Privacy Policy, effective August 23, 2018

  1. OUR APPROACH TO PRIVACY

1.1 Hosts Destination Services, LLC and its affiliates (listed in the “Affiliates” (Section 14 below) (“Hosts Destination Services”, “Company” “we“, “our“, or “us“) are committed to respecting your privacy. We are committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”), and individuals who register to attend Customer’s corporate events (“Attendees”). This Privacy Statement describes Company’s’ privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by Company (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal information.

1.2 We collect data about users of our websites, blogs, mobile sites, or applications; about individuals that attend events organized, hosted or managed by us; and about our clients (where these are natural persons) or their employees, agents and representatives (and these individuals about whom we collect data are referred to as “you” in this Privacy Policy).
1.3 We may collect data that identifies or is associated with you (“personal information“) when you access our websites, blogs, mobile sites, applications, widgets and other interactive features, when you register or attend an event organized or hosted by us, or when you otherwise contact us (“Public Services“).
1.4 We may also collect personal information about you when we provide services or market our services (“Client Services“) to you, your employer, or any other person that has authorized you to communicate with us regarding the provision of Client Services to them in accordance with our client agreement.
1.5 This Privacy Policy sets out how we collect, store, process, transfer, share and use your personal information.
1.6 Before accessing, using or receiving our Public Services or Client Services, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this privacy policy.

  1. DATA CONTROLLER

2.1 The identity of the data controller of the personal information we hold about you will depend on if you are engaging with Hosts Destination Services, LLC or any of our affiliates, or if you access, use or receive our Public Services or Client Services. Please refer to our list of Offices below to determine who the applicable data controller is for the office you are engaging with.

  1. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

Information you provide to us
3.1 We collect personal information about you when you voluntarily submit information directly to us when you access, use or receive the Public Services or the Client Services. This can include information you provide to us when you submit an inquiry through our website, register for and/or attend an event, correspond with us by phone, email or otherwise, subscribe to our mailing lists, client alerts, newsletters or other forms of marketing communications, provide information requested by us to comply with our professional and Client obligations, or in connection with our provision of the Client Services.
3.2 If you choose not to provide personal information, we may not be able to provide some or all of the Public Services or Client Services to you or respond to your other requests.
3.3 When you use the Public Services, the categories of information we collect may include:

  • contact information
  • business information
  • employment information
  • location information
  • information provided by third parties
  • your comments and opinions that you express when you comment on a blog post, contact us by email, mail or phone.

We use this information to operate, maintain and provide to you the features and functionality of the Public Services, to address your questions and concerns, to personalize your content so that it is relevant to the city or country you are using your device in, to contact you, including sending you news, alerts and marketing communications, and to help us develop new products and services.
3.4 The table at Appendix 2 further sets out the categories of personal information we collect about you when you use the Public Services and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the personal information.
3.5 When you use Client Services, the categories of information we collect may also include:

  • identification information
  • instructions and information about payment and transaction information

We use this information to provide you with the Client Services in accordance with our agreements; to communicate with you; to comply with our professional or Client obligations and to facilitate our internal business operations.
3.6 The table at Appendix 3 further sets out the categories of personal information we collect about you when you use the Client Services and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the personal information.
Information we collect about you automatically
3.7 We also automatically collect personal information about you indirectly about how you access and use our websites, blogs, mobile sites, applications, widgets and other interactive features (the “Online Services“) and information about the device you use to access the Online Services. For example, we may collect:

  • information about how you view the Online Services (e.g., the pages you view, the links you click);
  • information about your browser and usage patterns (e.g., your IP address, browser type and language); and
  • information about the device you use to access the Online Services (e.g., device identifier, device type, model and manufacturer)

We use this information to: present our Online Service to you on your device; determine news, alerts and other products and services that may be of interest to you for marketing purposes; and monitor and improve our Online Services and business, and to help us develop new products and services.
3.8 The table at Appendix 4 further sets out the categories of personal information we collect about you automatically and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the personal information.

  1. PERSONAL INFORMATION WE SHARE WITH OTHERS

4.1 As required in accordance with how we use it, we will share your personal information with the following:
(a) Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.
(b) Affiliates. Other affiliates of Hosts Destination Services, LLC so that they can provide you with client updates, information and marketing messages about products or services that may interest you.
(c) The public. When you use our Public Services, content and information that you post on message boards, blogs or other services on our website, or that you allow us to make public, may be available to other visitors to our websites and to the general public. When you use our Client Services, to the extent you have given us consent to do so, we may also share your name and the company you work for together with comments and feedback on our Client Services.
(d) Client directories. When you use our Client Services, we may share your contact details and limited information about the Client Services provided to you or the client with client directories or other promotional publications or communications, in order to promote our Client Services. We will only share your personal information in this way to the extent that you have given us your consent to do so.
(e) Social Media Networks. When you use our Public Services, content that you share through social media may be shared with your social media account provider and your friends, followers or contacts on the connected social network.
(f) Purchasers and third parties. In connection with a business transaction. We may, where permitted by our professional confidentiality obligations, disclose generic information about our current clients, such as limited client lists and/or brief descriptions of the Client Services being provided, to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
(g) Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) enforce the terms of our agreement (being, as applicable, our Terms of Use Agreement for Public Services or the terms of our client engagement letter for Client Services) and pursue available remedies or limit the damages that we might sustain; (e) protect the security or integrity of the Public Services or Client Services (as applicable); and/or (f) exercise or protect our rights, privacy, safety or that of our affiliates, clients, you or others.

  1. MARKETING AND ADVERTISING

5.1 From time to time we may send you Client updates, alerts, news and mailings relating to seminars or events that we think may be of interest to you.
5.2 Most messages we send will be by email. For some messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
5.3 If you are a citizen of or reside in the EEA, we will only send you marketing messages if you have given us your consent to do so. If you do not want to receive messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details or by refusing or withdrawing your consent. You can also change your preferences at a later date by clicking on the unsubscribe link at the bottom of our messages, visiting www.hosts-global.comcontact us page to adjusts your communication preferences, or by emailing us at privacy@hosts-global.com.
5.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of Client Services.
5.5 Your personal information may also be shared with any affiliates of Hosts Destination Services LLC, who may also use this information for the same purposes outlined in this Privacy Policy.

  1. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

6.1 Retention periods. We will store your personal information for no longer than necessary for the purposes set out in Appendices 23 and 4, and in accordance with our Client obligations and legitimate business interests.
6.2 Security. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage.
6.3 International Transfers of your Personal Information. As an international services provider, our affiliates and service providers are located around the world. The personal information we collect may therefore be transferred to and stored in countries outside of the jurisdiction you are in. Any international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission or the Privacy Shield Frameworks, as detailed in Section 10 below. If you wish to enquire further about these safeguards used, please contact us using the details set out in Section 15 of this privacy policy.

  1. YOUR GDPR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

7.1 If you are a resident or citizen in the European Economic Area, under European law you have the following rights in respect of your personal information that we hold:
(a) Right of access. You have the right to obtain:

  1. (i) confirmation of whether, and where, we are processing your personal information;
  2. (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
  3. (iii) information about the categories of recipients with whom we may share your personal information; and
  4. (iv) a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
(f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
7.2 If you are resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death.
7.3 If you wish to exercise one of these rights, please contact us at privacy@hosts-global.com 
7.4 You also have the right to lodge a GDPR complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
7.5 Residents in other jurisdictions may also have similar rights to the above. Please contact us at privacy@hosts-global.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

  1. COOKIES AND SIMILAR TECHNOLOGIES

8.1 Our websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website or access any of our other websites and also allows us to improve our websites.
8.2 Cookies are pieces of code that allow for personalization of our website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes.
8.3 We use the following types of cookies:
(a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
(b) Analytical/performance cookies.They allow us to recognize and count the number ofvisitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Online Services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
(c) Functionality cookies.These are used to recognize you when you return to our website. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).
8.4 The cookies we use are designed to help you get the most from the website but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
(a) Cookie settings in Internet Explorer
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
(b) Cookie settings in Firefox
https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
(c) Cookie settings in Chrome
https://support.google.com/chrome/answer/95647?hl=en
(d) Cookie settings in Safari on Mac
https://support.apple.com/kb/PH21411?locale=en_US
(e) Cookie setting in Safari on iPhone, iPad, or iPod touch
https://support.apple.com/en-gb/HT201265
8.5 Deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like Flash objects or HTML5.
8.6 We are unable to respond to Do Not Track signals set by your browser at this time.

  1. LINKS TO THIRD PARTY SITES

The Public Services may, from time to time, contain links to and from third party websites, including those of other users and news publications. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

  • PRIVACY SHIELD FRAMEWORKS

Hosts Destination Services, LLC and its affiliates (listed in Section 13 of this policy) comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield.  Company has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/    

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also may correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@hosts-global.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual with an opt-in or opt-out choice, as appropriate, before we share their data with third parties other than our agents, or before we use it for a purpose other than the purpose for which it was originally collected or subsequently authorized. To limit the use or disclosure of your personal information, please submit a request to privacy@hosts-global.com.

Hosts Destination Services’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Hosts Destination Services remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Hosts Destination Services proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Hosts Destination Services commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. EU or Swiss individuals with Privacy Shield inquiries or complaints should first contact Hosts Destination Services by email at privacy@hosts-global.com.

Hosts Destination Services has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 here.

With respect to data received or transferred pursuant to the Privacy Shield Frameworks, Hosts Destination Services is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

  1. OUR POLICY TOWARDS CHILDREN

Our Public Services and Client Services are not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

  1. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

  1. NOTICE TO YOU

If we need to provide you with information about something, whether for Client, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Online Services. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

  1. AFFILIATES

The following entities are “affiliates” of Hosts Destination Services, LLC:

    • Hosts Destination Services, LLC
    • Global Alliance
    • Hosts Baltimore
    • Hosts Chicago
    • Hosts Las Vegas
    • Hosts New Orleans
    • Hosts Southern California
    • Hosts Washington DC
  • CONTACTING US

15.1 Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to privacy@hosts-global.com or to the partner with whom you entered into an engagement for the provision of Client Services. If you are in Germany, you can also contact our Data Protection Officer at privacy@hosts-global.com.
15.2 The policy shall take effect on May 22 2018.
APPENDIX 1 – HOSTS DESTINATION SERVICES, LLC OFFICES

Office

Data Controller

Global Alliance

Jeff Wingstrom

Hosts Baltimore

Jeff Wingstrom

Hosts Chicago

Jeff Wingstrom

Hosts Las Vegas

Jeff Wingstrom

Hosts New Orleans

Jeff Wingstrom

Hosts Southern California

Jeff Wingstrom

Hosts Washington DC

Jeff Wingstrom

APPENDIX 2 – PERSONAL INFORMATION WE COLLECT WHEN YOU USE THE PUBLIC SERVICES

Category of personal information

How we use it (purpose of use)

Legal basis for the processing

Contact information.
Personal information, such as your name, phone number, address, email address.

We use this information to deal with inquiries and complaints made by or about you relating to the Public Services.

The processing is necessary for our legitimate interests, namely administering the Public Services and dealing with inquiries and complaints relating to the Public Services.

We use this information to operate, maintain and provide to you the Public Services.

The processing is necessary for our legitimate interests, namely administering the Public Services and dealing with inquiries and complaints relating to the Public Services.

We use this information to communicate with you, including sending service-related communications.

The processing is necessary for our legitimate interests, namely administering the Public Services and communicating with you in connection with the Public Services.

We use this information to send you statements and invoices in relation to any agreement between us to provide you with any part of the Public Services.

The processing is necessary for the performance of a contract and/or to take steps at your request prior to entering into a contract.

We use this information to send you news, alerts and marketing communications in accordance with your preferences.

If you are in the EEA, or if the relevant data controller using your personal information for this purpose is in the EEA, we will only process your personal information in this way to the extent that you have given us consent to do so.

If neither you nor the data controller are in the EEA, the processing is necessary for our legitimate interests, namely for marketing purposes.

Employment information.
Such as information about your employing entity, business unit, manager and management reporting structure, job title, function and the nature of your duties and responsibilities.

We use this information to tailor content provided to you through our Public Services, including notifications, news, alerts and marketing communications.

The processing is necessary for our legitimate interests, namely to tailor our service to the user.

We use this information to monitor and improve the Public Services.

The processing is necessary for our legitimate interests, namely to improve our Public Services.

Comments and opinions.
When you contact us directly, e.g. by email, phone, mail, when you post on message boards, blogs or complete an online form, we will record your comments and opinions.

We use this information to address your questions, issues and concerns.

The processing is necessary for our legitimate interests, namely administering the Public Service and dealing with enquiries and complaints relating to the Public Services.

We use this information to improve our Public Services.

The processing is necessary for our legitimate interests, namely to inform the development of new features of the Public Services and the improvement of the Public Services generally.

We use this information to determine products and services that may be of interest to you.

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

Location information.
Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location.

We may use an approximate location to ensure content made available to you through our Public Services is relevant to the city or country you are using your device in.

The processing is necessary for our legitimate interest, namely to tailor our service to the user and to improve our service generally.

Information provided by social networks you connect to the Public Service.
If you connect a social network, such as LinkedIn or Facebook, to our Public Services we will collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, Facebook ID, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list and any other information you have agreed it can share or that the social network provides to us.

We will use the personal information provided to allow you to assist you in sharing content from our Public Services, or your experiences on our Public Services, with your friends, followers or contacts on the connected social network.

The processing is necessary for our legitimate interest, namely to tailor our service to the user and to improve our service generally.

Preferences.
Preferences set for notifications, marketing communications and how our website is displayed.

We use this information to provide notifications, send news, alerts and marketing communications and provide our Public Services in accordance with your choices.

The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications.

We use this information to ensure that we comply with our Client obligation to send only those marketing communications to which you have consented.

The processing is necessary for compliance with a Client obligation to which we are subject.

Information provided by third parties.
From time to time, we may receive information about you from third parties and other users. We may obtain information from third parties to enhance or supplement our existing user information. We may also collect information about you that is publicly available.

We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials or to personalize the Public Services, to pre-populate forms, and to better understand the demographics of our users.

The processing is necessary for our legitimate interests, namely to tailor our service to the user and to improve our service generally.

All personal information set out above.

We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Public Services, to communicate with you, to monitor and improve the Public Services and business, and to help us develop new products and services.

The processing is necessary for our legitimate interest, namely to administer and improve the Public Services.

APPENDIX 3 – PERSONAL INFORMATION WE COLLECT WHEN YOU USE THE CLIENT SERVICES

Category of personal information

How we use it (purpose of use)

Legal basis for the processing

Contact information.
Personal information, such as your name, phone number, address, email address.

We use this information to provide you or the client with Client Services in accordance with our agreement with you, or in accordance with our agreement with the client.

Where you are the client, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where you are not the client, the processing is necessary for our legitimate interests and those of our clients, namely administering the Client Services.

We use this information to communicate with you in connection with the provision of Client Services, including sending statements and invoices, and to deal with inquiries and complaints made by or about you relating to the Client Services.

Where you are the client, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where you are not the client, the processing is necessary for our legitimate interests and those of our clients, namely administering the Client Services and communicating with clients and other persons in connection with the provision of Client Services.

We may use this information to promote our Client Services, such as disclosing your contact information to client directories or other promotional publications or communications.

We will only process your personal data in this way to the extent that you have given us your consent.

Identification information.
Proof of identity, such as copy of official government identification.

We use this information to verify the identification of individuals receiving the Client Services.

The processing is necessary for compliance with a Client obligation to which we are subject.

We use this information to facilitate our internal business operations, including compliance with our professional obligations.

The processing is necessary for our legitimate interests, namely preventing fraud and ensuring compliance with our professional obligations.

Employment information.
Such as information about your employing entity, business unit, manager and management reporting structure, job title, function and nature of duties and responsibilities.

We use this information to tailor and provide you or the client with Client Services.

Where you are the client, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where you are not the client, the processing is necessary for our legitimate interests and those of our clients, namely administering the Client Services.

Instructions, comments and opinions.
When you contact us directly, e.g. by email, phone, mail or by completing a form, we will record your comments and opinions.

We use this information to provide the Client Services in accordance with our client’s instructions and respond to your questions, issues and concerns.

Where you are the client, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where you are not the client, the processing is necessary for our legitimate interests and those of our clients, namely administering the Client Services.

We use this information to tailor the Client Services to your or our client’s requirements, deal with complaints made by or about you relating to the Client Services and monitor and improve our Client Services.

The processing is necessary for our legitimate interests, namely communicating with clients, tailoring our service to clients and to improve our service generally, and for internal risk management purposes; the processing is also necessary for your legitimate interests and those of our clients, namely receiving the Client Services.

We may use this information to promote our Client Services, such as disclosing your contact information to Client directories or other promotional publications or communications.

We will only process your personal data in this way to the extent that you have given us your consent.

Information about your Client matter.
Information regarding the issue or matter in respect of which we have been engaged to provide Client Services may contain personal information about you.

We use this information to provide the Client Services in accordance with our client’s instructions and to tailor the Client Services to your or our client’s requirements.

Where you are the client, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where you are not the client, the processing is necessary for our legitimate interests and those of our clients, namely administering the Client Services.

We may use this information to promote our Client Services, such as disclosing your contact information to Client directories or other promotional publications or communications.

We will only process your personal data in this way to the extent that you have given us your consent.

Payment and transaction information.
Payment information, such as your credit card or bank account details, and other information such as date and time of your transaction.

We use this information to facilitate transactions made in connection with the provision of the Client Services.

Where you are the client, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where you are not the client, the processing is necessary for our legitimate interests and those of our clients, namely administering the Client Services.

We use this information to detect and prevent fraud.

The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.

Location Information.
Information that you choose to provide to us, such as your address or business address, or country of residence.

We may use this personal information to facilitate internal business operations, including fulfilling our Client requirements and professional obligations.

The processing is necessary for our legitimate interest, namely to comply with our professional obligations.

Information provided by third parties.
From time to time, we may receive information about you from clients or third parties. We may obtain information from third parties to enhance or supplement our existing information about you. We may also collect information about you that is publicly available.

We may combine this information with the information we collect from you directly. We use this information to:
· contact you; and
· provide the Client Services in accordance with our client’s instructions.

Where you are the client, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where you are not the client, the processing is necessary for our legitimate interests and those of our clients, namely administering the Client Services.

All personal information set out above.

We use this information to comply with any professional or Client obligation to which we may be subject, such as disclosure of information to comply with a court order or at the request of a regulator.

The processing is necessary for compliance with a Client obligation to which we are subject.

We use this information to facilitate our internal business operations that are put in place for compliance with our Client obligations.

The processing is necessary for our legitimate interests, namely the detection and prevention of fraud and the fulfilment of professional obligations.

APPENDIX 4 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Category of personal information

How we use it (purpose of use)

Legal basis for the processing

Information about how you access and use the Online Services.
For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Online Services, the time you access the Online Services and how long you use them for, whether you open emails or click the links contained in emails, whether you access the Online Services from multiple devices, and other actions you take on the Online Services.

We use this information to present our Online Service to you on your device.

The processing is necessary for our legitimate interests, namely to tailor our Online Services to the user.

We use this information to determine news, alerts and other products and services that may be of interest to you for marketing purposes.

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We use this information to monitor and improve our Online Services and business, and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely to improve our Online Services generally; to monitor and resolve issues; and for the detection and prevention of fraud.

Information about your device.
We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Online Services. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Online Services through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).

We use this information to present our Online Service to you on your device.

The processing is necessary for our legitimate interests, namely to tailor our Online Services to the user.

We use this information to determine news, alerts and other products and services that may be of interest to you for marketing purposes.

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We use this information to monitor and improve our Online Services and business, and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely to improve our Online Services generally; to monitor and resolve issues; and for the detection and prevention of fraud.