Last Updated: November 2022
The Data We Collect, and How We Collect It
To provide our Services, we collect data that is not personally identifiable (“Anonymous Data”) and also data that, either alone or in conjunction with other data, could be used to identify an individual or household (referred to as “Personal Data”). Collectively, Anonymous Data and Personal Data are referred to as “Data”. We only collect or have access to information that you voluntarily give us when registering for any of our events/discussions, when participating in our events/ discussions, via our online portal, marketing site, mobile app or related tools. We will not sell or rent this information to anyone and have not sold this information in the immediate 12 months.
We collect and process the following type of Data:
- Identifiers, which includes your name, physical address, and email;
- Categories of personal information that identify, relate to, describe, or is capable of being associated with, a particular individual, including, but not limited to, name, signature, physical characteristics or description, address, telephone number, education, employment, and employment history;
- Commercial information, such as products or services purchased, obtained or considered or consuming histories or tendencies;
- Site Usage Data / Internet or other electronic network activity information, such as browsing history, search history, IP address, browser types, log-in history (date, time, locations), and information regarding interactions with the Site;
- Audio, visual or similar information;
- Registration Information: Information provided when registering for our events, or recording, which may include name and contact information, responses to registration questions, and other registration information we may request. Professional or employment related information, such as what company you work/consult;
- Inferences drawn from other personal information to create a profile about a user;
- Content and context from events, meetings, webinars, and other collaborative features, which includes, content generated in meetings, events, webinars, which may include audio, video, in-meeting messages, transcriptions, transcript edits, written feedback, responses to polls, surveys, and Q&A, as well as related context, such as invitation details, or meeting agenda. Content may contain your voice and image, what you choose to share, your settings, and what you do on our Services.
Data may be collected in the following ways:
- Account and Transaction Data: We collect Personal Data that is provided to us voluntarily either via direct communications (e.g., email, phone, via live chats/events/discussions, submitting service requests, in person, registering for our newsletter and/or for email updates, registering for an account, or via survey responses) or through a user’s use of our Site, such as when a user asks us to contact them, seek information about our Services, how to participate in our Services, etc. We use Account Data to provide our Services to you, and we may also use Account Data to contact users for limited marketing or product communication purposes (subject to the provisions herein).
- Site Usage Data: We collect certain Site utilization data through the use of tracking technologies (including cookies, as detailed below) and the Data collected can include both Anonymous Data (e.g., how a Site is used) and Personal Data. We use Site Usage Data to understand how our Sites and Services are used, to improve our Sites and Services, and to protect the integrity and security of our Sites and Services.
- Other Information you Choose to Provide: We collect information you choose to provide, such as information about your employment, investments, strategy, market information, insights, recommendations, practical solutions, contact preferences, and communications and interactions or when you request technical or customer support or contact us.
- Information we Collect from Social Media Platforms: We may obtain information about you from social media platforms that you use in connection with our Site or when using our Services, or that share or allow you to share information with us, such as Facebook, Twitter, YouTube, and LinkedIn. For example, if you post content to feeds on third-party social media sites or use social media platforms in connection with the Site, if you use credentials (g., username and password ) from a third party site to create or log into your account on the Site, or if you like us or follow us on social media platforms, we may collect the information that you share with us, or that those social media platforms share with us in accordance with their privacy policies and privacy settings. For more information about social media platform privacy practices, please review the privacy policies and settings of the social media platforms and networks that you use. You may update your privacy settings on each social media platform directly.
If we combine Personal Data with Anonymous Data, the combined information will be treated by us as Personal Data for as long as it remains combined.
Cookies and Other Automated Tracking Technologies
We may use the following types of cookies on the Site:
- Functional Cookies: These cookies enable the Site to provide enhanced functionality and customization. If you do not allow these cookies then some or all of the functionality of the Site may not be available to you and some or all of our Services may not function properly.
- Strictly Necessary Cookies: These cookies are essential for you to brose the Site and cannot be switched off in our systems. They are usually only set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not work.
- Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site and Services. They help us know which pages are the most and least popular and see how Site visitors move throughout the Site. If you do not allow these cookies we will not know when you have visited our Site and will not be able to monitor its performance.
For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://allaboutcookies.org/.
How We Use the Data that We Collect
- Provide Our Services to You: We use your Data to provide the Services to you, facilitate account creation, allow for follow-up support, provide access to additional information, provide maintenance and support (including by sending you confirmations, related transactional, communications, security alerts, support and administrative messages), and to improve our Services and the Sites. We also use anonymized, de-identified and aggregated data generated by the Services to provide insights to our customers. This may also include using personal data for customer support, which may include accessing transcribed conversations, and other content or context. We also use personal data to manage our relationship and contracts with account owners and others, including billing, compliance with contractual obligations, and related administration.
- To Provide Transcriptions of Our Events: When you participate as a speaker in any of our events, whether as a speaker or participant asking questions or otherwise engaging with the speakers, you consent to being recording via audio so that we can transcribe those proceedings and publish or otherwise offer them to users for informational purposes. If you do not consent to being recorded, you must not participate in our events, either as a speaker or speaking participant. Please note that no Personal Data will be included in the transcribed product.
- Product Research and Development: To develop, test, and improve our Site and Services, including, content-related features, and to troubleshoot the Site and Services.
- Further our Business Purposes: We use it to operate, improve upon and expand our business and lawful business activities; to maintain our programs, accounts, and records; for research; to detect and prevent fraud or misuse of our Services; to prevent malicious conduct or unsafe experiences, address security threats, protect public safety, secure our Services, and for any other business purpose that is permitted by law.
- Customize and Enhance your Experiences with Us. We use it to remember and categorize your interests and preferences; customize the services we share with you through direct marketing; communicate with you about the Site, Services, offers, promotions, surveys, events, and other news and information we think may be of interest to you and contact you for feedback.
- Respond to You. We use it to respond to you, such as when you register for an event, call us, make a request or inquiry, complete a survey, or share a comment or concern.
- Business Transferees. We may sell, transfer, or otherwise share some or all of your Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the event of an insolvency, bankruptcy, or receivership.
- Law Enforcement, Legal Process, and Emergency Situations. In some cases, we may use or disclose your personal information to a third party if we are required to do so by law or if we in good faith believe that such action is necessary to comply with the law or legal process; to protect and defend our rights or to prevent misuse of our Services; or to protect the personal safety of our employees, agents, partners, the users of the Services, or the public.
- Professional Advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
- Miscellaneous. We use it for any of the following reasons:
- To identify your preferences
- To provide you information about our other Services that might be of interest to you
- To comply with our internal record-keeping needs to legal compliance needs
- To notify you about changes to our Services
- To allow you the option to participate in interactive features of our Services
- To detect, prevent, and address technical issues
- To protect or otherwise investigate our Services regarding misuse, security breaches, prevention, detection, mitigation, or investigation of fraud, or other potentially prohibited or illegal activities and/or attempts to interfere with the Website or Services or to harm others
- With respect to a transfer or sale, including a potential transfer or sale, of any of our assets and/or operations to another party or in the due diligence process in line with a potential transfer or sale
- To determine your level of engagement
- Monitor and improve the information security of our Sites and/or our Services
- Comply with governmental regulations or to respond to a subpoena or other governmental, court, administrative, Member State, Supervisory Authority or other legal requirement
- Hire, train and/or manage our staff/employees
- Any other purpose communicated to you at the time of collecting the Personal Data and if required by law for which consent has been obtained
- We may use non-personally identifiable information such as demographic data to analyze and develop our marketing strategy and maintain and further improve the Sites and our Services
- To monitor and improve marketing campaigns and make suggestions relevant to Users
- To send out email blasts to you on our behalf to advise you of new services or products that we may have to offer
How We Share Your Data
We only provide your Personal Data to third parties with your consent or in one of the following circumstances (subject to prior consent where required by law):
- For Legal Purposes. We also reserve the right to disclose Data or any information submitted via the Site if we have a good faith belief that disclosure of such information is reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims;(v) prevent harm to our rights, property or safety (or the same interests of our users or any third party); (vi) to notify you of any product recalls or other safety concerns; or (vii) for any other legal purpose.
- Related Companies / Corporate Affiliates. We may share your Personal Data with our corporate affiliates, including our parent company, sister companies and subsidiaries including those entities specifically identified herein. Such corporate affiliates process personal information on our behalf as our Service Providers, where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.
- Change of Control. We may share Personal Data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or portion of our business or assets, including in connection with bankruptcy or similar proceedings.
- For Other Purposes. We may share Personal Data with third parties for other purposes. For example, we share Personal Data with:
- Third parties who provide products and services that may be of interest to you, including third parties that provide us with products and services that enhance our products and services for you and that provide us with marketing, research and advertising services, including to: serve advertisements across the Internet; track and categorize your activity and interests over time on our Website and mobile application, and on third-party websites and mobile applications; and to identify the different device(s) you use to access websites and mobile applications.
- Our Site if you provide comments or reviews on our services or products.
Privacy Rights and Choices
- Social Media: You should review your privacy settings and options directly with each of the social media platforms and networks that you access to determine your options and choices about sharing information from these sites with us.
- Email Communications: You may choose during the account registration process on the Sites, or otherwise, to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other materials related to our products and services. You may opt out of receiving these promotional communications from us by following the instructions in those communications (such as by using an “unsubscribe” link in an email you receive) or by contacting us at the contact information provided above. Even if you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
- Participation Information: When you participate as a speaker in any of our events, whether as a speaker or participant asking questions or otherwise engaging with the speakers, you consent to being recording via audio so that we can transcribe those proceedings and publish or otherwise offer them to users for informational purposes. If you do not consent to being recorded, you must not participate in our events, either as a speaker or speaking participant. Please note that no Personal Data will be included in the transcribed product.
If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:
- Inform you of what Personal Data we have about you that is under our control;
- Amend or correct such Personal Data or any previous privacy preferences you selected, or direct you to applicable tools; and/or
- Delete such Personal Data or direct you to applicable tools.
Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others. As an account owner or a user under a licensed account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.
Confidentiality and Security
We restrict access to non-public, Personal Data about you, to those employees and agents who need to know that information to provide Services to you. We maintain physical, electronic, and procedural safeguards to protect your non-public, personal information. We do not disclose any non-public, personal information about clients or former clients to anyone except as permitted by law.
The criteria used to determine our retention periods include the following:
- The length of time we have an ongoing relationship with you and provide Services to you;
- Whether we have a legal obligation to keep the Personal Data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).
European Data Protection Specific Information
Data Subjects Rights
If you are in the EEA, Switzerland, or the UK, your rights in relation to your Personal Data processed by us as a controller specifically include:
- Right of access and/or portability: You have the right to access any Personal Data that we hold about you and, in some circumstances, have that Personal Data provided to you so that you can provide that Personal Data to another provider;
- Right of erasure: In certain circumstances, you have the right to the erasure of Personal Data that we hold about you (for example, if it is no longer necessary for the purposes for that was originally collected);
- Right to object to processing: In certain circumstances, you have the right to request that we stop processing your Personal Data and/or stop sending you marketing communications;
- Right to rectification: You have the right to require us to correct any inaccurate or incomplete Personal Data;
- Right to restrict processing: You have the right to request that we restrict processing of your Personal Data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.
Legal Basis for Processing Personal Data
We only use your information in a lawful, transparent, and fair manner. Depending on the specific Personal Data concerned and the factual context, when we process Personal Data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:
- As necessary for our contract: When we enter into a contract directly with you, we process your Personal Data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing our Services, and manage our relationship and contract, including compliance with contractual obligations, and related administration). If we do not process your Personal Data for these purposes, we may not be able to provide you with all Services;
- Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool, available Cookies Settings
- As necessary to comply with our legal obligations: We process your Personal Data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
- To protect your vital interests or those of others: We process certain Personal Data to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
- As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your Personal Data based on such legitimate interests to (i) enter and perform the contract with you to provide the Services (which includes compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our Services and troubleshoot our Site and Services; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and Services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the Services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.
International Data Transfers
Our Site is available globally, which means Personal Data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where we or our Service Providers have customers or facilities – including in countries where meetings that you participate in are based.
Therefore, by using our Services or providing Personal Data for any of the purposes stated above, you acknowledge that your Personal Data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.
California Privacy Rights
California Consumer Privacy Act/California Privacy Rights Act
Under the California Consumer Privacy Act of 2018 (CCPA) and California Privacy Rights Act of 2020 (CPRA) California residents may have a right to:
- Access the categories and specific pieces of Personal Data we have collected, the categories of sources from which the Personal Data is collected, the business purpose(s) for collecting the Personal Data, and the categories of third parties with whom we have shared personal data
- Delete Personal Data under certain circumstances;
- Right to correct inaccuracies in your Personal Data be corrected; and
- Opt out of the “sale” of Personal Data. We do not sell your Personal Data including for the purpose of interest-based advertising.
We will not discriminate against you for exercising any of these rights, which is further in line with your rights under the CCPA/CPRA.
We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to 90 days) in writing.
Under the CCPA/CPRA, only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests to access or delete Personal Data under the CCPA/CPRA, we must verify your identity. We may do so by requiring you to log into your account (if applicable), provide information relating to your account (which will be compared to information we have, such as profile information), give a declaration as to your identity under penalty of perjury, and/or provide additional information. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
California’s Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Data (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Data with third parties for the third parties’ direct marketing purposes.
BWG Strategy LLC
25 Commerce Drive
Cranford, NJ 07016