The following Additional Privacy Statements (the "Additional Statements") have been added by the Event Organiser and are specific and in relation to this Event ("Transform Virtual Summit") only. These set out additional Promotion and Insight activities that are being conducted by the Event Organiser and sets out additional data processing that they expect to do:
Showpad Privacy Principles (Last update 23 January 2020)
Showpad NV / Showpad inc. (“Showpad”) operate, exploit and maintain certain SaaS Products and Services (“Products and Services”) for and on behalf of Showpad customers’ use and benefit.
These Showpad Privacy Principles wish to explain what processing activities are taking place in respect of information relating to individuals (as being an identified or identifiable natural person) (“Personal Data”) when such individual (the “Data Subject”) is interacting, directly or indirectly (e.g. through an integration or through a software client), with the Products and Services and/or certain content of the Showpad Customer managed thereon (see FAQ B7.).
These Showpad Privacy Principles do NOT apply in situations other than explained above, or in the specific situations where the Showpad Privacy Policy applies (showpad.com/privacy-policy).
These Showpad Privacy Principles are always subject to i) the terms of the Agreement between Showpad and the Showpad Customer, as well, ii) the applicable polic(y)(ies) of the Showpad Customer (e.g. as being Your employer, the applicable Showpad Customer Privacy Policy, …) (“Customer Policy”) that apply to Your interaction with the Products and Services and/or certain Customer Content managed thereon (see FAQ A2.).
Showpad may change these Privacy Principles at any time, and all such changes are effective immediately upon posting a revised version of these Privacy Principles on the Showpad website. You should review these Privacy Principles often to stay informed of changes that may affect You. Your Interactions constitute Your continuing agreement to these Privacy Principles, as they are amended from time to time.
A. General
As GDPR currently is the most advanced and elaborate data protection legislation in the world, Showpad uses GDPR as its main benchmark for its companywide privacy program.
Seeing the global activities of Showpad, it goes without saying that with these Privacy Principles, in addition to GDPR, also want to take into account the principles of other applicable data protection legislations (such as the California Consumer Privacy act of 2018, the UK Data Protection act 2018, or, the Swiss Data Protection act).
The principles of such other data protection legislations have either already been incorporated through GDPR (in most of the cases) or either have specifically been added to these Privacy Principles.
Showpad is acting as “Processor” / “Service Provider” in respect of the operation of the Products and Services and not as data controller (see FAQ B12), which means that the Customer Policy shall always have priority over these Privacy Principles.
In no way do these Privacy Principles or the publication thereof mean that Showpad is taking up a role as data “Controller” under these Privacy Principles or taking up additional liabilities or responsibilities than as legally applicable between a controller and processor.
The publication of, or getting acceptance against, the Customer Policy (or absence thereof) occurs solely under the responsibility of the Showpad Customer.
Where the Data Subject already has accepted the Customer Policy (or where such (updated) Customer Policy subsequently becomes applicable) that cover Your interaction, directly or indirectly (e.g. through an integration or through a software client), with the Products and Services and/or certain Customer Content managed thereon, the Customer Policy shall apply instead of these Privacy Principles.
These Privacy Principles are being provided under the responsibility of the Showpad Customer, who is acting as data “Controller” for the processing activities covered under these Privacy Principles (see FAQ B12).
These Privacy Principles do NOT apply in situations other than explained above or in situations where the Showpad Privacy Policy applies (www.showpad.com/privacy-policy) (Showpad acting as data “Controller”, including in respect of Showpad’s use of its own Products and Services).
B. Showpad organistion
Organisational initiatives include: Dedicated privacy website & FAQ’s in respect of the Showpad privacy program: www.showpad.com/gdpr-information-hub/ and www.showpad.com/gdpr Data protection officer (DPO): Showpad has appointed a qualified data protection officer who supervises the entire data privacy program at Showpad and works in close conjunction with the Showpad Information Security Manager. The data protection officer is registered with the Belgian Data Protection Authority (https://www.dataprotectionauthority.be/). Vetting by Showpad of its vendors & subprocessors: Each vendor to Showpad is vetted by Legal, Infosec and the Showpad DPO in the areas of security, contractual terms and privacy related matters (e.g. data processing agreements, and applicable transfer mechanisms (e.g. EU standard contractual clauses / Privacy Shield)). Special attention is given to subprocessor that are acting as subprocessor with regard to the Products and Services. Contractual documents / privacy policies: Our contractual documents are state-of–the-art and contain the necessary provisions, including in respect of data processing agreements, end-to-end confidentiality, and privacy policies (meeting all necessary legal requirements). Privacy Shield certification: Showpad Inc. adheres to the EU-US Privacy shield, in order to facilitate and safeguard transfer of Personal Data to the US. ISO 27001 certification: The Products and Services are covered under the Showpad ISO 27001 certification Information security Management system (ISMS): Showpad has implemented an elaborate ISMS managing and following up on internal policies on data security.
Product related initiatives include: EU Data centres / US CDN opt out: Showpad’s principle hosting infrastructure is located within the EU at a first-class world-renowned hosting partner (AWS – 2 separate EU regions). CDN (Content delivery network) towards the Showpad US data centres can be switched off (AWS – US East region). Product engineering: All new product capabilities that are to be introduced within the Products and Services are vetted and checked for privacy compliance and follow three key cornerstones: (i) the GDPR principles of “privacy by design” and “privacy by default”, (ii) giving flexibility to both EU customers and non-EU customers to allow for localized application of the Products and Services – while (iii) keeping all changes as simple as possible. Elaborate privacy settings: The Products and Services provide for elaborate privacy settings allowing e.g. for a localized approach in a granular way or enabling/disabling tracking options. Self-Service Data Protection Agreement (DPA): To the extent the activities of the Showpad customer are covered by the material and territorial scope of an applicable data protection legislation (e.g. GDPR, CCPA, UK Data Protection Act, Swiss Data Protection act), such applicable data protection legislation may require that the processing of the personal data by the Showpad Products and Services is covered under a data processing agreement concluded between Showpad and its Customer. Showpad thereto makes available a complete DPA for self-execution via showpad.com/dpa that reflects the unique aspects of the Products and Services and containing all required specifics in order for the Showpad Customer to meet his legal obligations. 2. What security measures are used for the Products and Services? Showpad has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (a) the pseudonymisation and encryption of personal data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
Showpad shall thereto take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
While Showpad aims to implement industry-leading safeguards designed to protect Personal Data, we cannot guarantee that any Personal Data which was incidentally processed by the Showpad Customer (e.g. regulated or sensitive Personal Data, see FAQ’s B4 and B5) is maintained at levels of protection to meet specific needs or obligations the Showpad Customer may have relating to that type information.
The Showpad Information security program is covered under an ISO 27001 certification (see https://www.bsigroup.com/en-GB/our-services/certification/certificate-and-client-directory/), BSI certificate n° IS653767), as well as an ISAE3402 accreditation, and is audited on a regular basis by an external audit firm.
The Showpad Information security program is managed by the Showpad Information Security Team.
Showpad thereto makes available a complete DPA for self-execution via showpad.com/dpa that reflects the unique aspects of the Products and Services and containing all specifics – as required per the applicable data protection law – in order for the Showpad Customer to meet his legal obligations (e.g. standard contractual clauses).
Vie the URL www.showpad.com/dpa, you can access the e-signature platform where Showpad makes the DPA available for your review and possible execution.
D. Cookies
Cookie: a tiny data file that may be placed on Your Device when making use of the Products and Services that stores certain information and makes it available to the publisher of the cookie; Embedded scripts: programming code that is designed to collect information about your interactions with the Products and Services, such as the links you click on. The code is temporarily loaded onto your Device from a web server or a third-party service provider, and is active while your Devices is connected to the Products and Services. Web Beacons: Small graphic images (also known as “1×1 GIFs” or “clear GIFs”) that is designed to collect information about your interactions with the Products and Services, such as the emails you open. Web Beacons are temporarily loaded onto Your Device from a web server when making use of the Products and Services. 2. Do the Products and Services use Cookies or similar technology? The Cookies/Embedded scripts/Web Beacons used within the Products and Services enables certain features and functionalities of the Products and Services.
A Cookies/Embedded script/Web Beacons does not contain or collect information in isolation, but when read by a server via Your web browser or through the Products and Services, it can provide information to such server (e.g. to facilitate a more user-friendly service by registering users’ preferences, detect errors, account information, device identification, statistical data, …).
The SHOWPAD_SESSION cookie in the Prospect microsite environment, is optional and placing this cookie on an end user Device is dependent on i) the applicable privacy settings as determined by the administrator of the Showpad platform at our customers, and ii) the corresponding consent given (or not) by the Prospect in question to become subject to the profiling towards the Customer Content shared. If consent was provided, this cookie will be placed and has a validity period of 14 days, after which consent will be asked again to confirm continued tracking. Deleting this cookie restricts further processing of Personal Data of the Prospect in question.
Deleting or disabling a Cookie can be done by using the following options:
Web browser Most web browsers (e.g. Internet Explorer, Mozilla Firefox, Safari, and Google Chrome) have cookies automatically enabled. You can decide on whether and to what extent cookies will access Your end device by changing your browser settings.
Online assistance More information on cookies and the way to manage or refuse cookies per browser type (e.g. Internet Explorer, Mozilla Firefox, Chrome, Safari, …) can be found at https://www.allaboutcookies.org , https://www.aboutcookies.org or http://www.youronlinechoices.eu
Tools Certain tools (e.g. “Ghostery”, “Disconnect”, … ) may provide you with more granular options in order to manage cookies.
F. Rights of Data Subjects
Obtain access to and/or rectification of one’s Personal Data as processed by the Products and Services; Request to receive one’s Personal Data in a format at the discretion of the Showpad Customer (e.g. excel, .CSV file, via the Showpad API, …), that allows for the data portability of such data to a similar service; Withdraw one’s consent for processing of one’s Personal Data (be advised that such leaves unharmed and does not affect the prior lawful processing of one’s Personal Data, or the continuation of processing of (part of) Your Personal Data as allowed under an applicable legal ground (see FAQ B15) The restriction of processing of Your Personal Data under article 18 GDPR and/or right to object to the processing of Your Personal Data under article 21 GDPR. Please check the applicable data protection legislation for the ability to exercise such rights.
As Showpad is merely the data “Processor” (see FAQ B12) such rights need to be exercised towards the Showpad Customer, as being the data “Controller”. In order to exercise such rights, You may be required by the Showpad Customer to provide proof of Your identity by providing an official document (e.g. ID Card, driver’s license, …).
Should Showpad receive such request directly from You, Showpad can legally only pass such request on to the Showpad Customer. Showpad is legally not allowed to respond to such request, unless as instructed by the Showpad Customer.
From the moment it is established that the Data Subject request is related to a processing activity for which the Showpad Customer is data “Controller”, and to the extent the Showpad Customer is identified, Showpad shall pass on such request without undue delay to the respective Showpad Customer, in order for the Showpad Customer to respond to such request.
If You have an unresolved complaint, You always have the right to log a complaint with the competent “data protection authority”. Information on the competent data protection authority and the way of logging a complaint can be found here (or the URL as updated by the European Commission).
Showpad NV, located in Belgium, acts as so-called:
“main establishment” in the EEA under GDPR. “representative“ in line with section 27 GDPR for and on behalf of Showpad Inc. As a result, the competent Data Protection Authority for Showpad NV is the Belgian DPA (Drukpersstraat 35, 1000 Brussel / +32 (0)2 274 48 00 / contact@apd-gba.be / https://www.dataprotectionauthority.be/).
Showpad has appointed a data protection officer for the whole Showpad Group who can be contacted at “Office of the Data Protection Officer – Showpad NV – Moutstraat 62 – 9000 Gent (Belgium)” or privacy@showpad.com.
E. EU–US Privacy Shield
On July 12, 2016, the European Commission, through the “Commission implementing decision (EU) 2016/1250”, has accepted that the EU-U.S. Privacy Shield ensures an adequate level of protection for Personal Data transferred from the EEA to organisations in the United States, to the extent covered under the EU-U.S. Privacy Shield. To learn more about the Privacy Shield program, please see https://www.privacyshield.gov/Program-Overview.
Until further notice, the EU-U.S. Privacy Shield is deemed adequate to provide safeguards for transfers taking place from the UK towards a US Recipient, please see https://www.privacyshield.gov/article?id=Privacy-Shield-and-the-UK-FAQs
Showpad Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, resulting in the fact that personal data originating from within the EEA as well as the United Kingdom may legally be exported to Showpad Inc. under this basis.
If there is any conflict between the terms in these Privacy Principles and the EU-U.S. Privacy Shield Framework, the EU-U.S. Privacy Shield Framework shall govern.
For purposes of enforcing compliance with the EU-U.S. Privacy Shield, Showpad Inc. is subject to the investigatory and enforcement authority of the US Federal Trade Commission.
To learn more about the Privacy Shield program, and to view the Showpad Inc. certification, please visit https://www.privacyshield.gov.
Transfer to third parties Where Showpad Inc., has received Your Personal Data in the United States and subsequently transfers that information to a third-party recipient (e.g. a subprocessor), and such third-party recipient processes Your personal data in a manner inconsistent with the Privacy Shield Principles, Showpad Inc. may be responsible under the Privacy Shield Principles to the extent Showpad Inc. is responsible for the event giving rise to the damage.
Binding arbitration You may also have the option to select binding arbitration for the resolution of Your complaint under certain circumstances. To find out more about the Privacy Shield’s binding arbitration scheme please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
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 www.HeySummit.com and/or www.app.HeySummit.com (the "Platform") and what Insight activities are ongoing there too.
Please read these Privacy Statements carefully and ensure that you understand them. You will be able to change your Privacy Preferences at any time throughout your time using the Platform and thereafter.
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 support@heysummit.com Please be prepared to provide your first and last name and email address that matches information we currently have on file. Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from California consumers as required by law.