Effective Date: May 2022
I. COLLECTION OF INFORMATION
The information we collect about you may vary based on the nature of our relationship with you. Our Offerings provide customers with people intelligence services, such as information our customers may find useful in pursuing a business relationship with you, including:
- Information we collect from public resources. We may gather information about you from publicly accessible sources such as public registers, trade and industry references, professional directories, or print and broadcast media and company websites. This information may include your name, age, business contact information, employment history, investment history, family and professional affiliations, personal wealth ownership details and estimates, reputational background information, or litigation involvement.
- Data from other information providers. We also may gather information about you from information providers, or “data brokers,” such as demographic information, commercial or transactions information, and professional or employment-related information.
We also may also collect information about you when you use our Services, such as when you visit or use our websites or other Online Platforms, including:
- Information you provide directly to us.
- Contact and Sign-In Information, including username and password, name, email address, telephone or mobile phone number, address and other contact information you provide to us such as when you register with one of our websites or sign up for a free trial of our Services.
- Employment Information, including job title, such as when you register for an event or conference, or information about your social or business connections if you choose to upload that information to one of our websites. We may also collect information, consistent with your permissions, if you sync your electronic address book to your account on one of our websites or use various third-party tools, such as software widgets, to otherwise synchronize your calendar or contacts with our Services.
- Geolocation data, including geolocation information derived from your GPS, WiFi and Bluetooth signals, IP address, and other device information.
- Transaction and Billing Data, including bank account and payment card details, such as credit card number, expiration date, and credit card security code, billing address, and transaction history; and
- Correspondence you send to us, including correspondence related to our communications with you through email, messages sent to you through the Services, and surveys or polls which request your feedback on our Services.
- Information we collect automatically.
- We collect internet, electronic activity, and other information automatically from the devices, browsers, and apps that you use, including your device type; Internet protocol (IP) address; device and advertising identifiers, and other unique personal or online identifiers; time zone setting and location; browser type and version; browser plug in types and versions; operating system and platform; Internet service provider; pages that you visit before and after using the Services, browsing history, and search history; the date and time of your visit; information about the links you click, pages you view, and advertising you interact with within the Services and other information about how you use the Services; the technology on the devices you use to access the Services; standard server log information; and app usage data and files downloaded to your apps.
- If you engage with our content on social media, we may receive information about people with whom you are friends or otherwise connected.
- We may also automatically collect information from the emails we send you in order to determine if our emails are opened among other information.
- If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
We also receive some of the information described above from other sources, including from other users of our Services, marketing partners, entities that sell data, and third-party services and organizations. For example, if you access any social media or similar services through the Services to login or to share information about your experience on our Services with others, we may collect information from these third-party services. We may associate some of the personal information we automatically collect about you with information that we collect in other ways or receive from third parties.
II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING
We use and otherwise process each of the categories of information identified above for the following business purposes:
EEA lawful basis for processing, including basis of legitimate interest
To provide our Offerings.
Necessity for our legitimate interests (namely, to grow our business)
(a) Performance of a contract with you or our customers
(b) Necessity to comply with a legal obligation
(c) Necessity for our legitimate interests (for instance, to keep our records updated)
To make suggestions and recommendations about things that are similar to those that you or our customers have enquired about or may otherwise be of interest to you or our customers, or to send promotional materials from us or by our affiliates and trusted business partners.
Necessity for our legitimate interests (to grow our business)
To improve our Services and to ensure that content is presented in the most relevant and effective manner; to administer our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes; to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.
(a) Necessity for our legitimate interests (for running and protecting our business; for provision of administration and IT services; for network security and to prevent fraud; in the context of a business reorganisation or group restructuring exercise; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy)
(b) Necessity to comply with a legal obligation
Where legally required and we have no other valid legal basis to process your information, we will obtain consent (for example, to provide you with marketing information in accordance with applicable law), which may subsequently be withdrawn at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.
Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).
III. DISCLOSURE OF INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
- Our Customers. We share personal information with our customers as part of our people intelligence services and other Offerings. We require our customers to comply with applicable laws with respect to this data.
- Authorized third-party vendors and service providers. We share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.
- Corporate affiliates. We may share your information with our corporate affiliates, including Delinian Limited and its subsidiaries.
- Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
- Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of our corporate affiliates (including Delinian Limited and its subsidiaries), users, or the public.
- With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services such as social media services through the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of our Services, in accordance with their own privacy policies.
If you choose to engage in public activities on the Services, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.
IV. ADVERTISING, COOKIES AND SIMILAR TECHNOLOGIES
The following types of cookies are used on our Services:
- Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. For example, without these cookies, we cannot ensure the prompt loading of pages. These cookies also help keep our Services safe and secure.
- Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
- Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable Local Shared Objects and similar technologies. For example, Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt-out selection in your browser.
Some of our third-party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your information and what choices you may have, visit their site here. Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest-based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.
You also may be able to control our collection and use of your location information through your mobile device or app settings.
Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
V. YOUR RIGHTS AND CHOICES
You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, correction, deletion, and portability of your information or more information about our information practices. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
You can also update your email preferences at any time by clicking the “unsubscribe” link included in the emails we send you.
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you. Any difference in the Services are related to the value provided.
Depending on where you live, you may be able to lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful.
VI. INTERNATIONAL TRANSFERS
By using the Services and providing us with information, you understand and agree that we may transfer and store your information on servers located outside your resident jurisdiction. Some of the entities (such as third-party vendors) to which we disclose information may be located outside of the EEA, including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality, and we implement measures such as standard data protection contractual clauses to ensure that any transferred information remains protected and secure. A copy of these clauses can be obtained by contacting us at the address listed below.
We do not knowingly collect or sell any information from children, as defined by applicable law.
VIII. DATA RETENTION, SECURITY, AND INTEGRITY
Information will be retained only for so long as reasonably necessary for the purposes set out above and consistent with our retention policies, in accordance with applicable laws. Because we are in the business of providing information and people intelligence services to our customers, we will retain data in our secure database until we find that it is no longer useful to our customers.
We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
- CONTACT INFORMATION
Altrata Chief Privacy Officer
8 Bouverie Street
London, EC4Y 8AX
XII. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
XII. ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN THE PEOPLE’S REPUBLIC OF CHINA
Our Legal Basis for Processing the Personal Information
We will process your personal information in accordance with the principles of legality, legitimacy, necessity, and good faith. We will obtain your consent before processing your personal information. Especially, when we want to process your sensitive personal information, we will obtain your separate consent or your written consent according to laws and administrative regulations.
When it comes to the following purposes of using your personal information, we will request your consent. You will always be free not to respond. You could easily withdraw the consent at any time.
Advertising & Marketing
You’re fully aware that we may process your personal information outside the need to obtain the authority and consent from you, under any of the following circumstances:
- where it is necessary for the conclusion or performance of a contract to which you are a party, or for the implementation of human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with the law;
- where it is necessary for the performance of statutory duties or statutory obligations;
- where it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person;
- where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of personal information is within a reasonable scope;
- where it is necessary to process the personal information disclosed by you or other personal information that has been legally disclosed within a reasonable scope in accordance with the provisions of this Law; and
- other circumstances prescribed by laws and administrative regulations.
How We Share Your Information
We will not share your personal information with a third party unless we obtain your separate consent or in circumstances where your consent is not required according to laws and regulations.
We may share your name, job title, company, address, telephone number and email with event sponsors. Due to the event sponsors will differ from time to time, we will inform you of the name and contact information of the sponsors, purpose and method of processing and obtain your separate consent before sharing your personal information.
Storage Location and International Transfers
Your personal information will be stored in the UK. Therefore, Delinian Limited (https://www.delinian.com/), who is running the information system , will receive your personal information (name, job title, company, address, telephone number and email).
We may also share your personal information with our corporate affiliates, for them to send you marketing materials.
We will take necessary measures required by laws including obtaining your separate consent, concluding standard contractual clauses with the overseas recipient to stipulate the rights and obligations between us, and will ensure that the foreign receiving party provides adequate protection for your personal information under applicable laws.
Your Additional Privacy Rights
Under the stipulations of PIPL, you have the following rights:
- Right to access and copy: You can request access to your personal information or obtain a copy of your personal information.
- Right to correct and supplement: You can request that we to make corrections or supplements where you find that your personal information is inaccurate or incomplete.
- Right to delete: You can request the deletion of your personal information in certain circumstances (for example while you withdraw your consent, or the purpose of personal information processing has been achieved, it is impossible to achieve such purpose, or it is no longer necessary to achieve such purpose;)
- Right to transfer: You can transfer your personal information to a personal information processor designated by you when it meets the conditions stipulated by the authorities.
- Right to make decisions, restrict and refuse: You can make decisions on the processing of your personal information and restrict or refuse that we process your personal information.
- Right to withdraw your consent: You can withdraw your consent. Please understand that each service needs some basic personal information to be completed. After you withdraw your consent, we will not process the relevant personal information, and cannot provide you with the corresponding services as a result. However, withdrawal of consent by you will not affect the previous personal information processing based on your authorization.
For security, we may verify your identity before handling your request. After verifying your identity, we will respond to your request in time, and give a reply and reasonable explanation within 15 days after verifying your identity, or inform you of the external ways to solve the dispute.
We will not be able to respond to your request under the following circumstances:
- Related to our compliance with the obligations under the laws and regulations;
- Directly related to national security or defense security;
- Directly related to public security, public health or major public interests;
- Directly related to criminal investigations, prosecutions, trials and enforcement of court decisions, etc.;
- We have sufficient proof that you have subjective malice or abuse of rights；
- For the purpose of safeguarding your life, property and other important legal rights and interests or those of other individuals but it is difficult to obtain consent;
- Responding to your request will cause serious harm to your legitimate rights and interests, or those of other individuals or organizations.
- Involving trade secrets.
How to Contact Us
Altrata Chief Privacy Officer
8 Bouverie Street
London, EC4Y 8AX
12/F, V-Point, 18 Tang Lung Street, Causeway Bay, Hong Kong.
Protecting Your Data
We endeavor to keep your personal data secure and takes appropriate technical and organizational measures to protect your personal data from loss, unauthorized use, disclosure or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk.
All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.