Information to third parties. For purposes of compliance with the EU General Data Protection Regulation (“GDPR”), where applicable, we are the Controller of the Personal Information that we receive about you in connection with your use of our Sites and/or Services.
This Privacy Policy also describes your rights, where applicable, and how to exercise them. You may contact us at any time with questions related to our Privacy Policy and the processing of Personal Information and privacy at privacy@greenlight.guru.
This Privacy Policy applies regardless of whether you use our Sites and/or Services via a computer, mobile device, or any other platform or equipment (collectively, your “Equipment”).
A. TYPES OF INFORMATION COLLECTED
We collect the following kinds of information about users:
(1) Personal Information: For purposes of this Privacy Policy, Personal Information means any information relating to an identified or identifiable natural person. This includes any information that may be used to directly identify or contact you, such as your name, address, or phone number. Personal Information also includes information that may be used to indirectly identify you in combination with other readily available information, including by reference, for example, to an online identifier, location data, or an identification number. Certain information may not be Personal Information when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and address). Personal Information, as defined herein, is intended to cover all information subject to personal data processing and privacy laws applicable to our business.
Examples of Personal Information that we may collect from or about you include, among other things, your name, mailing address, phone number, email address, business contact information, payment information, username and password, demographic information, and any other information that meets the definition of Personal Information provided herein.
(2) Non-Personal Information: For purposes of this Privacy Policy, Non-Personal Information is any information that does not identify an individual, and cannot be used in combination with other readily available information to identify an individual.
(3) Device Information: For purposes of this Privacy Policy, Device Information refers to information that may be automatically collected from devices that you use when visiting or using our Sites. Examples of Device Information that we may collect from or about you include, among other things, IP address, device identifier, cookies, log files, and any other information that may be collected from your devices. Under some circumstances, Device Information may constitute Personal Information (i.e., if it can be combined with other information to identify an individual). However, Device Information does not always constitute Personal Information, and whether it does will depend on the circumstances.
B. HOW WE USE AND SHARE YOUR INFORMATION
(1) General Uses: We may use the information we collect from you for the purposes described below. When necessary to comply with applicable law, we will obtain your consent before using your Personal Information for any of these purposes:
Provision of Services to Users of Our Sites. If you use our Sites, we may use your information, including your Personal Information, to provide you with our Services, and to process and respond to your requests, comments, inquiries, and other forms you submit through our Sites.
Processing Online Purchases. We may use your information, including your Personal Information, to process any purchases made on our Sites, including, when necessary, disclosure of your Personal Information to third-party payment processors.
Improving our Services. We may use your information, including your Personal Information, to enhance our understanding of our users’ preferences in order to improve the quality, performance, and delivery of our Sites and/or Services.
Disclosures to Service Providers. We may share your information, including your Personal Information, with third-party service providers that assist us with hosting and maintaining the Sites, processing credit card information, analyzing online activity on the Sites, marketing our services, and managing our daily business operations and delivery of the Sites. We share only the minimum amount of Personal Information with these third-party service providers that they need to perform their tasks. We also enter into contracts with these third-party service providers that require them to protect Personal Information.
Compliance with Legal Obligations. We will share your information, including your Personal Information with law enforcement, government officials, regulatory agencies, or other parties when we are required to do so by applicable law. We will also disclose your Personal Information to comply with a judicial proceeding, court order, subpoena, or legal process.
Protection of Individual’s Vital Interests. In emergency situations, we will use or share your Personal Information when doing so is necessary to protect an interest that is essential for an individual’s life.
Other Legitimate Interests. We may use and disclose your Personal Information when necessary for our legitimate interests, including our legitimate business interests, as long as our legitimate interests are not overridden by your interests, rights, and freedoms with respect to your Personal Information.
De-Identified Information. We may also share and otherwise process aggregated or de-identified information that does not identify you individually, and such information may be shared with other parties. For example, from time to time, we may collect survey information from you on an aggregate and/or de-identified basis. We also de-identified information for various business purposes, including the creation, marketing, and sale of products and services to our customers and prospective customers. Such information is not traceable to any particular individual and will not be used by a third party to contact you.
(2) Legal Bases for Processing: To the extent required by applicable law, the legal bases for processing your Personal Information for the purposes described above or elsewhere in this Privacy Policy include, without limitation, that (1) you have given consent to the processing of your Personal Information for one or more specific purposes, (2) it is necessary to perform a contract with you (e.g., for the sale of goods or services) or in order to take steps at your request prior to entering into a contract; (3) it is necessary to comply with a legal obligation (such as notifying you of Privacy Policy changes); (4) it is necessary for the pursuit of our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Information; (5) it is necessary for your vital interests or those of another individual; and/or (6) it is necessary for the performance of a task carried out in the public interest.
The following is an overview of the purposes for which Greenlight Guru may process your Personal Information, and, where required by applicable law, the one or more legal bases that support such processing.
Purpose of Processing
Legal Bases for Processing
Provide you with Services and/or communicate with you (or your company/organization) about your accounts or your use of our Sites and/or Services.
· Perform or enter into a contract
· Legitimate business interests
· Comply with a legal obligation
Register or establish an account for you (or your company/organization) as a customer, and/or register you (or your company/organization) to receive information regarding our Sites and or/Services.
· Perform or enter into a contract
· Legitimate business interests
· Comply with a legal obligation
· Consent
Process transactions that you initiate through one of our Sites and/or Services.
· Perform or enter into a contract
· Legitimate business interests
· Comply with a legal obligation
Manage our relationship with you (or your company/organization) as a customer or prospective customer.
· Perform or enter into a contract
· Legitimate business interest
Identify you (or your company/organization) as a prospective or repeat customer and directly market our Sites and/or Services to you.
· Legitimate business interests
· Consent
Using metadata (e.g., usage statistics, access activity, customer data storage profiles, etc.) for internal purposes such as marketing, research, pricing, and technical/product development.
· Perform or enter into a contract
· Legitimate business interests
Using copies of any user-entered repository content for purposes of testing operations, scalability, and/or performance, or for other internal uses.
· Perform or enter into a contract
· Legitimate business interests
Monitor for and prevent security threats and fraud involving the user of our Sites and/or Services.
· Legitimate business interests
· Comply with a legal obligation
Communicate with you (and/or your company or organization) about your account or use of our Sites and/or Services.
· Legitimate business interests
· Consent
To enforce our legal rights related to our Sites and/or Services and/or defend against claims made against us.
· Perform or enter into a contract
· Legitimate business interests
Improve the quality of our Sites and/or Services.
· Legitimate business interests
Share information with third-party service providers who perform functions on our behalf (e.g., assisting us with hosting and maintaining the Sites, processing credit card information, analyzing online activity on the Sites, marketing our Services, and managing our daily business operations and delivery of the Sites and/or Services).
· Perform or enter into a contract
· Legitimate business interests
· Comply with a legal obligation
· Consent
(3) Processing for Direct-Marketing Purposes: For customers or users of our Sites and/or Services, we may use Personal Information gathered from your use of our Sites and/or Services for direct-marketing purposes.
To the extent required by applicable law, you have the right to object at any time to the processing of your Personal Information for direct-marketing purposes, and to opt-out from receiving such communications. If you no longer wish to receive electronic direct-marketing communications from Greenlight Guru, you may opt out of receiving such communications by using the unsubscribe method provided in our communications or by contacting us directly at privacy@greenlight.guru. You also have the right to object to our use of your Personal Information for direct-marketing purposes, where required by applicable law, by contacting us at privacy@greenlight.guru.
(4) Transfer of Assets: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the Personal Information and Non-Personal Information we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
(5) Other: Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any Personal Information or Non-Personal Information about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property of our Services, or other users; or (d) in an emergency to protect the health and safety of our customers or the general public.
C. CHILDREN
The features, programs, promotions, and other aspects of our Services requiring the submission of Personal Information are not intended for children. We do not market and do not knowingly collect Personal Information from children under the age of 16. Certain benefits of our Services may be restricted to adults, age 18 or older. If you are a parent or guardian of a child under the age of 16 and believe he or she has disclosed Personal Information to us, please contact us as provided in Section I below. A parent or guardian of a child under the age of 13 may review and request deletion of such child's personally identifiable information as well as prohibit the use thereof. If we discover that we have inadvertently collected information from a child under 13 years of age, we will promptly take all reasonable measures to delete such information from our systems.
D. KEEPING YOUR INFORMATION SECURE
We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse, and alteration of the information under our control. Please be advised, however, that while we strive to protect your personal data and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online or through our Services, and are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information. In the unfortunate event that your Personal Information (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by email (at our sole and absolute discretion) to the last email address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
E. OTHER SITES/THIRD-PARTY LINKS
Our Services may link to or contain links to third party websites that we do not control or maintain, such as in connection with purchasing products we may recommend or reference via our Services and/or advertisements you may see while using our Services. We are not responsible for the privacy practices employed by any third party website. We encourage you to note when you leave our Site and to read the privacy statements of all third party websites before submitting any Personal Information.
F. CONTACT & OPT-OUT INFORMATION
You may contact us as provided below if: (a) you have questions or comments about our Privacy Policy; (b) wish to make corrections to any Personal Information you have provided; (c) want to opt-out from receiving future commercial correspondence, including emails, from us or our affiliated companies; or (d) wish to withdraw your consent to sharing your Personal Information with others.
Email: privacy@greenlight.guru
Phone: 317-960-4220
Mail: 525 S. Meridian St., Ste 3A-1, Indianapolis, IN 46225
We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable, to the extent required by applicable law. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services.
G. SOLE STATEMENT
This Privacy Policy as posted on this Site is the sole statement of our privacy policy with respect to our Services, and no summary, modification, restatement or other version thereof, or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to the Site.
H. YOUR RIGHTS
For users from the European Economic Area (the “EEA”) or as required by applicable law, users have the following rights:
To access the Personal Information we maintain about you;
To be provided with information about how we process your Personal Information;
To correct your Personal Information;
To have your Personal Information erased;
To object to or restrict how we process your Personal Information; and
To request your Personal Information to be transferred to a third party.
To exercise the above rights, please contact us at the information provided above. We will consider and process your request within a reasonable period of time. Please be aware that under certain circumstances, the GDPR may limit your exercise of these rights.
I. RETENTION OF PERSONAL DATA
For users from the EEA or as required by applicable law, we will retain your Personal Information only as long as necessary to process your request or other submission, fulfill the terms of our service contract with you, and comply with applicable law.
J. HOW TO WITHDRAW CONSENT
At any time, users from the EEA (or other users to the extent required by applicable law) may withdraw consent you have provided to us for using, disclosing, or otherwise processing your Personal Information. You may withdraw your consent by emailing us at (privacy@greenlight.guru) and following the instructions in our communication to you.
Please note that your withdrawal of consent to process certain Personal Information about you (1) may limit our ability to deliver services to you and (2) does not affect the lawfulness of our processing activities based on your consent before its withdrawal.
K. HOW TO FILE A COMPLAINT
You may file a complaint regarding the Privacy Policy or our privacy practices by contacting us at the information we provide below. Additionally, users from the EEA may file a complaint with EU data protection authorities (DPAs). A list of DPAs from the European Commission may be found here:
http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061.
You may also contact us using the contact information provided above to be directed to the appropriate DPA contact(s).
L. MODIFICATIONS TO THIS PRIVACY POLICY
We generally keep this Privacy Policy posted on our Site. You should review this Privacy Policy frequently, as it may change from time to time without notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy. WHEN YOU USE OUR SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP USING OUR SERVICES. Please note, however, that if we decide to use your Personal Information in a manner materially different than what is provided in this Privacy Policy or what we advised at the time it was collected, we will notify you of this change by email to the last email address provided to us or through our Sites and/or Services. You will have a choice (by means of an “opt-out” opportunity) as to whether or not we use your information in this different manner. If you opt out, we will use your Personal Information in accordance with the terms in place when the information was collected.
HeySummit is not responsible for any part of the above Additional Statements and is only responsible for the Core Privacy Statements set out hereunder:
HeySummit's 'Core Privacy Statements'
The following Core Privacy Statements (the "Privacy Statements"), together with the Core Terms of Service and any other documents referred to herein set out we will use the data you provide us at www.HeySummit.com and/or www.app.HeySummit.com (the "Platform") and what Insight activities are ongoing there too.
Please read these Privacy Statements carefully and ensure that you understand them. You will be able to change your Privacy Preferences at any time throughout your time using the Platform and thereafter.
Purpose of this Privacy Statement
HeySummit’s purpose in establishing this Privacy Statement is to give you information about how HeySummit collects and processes your personal data through your use of the HeySummit Services, including any data you may provide through the HeySummit platform. If you do not agree with the terms, do not access or use the HeySummit Services, websites or any other aspect of HeySummit’s business.
This Privacy Statement applies to all users of HeySummits Platform and associated technology. It is important that you read this Privacy Statement together with any other Privacy Statement or fair processing policy we may provide on specific occasions when we are collecting, or processing, personal data about You, so that you are fully aware of how and why we are using your data. This Privacy Statement supplements other notices and privacy policies and is not intended to override them.
Controller/Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. HeySummit and Event hosts are independent controllers of certain types of your personal data, such as your registration data (like name and email) and attendance data (like Event name, date and time of Event, and Event sessions attended). Event hosts are the controller, and HeySummit is the processor of Event data, such as information and materials submitted to, or during an Event.
Changes to our Privacy Statement and your duty to inform us of changes to your personal data
We keep our Privacy Statement under regular review and it may be updated periodically. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will notify you by posting an updated, date-stamped version of this Privacy Statement on our website. If we make changes that materially alter your privacy rights, we will provide notice to you in accordance with applicable law. Notice may be by posting a notice on our website, by email to you at the email address that you most recently provided to us, or by other means, consistent with applicable law. Accordingly, please keep your account information, including email address, updated.
Your access to and use of third party websites or services accessible through the HeySummit Services
The HeySummit Services include links to third-party websites and applications as well as to partner providers of multiple different types of services associated with a particular Event.
Third party web sites and applications.
Clicking on links to third party websites, content or applications may allow those third parties to collect or share data about you. We do not control those third-party websites or content and are not responsible for their privacy statements or the way in which they collect or use your data.
Where you access or use third party services provided by an Event organiser, advertiser, sponsor or any other party who participates in an Event, we encourage you to request details of and read the Privacy Statement of that party. We do not control those third parties and are not responsible for their privacy statements or the way in which they collect or use your data.
1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identifying information has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data which includes your image and first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. This may also include other audio-visual content which you appear in as you contribute to or interact with an Event.
- Contact Data which includes your home address, email address and telephone numbers.
- Transaction Data which includes details about payments you have made and other details of products and services you have accessed or used through the HeySummit Services. We do not store card details on our server. Credit and debit card payments are processed by Stripe on their secure payments server and all card details are fully encrypted and stored by them.
- Technical Data which includes your internet protocol (IP) address, your login data, browser type and version, hardware information, time zone setting and location, browser plug-in types and versions, operating system and website, and other technology on the devices you use to access the HeySummit Services.
- Profile Data which includes your username and password, purchases or orders made by you, your interests, volunteer record, preferences, feedback and survey responses.
- Usage Data which includes information about how you use our Services, as well as third-party platforms which you have linked to your use of our Services. Usage data includes metadata which provides additional context about the way the Services are being used such as length of visit, page views, navigation paths, and page interaction information (such as scrolling, clicks, mouse-overs, and mouse tracking) as well as information about the timing, frequency and pattern of use.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and our third party partners and your communication preferences.
- User Generated Content which includes data you submit as part of an Event or as a result of your interactions with the HeySummit Services such as Event materials, videos, chats, and messaging. Please note, the host of the Event is the controller of this data.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with access to the HeySummit Services).
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and other Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you: (a) create an account with us; (b) subscribe (or are subscribed) to our services; (c) interact in an Event; (d) request marketing to be sent to you; (d) enter a promotion or survey; or (e) give us feedback or contact us.
- Automated technologies or interactions. As you interact with the HeySummit Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We also collect Usage Data via automated technologies as a result of your interaction with the HeySummit Services. We collect this personal data by using cookies, server logs and other similar technologies.
- Third-Parties. Depending on your use of the HeySummit Services, we may collect data about you from third-party service providers which you have linked to your use of our Services (including social media account and single-sign-on services), your employer, your administrator, the host of organiser of an Event you register for or attend, publicly available sources, data enrichment vendors, payment and delivery service vendors, advertising networks, analytics providers, and our business partners. The information which we receive from third parties depends on what policies that third party follows and our and your respective relationships with the third party.
3. How we use your personal data
The legal basis for using your information as set out in this Privacy Statement are as follows:
- Where we need to perform the contract we are about to enter into or have entered into with you (e.g. to provide you with access to the functionality of the HeySummit Services).
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we have your consent.
- Where we need to comply with a legal obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of legitimate interest
|
To register you as a user of the HeySummit Event Platform |
(a) Identity
(b) Contact
|
Performance of a contract with you |
To process any paid entry to an Event:
(a) Managing payments, fees and charges
(b) Verifying your identity and details of your payment method or credit card account
(c) Communicating with you, for example sending you confirmation of your attendance for an Event.
|
(a) Identity
(b) Contact
(c) Transaction
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
|
To manage our relationship with you which will include:
(a) Providing access to Platform services
(b) Notifying you about changes to our terms or Privacy Statement
(c) Asking you to leave a review or take a survey
(d) Investigating complaints
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how users use the HeySummit Event Platform and associated products/services)
|
To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our business, administering our CRM, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
Necessary for our legitimate interests (to study how users use the HeySummit Event Platform and to grow our business and inform our marketing and growth strategy) |
Share your information to support the Host or Event Organiser or Team Member(s) to create, manage and deliver the Event. |
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
To provide our own services as per our collective agreements and support the Event Organiser to conduct their agreements with you. |
To use data analytics to improve our Platform, products/services, marketing, user and Partner relationships and experiences. |
(a) Technical
(b) Usage
|
Necessary for our legitimate interests (to define types of users for certain Platform services and to keep our services and web site updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about Events or other services available through the HeySummit Event Platform that may be of interest to you |
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
|
Necessary for our legitimate interests (to develop the products and services available through the HeySummit Event Platform) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may opt out of any non critical marketing communications but some communications are directly related to the provision of our Services.
Recommendations from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which services and offers may be relevant for you. Subject to applicable law, we may send you information that we think may be of interest to you.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time. You can contact us or, where applicable, use the instructions located at the bottom of your email. Please note that regardless of your request, we may still use and share certain information as permitted by this Privacy Statement or as required by applicable law. For example, you may not opt out of certain operational communications, such as those reflecting our relationship or transactions with you.
Cookies
We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the HeySummit Services and your experience, see which areas and features of our Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Advertising and Analytics Services Provided by Others
We may allow others to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the HeySummit Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by HeySummit and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the HeySummit Services and other websites and better understand your online activity.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
- External Third Parties as set out in the Glossary.
- Third parties in connection with, or during negotiations of, any merger, sale or transfer of company assets, financing or acquisition of all or a portion of our business. 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 Statement.
Where third parties provide Events or support the provision of Services made available to you, these third parties may receive certain personal data about you. Whilst we are not in control of these third parties, we require all third parties to respect the security of your personal data and to treat it in accordance with the law.
To help constantly improve and tailor the service we provide to you, we may use aggregated information so that we can administer and improve our services, analyze trends, gather broad demographic information and detect suspicious or fraudulent transactions and most importantly monitor and improve our operations on a day to day basis. In carrying out this activity, we may pass some information to third parties in aggregate and anonymized format.
Your disclosure to third parties
Except as otherwise expressly included in this Privacy Statement, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, different rules may apply to their use or disclosure of the information you provide to them. HeySummit does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.
5. International transfers
We may transfer your personal data outside your country of residence, including the European Economic Area (EEA), in our performance of services.
Whenever we transfer personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- 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.
- Where 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.
- Where we use providers based in the US, we only transfer data to them under the scope of a Data Processing Agreement which incorporates Standard Contractual Clauses, or another legally applicable data transfer mechanism, which require them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. Data security
We have put in place commercially reasonable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 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. That said, no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or as required or permitted by applicable law.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
If you provide personal data in connection with the submission of Event Content, we may process sensitive personal data as part of the HeySummit Services.
This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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.
7. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Object to processing of your personal data. We will assess your request and determine whether we have any legal or other justification for continued processing.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month or within the timeline provided by applicable law. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. Contacting HeySummit
If you have any questions about this Privacy Statement or our privacy practices, including any requests to exercise your legal rights, please contact us as follows:
- Full name and address of legal entity: Hey Summit Ltd of 71 - 75 Shelton Street, Covent Garden, WC2H 9JQ
- Email address: support@heysummit.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). You may also direct your complaint or concern to your applicable data protection authority. We would, however, appreciate the chance to address your concerns before you approach the ICO or another data protection authority.
9. Glossary
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In respect to HeySummit, that is the performance of our agreement with you to make the HeySummit Services available. We are not involved in the processing of your Personal Data during any engagement you enter into with our third party partners.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
- Service providers acting as processors who provide our IT and system administration services.
- Providers of our cloud services such as AWS and Google.
- Stripe for the purposes of payment transaction management.
- Freshworks who provides our chat and customer support features.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
- Our third-party partners and affiliates whom you engage with through the use of the HeySummit Services in order to facilitate the provision of the HeySummit Services.
- Hosts or Event organisers whose Events you attend through your use of the HeySummit Services.
Submitting Requests
Requests to exercise your rights may be submitted by emailing us at support@heysummit.com Please be prepared to provide your first and last name and email address that matches information we currently have on file. Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from California consumers as required by law.