This event ('Paid Social Show 2020 in association with Majestic Monitor') has 'Additional Privacy Statements'

INTRODUCTION This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://www.brightonseo.com/ & https://ecommerceseosummit.heysummit.com/

By providing us with your data, you warrant to us that you are over 13 years of age.

Rough Agenda Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details Our full details are:

Full name of legal entity: Rough Agenda Limited

Email address: [email protected]

Postal address: King Place Suite, 3 King Place, Brighton, BN1 1GA

Telephone number: 01273 805525

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected] OR by clicking the link to update your preferences in any marketing email you receive from us.

WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business). [NOTE SEE SECTION 4 BELOW]

Sensitive Data We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at [email protected]. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

HOW WE COLLECT YOUR PERSONAL DATA We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

We will also collect personal data when you register to attend an event.

MARKETING COMMUNICATIONS Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at [email protected] at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

DISCLOSURES OF YOUR PERSONAL DATA We may have to share your personal data with the parties set out below:

Other companies in our group who provide services to us. Service providers who provide IT and system administration services. Professional advisers including lawyers, bankers, auditors and insurers Government bodies that require us to report processing activities. Sponsors and Exhibitors at our events. Third parties to whom we sell, transfer, or merge parts of our business or our assets. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

DATA SECURITY We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

DATA RETENTION We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at [email protected] .

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 or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

THIRD-PARTY LINKS This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit

COOKIES You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy,

DoubleClick: We use Google Adwords & Google Analytics remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.

HeySummit is not responsible for any part of the above Additional Statements and is only responsible for the Core Privacy Statements set out hereunder:

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HeySummit's 'Core Privacy Statements'

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.

Purpose of this Privacy Statement

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.

Controller/Processor

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.

Changes to our Privacy Statement and your duty to inform us of changes to your personal data

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.

Your access to and use of third party websites or services accessible through the HeySummit Services

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.

Third party web sites and applications.

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.

1. The data we collect about you

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:

• Identity Data which includes your image and first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. This may also include other audio-visual content which you appear in as you contribute to or interact with an Event.
• Contact Data which includes your home address, email address and telephone numbers.
• Transaction Data which includes details about payments you have made and other details of products and services you have accessed or used through the HeySummit Services. We do not store card details on our server. Credit and debit card payments are processed by Stripe on their secure payments server and all card details are fully encrypted and stored by them.
• Technical Data which includes your internet protocol (IP) address, your login data, browser type and version, hardware information, time zone setting and location, browser plug-in types and versions, operating system and website, and other technology on the devices you use to access the HeySummit Services.
• Profile Data which includes your username and password, purchases or orders made by you, your interests, volunteer record, preferences, feedback and survey responses.
• Usage Data which includes information about how you use our Services, as well as third-party platforms which you have linked to your use of our Services. Usage data includes metadata which provides additional context about the way the Services are being used such as length of visit, page views, navigation paths, and page interaction information (such as scrolling, clicks, mouse-overs, and mouse tracking) as well as information about the timing, frequency and pattern of use.
• Marketing and Communications Data which includes your preferences in receiving marketing from us and our third party partners and your communication preferences.
• User Generated Content which includes data you submit as part of an Event or as a result of your interactions with the HeySummit Services such as Event materials, videos, chats, and messaging. Please note, the host of the Event is the controller of this data.

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).

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and other Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you: (a) create an account with us; (b) subscribe (or are subscribed) to our services; (c) interact in an Event; (d) request marketing to be sent to you; (d) enter a promotion or survey; or (e) give us feedback or contact us.
• Automated technologies or interactions. As you interact with the HeySummit Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We also collect Usage Data via automated technologies as a result of your interaction with the HeySummit Services. We collect this personal data by using cookies, server logs and other similar technologies.
• Third-Parties. Depending on your use of the HeySummit Services, we may collect data about you from third-party service providers which you have linked to your use of our Services (including social media account and single-sign-on services), your employer, your administrator, the host of organiser of an Event you register for or attend, publicly available sources, data enrichment vendors, payment and delivery service vendors, advertising networks, analytics providers, and our business partners. The information which we receive from third parties depends on what policies that third party follows and our and your respective relationships with the third party.

3. How we use your personal data

The legal basis for using your information as set out in this Privacy Statement are as follows:

• Where we need to perform the contract we are about to enter into or have entered into with you (e.g. to provide you with access to the functionality of the HeySummit Services).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we have your consent.
• Where we need to comply with a legal obligation.

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.

4. Disclosures of your personal data

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.

• External Third Parties as set out in the Glossary.
• Third parties in connection with, or during negotiations of, any merger, sale or transfer of company assets, financing or acquisition of all or a portion of our business. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Statement.

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.

5. International transfers

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:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we only transfer data to them under the scope of a Data Processing Agreement that incorporates Standard Contractual Clauses (SCCs) approved by the European Commission or UK Information Commissioner's Office, or another legally applicable data transfer mechanism. We also ensure supplementary measures are in place, such as strong encryption, access controls, and audit logging. In particular, we rely on Amazon Web Services (AWS), which is certified under the EU-US Data Privacy Framework (DPF), ensuring an adequate level of protection for personal data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

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.

7. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Object to processing of your personal data. We will assess your request and determine whether we have any legal or other justification for continued processing.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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.

8. Contacting HeySummit

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:

• Full name and address of legal entity: Hey Summit Ltd of 71 - 75 Shelton Street, Covent Garden, WC2H 9JQ
• Email address: [email protected]

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.

9. Glossary

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

• Service providers acting as processors who provide our IT and system administration services.
• Providers of our cloud services such as AWS and Google.
• Stripe for the purposes of payment transaction management.
• Intercom who provides our chat and customer support features.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Our third-party partners and affiliates whom you engage with through the use of the HeySummit Services in order to facilitate the provision of the HeySummit Services.
• Hosts or Event organisers whose Events you attend through your use of the HeySummit Services.

Submitting Requests

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.