This Privacy Policy, including the Annexes thereto, describes how we collect, use, process, and disclose your information, including personal information, when you use the Services.
This Privacy Policy is subject to the Conference Terms and Conditions. If you see an undefined term in this Privacy Policy, it has the same definition as in our Conference Terms and Conditions.
When this Privacy Policy mentions “THE SWITCH, "we", "us", or "our" it refers to THE SWITCH, a company that is responsible for your information under this Privacy Policy (the "Data Controller").
THE SWITCH provides the Services to individuals as well as to legal entities. THE SWITCH is acting as the Data Controller.
If you do not agree with this Privacy Policy, do not access or use our Services or interact with any other aspect of our business.
INFORMATION WE COLLECT There are two general categories of information we collect.
Information you provide us while using the Services 1.1.1. Information that is necessary for the use of the Services. We ask for and collect the following personal information about you when you use the Services:
Registration Information. When you fill in the registration form on the Website to use the Services you create a user account ("User account") and we require certain information such as your first name, last name, your country, your company, your phone number and email address. Information you provide through our support channels. The Services also include customer support, where you may send any question regarding the Services via email to [email protected]. If you speak to one of our representatives directly, by email or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem and any other information that would be helpful in resolving the issue. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services (including use of the Services itself, participation in our webinars, conferences etc.).
We retain your account information until you send us the de-registration request to [email protected]. We also retain some of your information, which is anonymized, as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve the Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
1.1.2. You may provide us with the following information: You may choose to provide us with additional personal information in order to obtain a better user or participant experience when using the Services. This additional information will be processed based on your consent.
Additional Information. You may choose to provide additional information as part of your User account (such as your job title). Information our partners, speakers provide us. If you use our Website to participate in our webinars, online conferences as our partner or speaker, we can ask you to provide us with some information (such as your name, job title, your photo, your country or other information). By posting or by providing us the right to post any information on our website you acknowledge and agree that the data you publish or provide us for publishing on our Website or any time later creates your public profile (hereinafter "Public Profile"). You acknowledge and agree that the information that you provide in your Public Profile would be visible to the others. Please note that you are responsible for receiving consent if you use these Services on behalf of another person.
Some of our Services may require to provide access to your profile in social networks (such as Facebook, Twitter, etc.). You are the only person who decides if you would like to provide this access. You can revoke this access in your social network’s profile any time.
1.2. Automatically collected information from your use of the Services
When you use the Services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Services.
Device and Connection Information. We collect information about your computer or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience and to fulfil our legal and fiscal obligations. Cookies and Similar Technologies. We use cookies and other similar technologies . Third-Party Widgets. Some of our Services contain widgets and social media features, such as the Facebook button; linked button. You are the only person who decides if you would like to press this button and share your personal data. These widgets and features collect your IP address, the information about the page you are visiting during your use of the Services, and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.
HOW WE USE INFORMATION WE COLLECT
We use, store, and process information, including personal information, about you to provide, improve, and develop the Services, create and maintain a trusted and safer environment, comply with our legal obligations and otherwise as can be specified herein.
2.1. To provide, improve, and develop the Services
Enable you to access and use the Services. Operate, protect, improve, and optimize the Services and experience, such as by performing analytics and conducting research. Subject to our contract with you we process this information either manually or by computer. Provide customer service: to resolve technical issues you meet, to respond to your requests for assistance, and to repair and improve the Services. Send you service or support messages, updates, security alerts, and account notifications. If you provide us with your contacts’ information, we may process this information: (i) for fraud detection and prevention, and (ii) for any purpose you authorize at the time of collection. We process this information given our legitimate interest in improving the Services, and where it is necessary for the adequate performance of the contract with you.
2.2. To create and maintain a trusted and safer environment
Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity. Conduct security investigations and risk assessments. Verify or authenticate information or identifications provided by you. Comply with our legal obligations. Resolve any disputes and enforce our agreements with third parties. Enforce our Conference Terms and Conditions and other policies. We process this information given our legitimate interest in protecting the Services, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3. To provide, personalize, and improve our advertising and marketing
Send you promotional messages, marketing, advertising, and other information that may be interested to you based on your preferences (including information about THE SWITCH campaigns and services) and social media advertising through social media platforms. Personalize, measure, and improve our advertising. For marketing activities performed by our partners, provided that you gave us relevant consent. We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by sending us an opt-out request at [email protected].
SHARING & DISCLOSURE
We collect information globally and store that information in the The Netherlands and USA cloud servers. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
3.1. If you give us a consent
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you participate in promotional activities conducted by THE SWITCH partners or third parties, for example during conferences.
3.2. In order to comply with the law, respond to legal requests, prevent harm and protect our rights
THE SWITCH may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to protect the rights, property or personal safety of THE SWITCH, its employees, or members of the public.
Where appropriate, we may notify you about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon THE SWITCH’s property, its users and the Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify you about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
Service providers THE SWITCH uses a variety of third party service providers to help us provide services related to the Services. Service providers may be located inside or outside of the United States. In particular, without limitation, you can find the list of service providers in Annex 1 hereto. We ensure that this third service providers have an adequate security controls.
For example, service providers may help us: (i) conduct background or police checks, fraud prevention, and risk assessment, (ii) perform product development, maintenance and debugging, (iii) allow the provision of the Services through third party platforms and software tools (e.g. through the integration with our APIs), or (iv) provide customer service, advertising, or other services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.
THE SWITCH will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
Corporate affiliates We may share your information, including personal information, with our corporate affiliates in order to support, integrate, promote and improve the Services.
Our partners We may share your information, including personal information, with our partners if you gave us relevant consent, for marketing purposes and in order to receive the offers and advertisements from our partners.
Please note that you may, at any time ask THE SWITCH to cease processing your data for these direct marketing purposes by sending an email to [email protected]
Social networking websites Where permissible according to applicable law, we may use certain limited personal information about you, such as your email address, to hash it and to share it with social network websites, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products or Services. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be interested to you.
The social network websites with which we may share your personal data are not controlled or supervised by us. Therefore, any questions regarding how your social network websites service provider processes your personal data should be directed to such provider.
Please note that you may, at any time ask THE SWITCH to cease processing your data for these direct marketing purposes by sending an email to [email protected].
Aggregated data We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis marketing and advertising, and other business purposes.
We also may use this information for research and development. We will never sell your Personal Data to any third party.
OTHER IMPORTANT INFORMATION 4.1. Analyzing your communications.
We may review, scan, or analyze your communications on the Services for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on our legitimate interest in ensuring compliance with applicable laws and our Summit Terms and Conditions, preventing fraud, promoting safety, and improving and ensuring the adequate performance of the Services.
Google Analytics and Google Adwords Parts of the Services use Google Analytics and Google Adwords. Use of Google Analytics and Google Adwords is subject to Google Privacy Policy, AdWords Terms & Conditions and Google Analytics Terms of Services.
YOUR RIGHTS You may exercise any of the rights described in this section by sending an email to [email protected]. Please note that we may ask you to verify your identity before taking further action on your request.
Managing your information You may access and update some of your information by sending the request to [email protected].
Rectification of inaccurate or incomplete information You have the right to ask us to correct inaccurate or incomplete personal information concerning by sending the request to [email protected].
Data access and portability If it is applicable under the legislation in your jurisdictions you may request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data retention and erasure We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information during the provision of the Services to you, you can request that we erase your personal information and close your User account. In this case your information will be erased within the term specified by the applicable legislation. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety within 7 (seven) years in accordance with applicable legislation. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations within 7 (seven) years in accordance with applicable legislation.
Information you have shared with others (if you are using the Services by participating in our webinars, online conferences as our partner/speaker) may continue to be publicly visible on our Website. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. Please be informed that if you directly disclose any information through our Website page open to the public, this information may be collected and used by third parties. We will correct or delete any information you have posted on the Website page open to the public if you request to do so. Because we maintain the Services to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time (no more than 3 months). Withdrawing consent and restriction of processing Where you have provided your consent to the processing of your personal information by THE SWITCH you may withdraw your consent at any time by sending us notification specifying which consent you are withdrawing at [email protected]. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 5.6 and pending the verification whether the legitimate grounds of THE SWITCH override your own.
Objection to processing If it is applicable under the legislation in your jurisdictions you may require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an email to [email protected]
Right to lodge a complaint with a supervisory authority Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work or place of the alleged infringement if you consider that we are in a breach of the processing of personal data relating to you.
WE OPERATE GLOBALLY
To facilitate our global operations we may transfer, store, and process your information within our family of companies or with service providers as described herein. Laws in the countries, where your information could be transferred, stored and processed may differ from the laws applicable to your country of residence. For example, information collected within the The Netherlands may be transferred, stored and processed outside of the The Netherlands for the purposes described in this Privacy Policy. Where we transfer store, and process your personal information outside of the The Netherlands we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.
Prior to sharing your information with corporate affiliates or third party service providers outside the The Netherlands we establish all the necessary means to ensure an adequate level of data protection.
SECURITY
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are as follows:
Limited access to the production database at the network level Limited access to the production database at the process/users level Password policy for access to the production database Data transfer encryption Data encryption in the database (for card data and authentication credentials) WAF (Web Application Firewall) DDoS protection Internal password change policies PCI DSS compliance Logging of actions and log analysis Antiviruses on admins workstations If you know or suppose that your Personal Data have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your User account, please contact us by email at [email protected].
OUR POLICY TOWARDS CHILDREN
The Services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
CHANGES We reserve the right to change this Privacy Policy at any time in accordance with this clause. If we make changes to this Privacy Policy, we will post the updated Privacy Policy on our website and will indicate the date of updating.
CONTACT US If you have any questions or complaints about this Privacy Policy, you may contact us by email at [email protected]. Effective Date: 1 July 2020
ANNEX 1 Personal Data Processing Purposes and Details Subject matter of processing: THE SWITCH’s provision of the Services and related technical support to User. Duration of Processing: Personal Data will be Processed for the period, commencing on the day you start using the Services and remains in full force and effect so long as: the Conference Terms and Conditions remains in effect, or THE SWITCH retains any Personal Data related to the Conference Terms and Conditions in its possession or control (Term). Nature of Processing: THE SWITCH will process User personal data submitted, stored, sent or received by User via the Services for the purposes of providing the Services and related THE SWITCH technical support and in marketing purposes, provided that User give us relevant consent. Personal Data Categories: Registration Information and other information specified in section 1 of the Privacy Policy and other electronic data submitted, stored, sent, or received via the Service. Data Subject Types: Personal data submitted, stored, sent or received via the Services may concern the following categories of data subjects: end users including User’s employees; partners, speakers and any other person who transmits data via the Services. Approved Subcontractors: THE SWITCH vendors: Kartra Inc. Zapier Inc. Zoom Video Communications Inc. Google Inc. Facebook Inc. LinkedIn Inc. Twitter Inc. International Bar Association (IBA) - THE SWITCH partners: listed on the Website.
Each partner warrants that it will receive all necessary consents and permissions to process personal data information as can be required by applicable law. Each partner warrants that it will collect the personal data in accordance with all applicable laws and will implement adequate technical and organizational security measures with regard to personal data.
THE SWITCH and THE SWITCH Affiliates may engage third party suppliers to provide other services such as facilities management, maintenance and security services from time to time.
HeySummit is not responsible for any part of the above Additional Statements and is only responsible for the Core Privacy Statements set out hereunder:
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 heysummit.com and/or 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.
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.
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.
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.
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.
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.
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:
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).
We use different methods to collect data from and about you including through:
The legal basis for using your information as set out in this Privacy Statement are as follows:
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.
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.
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.
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:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
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.
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:
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.
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
Requests to exercise your rights may be submitted by emailing us at [email protected] 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.
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