The 2112 Strategy Group, LLC, Privacy Policy 2018

The 2112 Strategy Group is committed to protecting your data and your privacy. This Privacy Policy (the “Policy”) explains how we collect and use information that you provide. Our data governance and privacy policies reflect our company’s values and how we strive to maintain your privacy.

This Policy discloses the privacy practices of The 2112 Strategy Group, LLC (“2112”) and governs how we use and protect personal information that we collect when you visit our Website, take part in our research programs, register for our services or events, or otherwise engage with us. Any practices or points that are specific to 2112 are also clearly marked in this Policy. We will attempt to post or display a link to this Policy on all forms and online pages to which it applies.

Any use you make of 2112 service offerings is subject to 2112’s Terms of Use (TOU).

Who We Are and What We Do

The 2112 Strategy Group, LLC is a limited liability corporation registered in New York state, with a principal office located at 51 Shadyside Avenue, Port Washington, NY, 11050, United States of America.

2112 provides a range of business strategy and research services to help technology industry professionals lead their organizations. Our services include but are not limited to:

• Research reports and Web-based multimedia content
• Technology industry analysis
• Quantitative, qualitative, and secondary research programs and surveys
• Business strategy subscriptions and services
• Consulting projects
• Events, presentations, and workshops

Questions or Concerns: Contact Us

Questions or concerns regarding the content, meaning, or enforcement of, or compliance with, this Policy should be directed to:

FAO: Data Protection Officer

Address: The 2112 Strategy Group, LLC, 51 Shadyside Ave., Port Washington, NY 11050, USA

Email: privacy@the2112group.com

The contact information above should also be used for communications relating to exercising the rights described below.

Information We Collect

When you access or download our online content, take part in our research, create an account on our Website, register for our events, or work with us on consulting engagements, you provide us with a variety of personal information. If you are not a paid member of 2112 services, you may choose to provide us with basic contact information in order to receive updates about our services and events.

Information You Provide to Us Directly

We gather information that you provide to us when you:

• Purchase products or services from us
• Subscribe to our newsletters and mailing lists
• Fill in forms, conduct searches, post content on our Website, respond to surveys, or use any other features of our Website
• Make an inquiry, provide feedback, submit correspondence, or make a complaint over the phone, by e-mail, on our Website, or by post
• Register for and/or update an online account with us
• Enter into a contract with us
• Apply for employment
• “Follow,” “like,” post to, or interact with our social media accounts, including but not limited to Facebook, LinkedIn, Twitter, and Instagram

The information you provide to us will include (depending on the circumstances):

• Identity and contact data: title, names, addresses, e-mail addresses, phone numbers, or your signature
• Account profile data: a username/display name, password, user preferences, and, if you sign up through a social media account, certain information about that account
• Conference registration details: the company/organization you work for, job title/position, language preferences, your name, your e-mail, your age, your gender, your job function, your experience, your opinions, why you are attending the conference and what you hope to learn, and your accessibility needs
• Financial data: payment details, which may include billing addresses, credit/debit card details, and bank account details
• Employment and background data: if you apply for employment, your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the relevant country, your national identification number, your passport or other identity document details, your current level of remuneration (including benefits), and any other such similar information that you may provide to us
• Visual and audio information about yourself: a photo, video footage, or sound recording, for example
• Your preferences: information about your preferences, interests, industry focus, community choices, and other customer profile information
• Any other information that you choose to share with us: for example, any information that you provide via correspondence, when you fill out our survey(s), that you share via our Website or social media accounts linked to our Website, or any information that you choose to provide in person at events, meetings, or over the phone

Information We Collect Through Automated and Online Technology

When you visit our Website or respond to our surveys, we automatically collect certain information, including:

• Unique browser identifiers
• IP addresses
• Operating system information
• Device identifiers
• Geolocation
• Internet connection information
• Details about your interactions with 2112 Websites and apps

Use of Cookies and Web Analytic Tools

We use “cookies” and other automated data collection technologies, including Web beacons and clear GIFs associated with cookies, on our Web pages, in newsletters, and in our e-mail campaigns to collect information both on an aggregate and individual basis. These technologies make it easier for you to navigate our Website and to help us manage the content on our Website and are used to analyze trends, administer the site, track users’ movements around the site (including which site you clicked from to arrive at our site), and gather demographic information about our user base. Our cookies store small pieces of non-personal identifiable data on your computer’s hard drive in accordance with your Internet browser settings to provide an enhanced and customized browser experience.

Information From Other Sources

In certain circumstances, we will receive information about you from other sources, including third parties. For example, we may receive personal information from any of the following, who may be based inside and/or outside the EU:

• Other Website users
• Event attendees
• Your agents or representatives who are acting on your instructions
• Commercial contact lists that we acquire from other organizations
• Organizations that we acquire or merge with
• Organizations with which 2112 provides professional and other services
• Organizations with which 2112 provides co-branded events, Websites, products, and services
• Fraud detection agencies
• Service providers including our Website developers, IT support providers, cloud services providers, payment services providers, billing service providers, contractors, consultants, advertising agencies and platforms, digital performance monitoring and management providers, advertising analytics providers, marketing and sales service providers, user experience testing platforms, B2B contact databases, recruitment agencies, survey tool providers, customer relationship and customer support service providers, event ticket retailers, event management platform service providers, customer identity account management providers, HR service providers, couriers, and instant messaging service providers
• Social media plugins; by providing your social media account details, you are authorizing that third-party provider to share with us certain information about you
• Publicly available sources such as social media

We might also receive information about you from other third parties if you have indicated to such third parties that you would like to hear from us.

How We Use Information We Collect

We will use your information to:

• Provide you with, or improve upon, our products and services and respond to requests that you initiate
• Provide access to our Website in a manner convenient and optimal and with personalized content relevant to you
• Work with you and undertake projects with you, including to process any proposals that you submit to us
• Process and fulfill your orders for 2112 products and services
• Let you know about news, events, new Website features, products, or services that we believe may interest you, including sharing your information with our marketing service providers
• Process any job applications you submit to us, whether directly or via an agent or recruiter, including sharing your information with our third-party recruitment agencies
• Gain additional information about you from other sources in furtherance of 2112’s, and 2112’s clients’, business and marketing objectives
• Comply with your preferences and do-not-contact requests
• Manage our relationship with you, which might include notifying you about changes to our terms of service or privacy policy, or asking you to leave a review or take a survey
• Monitor your account and use of services to ensure compliance with our end-user agreements and prevent and identify unlawful content use and violations and to protect against, investigate, and deter fraudulent, unauthorized, or illegal activity
• Conduct data analytics to improve our Website, products/services, marketing, customer relationships, and experiences
• Carry out marketing research and user testing to assess the levels of satisfaction of existing and proposed products and services

Sharing With Third Parties

We do not sell the personal information we collect to third parties. At times, 2112 may make the minimal level of your contact information available to vendors that provide services to 2112 in order to service you. In such cases, you are provided the option to opt out ahead of time. You may request our Data Processing Addendums with our vendors on a case-by-case basis. We may also share your personal information with certain third parties, in limited circumstances, including:

• Sponsors, partners, and collaborators, including sponsors of our events, products, or services, and organizations with which we host co-branded events
• Our service providers who are acting as processors and who assist us with our administrative or business functions, or in the provision of any of our products/services to you
• Regulators and governmental bodies and other authorities and regulators acting as processors or joint controllers who require reporting of processing activities in certain circumstances
• Marketing parties – that is, any selected third party that you consent to our sharing your information with for marketing purposes
• Any prospective buyer of our business or assets, only in the event that we wish to sell any part of our business or assets
• Other third parties including legal, professional, or other advisors, regulatory authorities, courts, law enforcement agencies, and government agencies where necessary to enable us to enforce our legal rights, or to protect the rights, property, or safety of our employees or where such disclosure may be permitted or required by law

How We Handle Your Information

Data Retention

We will keep your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require the retention of the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do so.

Please contact us at privacy@the2112group.com if you would like to obtain details of our retention periods for different aspects of your personal data.

Security

We use administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of personal data against loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We also operate a policy of “privacy by design” by looking for opportunities to minimize the amount of personal information we hold about you.

The safeguards we use include:

• Ensuring the physical security of our offices or other sites
• Ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption
• Using standard security protocols and mechanisms (such as secure socket layer, or SSL, encryption) to transmit sensitive data such as credit card details
• Maintaining a data protection policy for, and delivering data protection training to, our employees and contractors
• Limiting access to your personal information to those who need to use it in the course of their work

If you have any questions about the security of your personal information, please contact privacy@the2112group.com for further information.

Your Rights to Your Data Under GDPR

In compliance with the European Union’s General Data Protection Regulation 2016/679 (GDPR), you have the right to:

• Be informed of the ways in which we use your information, as we seek to do in this Policy
• Ask us not to process your personal data for marketing purposes
• Request access to the information that we hold about you
• Request that we correct or rectify any information that we hold about you which is out-of-date or incorrect
• Withdraw your consent for our use of your information in reliance of your consent
• Receive a copy of any information we hold about you in a structured, commonly used, machine-readable format, in certain circumstances
• Ask us, in certain limited circumstances, to limit or cease processing or erase information we hold about you
• Lodge a complaint about us to the Information Commissioner’s Office, as well as lodge a complaint with the relevant authority in your country of work or residence

How to Exercise Your Rights

We may need to request specific information from you to help us confirm your identity and to enable you to exercise the rights set out above. 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.

You will not have to pay a fee to exercise the rights set out above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will 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 if you have made a number of requests. In this case, we will notify you and keep you updated.

Please contact privacy@the2112group.com for further information.

Privacy Shield Notice

The 2112 Strategy Group, LLC (2112) participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. 2112 has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. To learn more about the Privacy Shield program, please visit www.privacyshield.gov.

2112 is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. 2112 complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, 2112 is subject to the regulatory enforcement authority of the U.S. Federal Trade Commission. In certain situations, 2112 may be required to disclose personal data in response to lawful requests by government authorities, including to meet national security or law enforcement requirements.

Dispute Resolution

In compliance with the EU-U.S. Privacy Shield, 2112 commits to resolve complaints free of charge about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding their data should first contact:

FAO: Data Protection Officer

Address: The 2112 Group, LLC, 51 Shadyside Ave., Port Washington, NY 11050, USA

Email: privacy@the2112group.com

2112 is committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

If your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Changes to Our Privacy Policy

We may update this Policy periodically to reflect changes to our information practices. If we make any changes, we will post them on this Website. We encourage you to review this page periodically for the latest information on our privacy practices. Changes take effect immediately upon posting.

This Policy was last updated on May 25, 2018.