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Tech-CIO Privacy Statement
This privacy statement was last updated on June 2023.

Tech-CIO is committed to protecting your privacy. This privacy statement
describes why and how we collect, use and disclose personal information
collected from individuals themselves or other third parties, and provides
information about individuals’ rights concerning their personal data. We may use
personal information provided to us for any of the purposes described in the
relevant section of this privacy statement or as otherwise stated at the point
of collection.

Our goal is to process personal information as necessary for our legitimate
business purposes in a transparent manner. If you have any questions regarding
our privacy practices, please contact us as outlined in the Contact Us section
below.

“Tech-CIO” (and “we,” “us,” and “our”) refers to such Tech-CIO member companies
located in Europe, Africa and the United Kingdom:

(1) Is involved in providing or receiving services or products;
(2) Sends you communications;
(3) Posted a position for which you are applying;
(4) You have a role or relationship with, including through the use of and
access to our websites and applications;
(5) Each member organisation in the Tech-CIO network is a separate legal entity.

Our processing activities – To find out more, please go to the section(s) of
this statement that is relevant to you.


Business Contacts

Information Collection
We collect and use business contact details for individuals associated with
existing and potential Tech-CIO clients to manage and maintain our relationship
with those individuals. Like most businesses, we use a customer relationship
management system (the “Tech-CIO CRM”) to store personal information about our
business contacts.


The collection of personal information about contacts and adding that personal
information to the Tech-CIO CRM is initiated by Tech-CIO staff. It may include
name, employer name, title, phone, email and other business contact details.
Additionally, the Tech-CIO CRM may collect data from Tech-CIO email and calendar
systems concerning interactions between Tech-CIO staff and business contacts.


When we send you emails, we may use technologies to determine whether the email
has been opened and whether the links contained within the message have been
clicked on. We may combine information collected through these means with other
information we maintain about you to measure interest in our specific offerings
and email campaigns, improve our offerings to specific target audiences, and
tailor our interactions with you.



Information Use
We use this information for the following business purposes:

Administering, managing and developing our business and services. We may process
personal information to run our business, including:
– managing our relationship with clients;
– providing services and customer support to our clients;
– developing our business and services, such as identifying client needs and
improvements in service delivery and learning more about client relationship
opportunities with other Tech-CIO member organisations or we have an interest
in;
– analysing and evaluating the strength of interactions between Tech-CIO and a
contact (e.g., the Tech-CIO CRM uses an algorithm to help with this analysis,
and the evaluation is primarily based on interaction frequency, duration,
recency and response time);
– performing analytics, including trends, relationship maps, sales intelligence,
and progress against account business goals;
– maintaining and using IT systems;
– hosting or facilitating the hosting of events;
– conducting surveys (e.g. benchmarking) or quizzes; and
– administering and managing our website, systems, and applications.


Providing information about us and our range of services. Unless we are asked
not to, we use client business contact details to provide information that we
think will be of interest about Tech-CIO and our services. For example, we may
send you industry updates and insights, information about other services that
may be relevant to you and invites to events. Please review the Individual
Rights section below for information about how you may unsubscribe from our
mailing lists and exercise other rights.


Information Retention
Personal information will be retained in the Tech-CIO CRM for as long as we
have, or need to keep a record of, a relationship with a business contact.
Personal information may be held for longer periods where extended retention
periods are required by law, regulation, or professional standards to establish,
exercise or defend our legal rights.


Information Disclosure
We may disclose personal information as described in the Information Disclosure
section below. Also, business contacts stored in the Tech-CIO CRM may be
accessed by other Tech-CIO member organisations for the reasons described above.


Corporate Clients
We are part of a global network of organisations. In common with other
professional service providers, we use third parties in other countries to help
us run our business. As a result, personal information may be transferred
outside the countries where our clients and we are located. This includes
transfers to countries outside the European Economic Area (“EEA”) and countries
that may not have laws that provide the same degree of protection for personal
information as your home country. Following applicable legal requirements, we
take appropriate measures to facilitate adequate protection for any data
transferred.

Where we transfer personal information outside of the EEA to a country or
framework not determined by the European Commission as providing an adequate
level of protection for personal information, the transfers will be under an
agreement which covers European Union requirements for such transfers, such as
standard contractual clauses. The European Commission-approved standard
contractual clauses are available here.

Although not currently relied upon as an authorised mechanism for cross-border
transfers, Tech-CIO also adheres to the EU - U.S. Privacy Shield Framework and
the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of
Commerce.


Event Attendees
We will only disclose personal information to others for business purposes and
when legally permitted. When we disclose information to others, we put
contractual arrangements and security mechanisms in place to protect the
information and comply with our information protection, confidentiality and
security standards. In addition to any information disclosure practices
described in the relevant section under Our processing activities, we disclose
personal information to the following categories of recipients:

• Other Tech-CIO member organisations
– For details of our member organisations’ locations, please click here.
– We may disclose personal information to other Tech-CIO member organisations
where necessary for administrative purposes and to provide professional services
to our clients (e.g., when providing services involving advice from Tech-CIO
member organisations in different territories).
– We store personal information on our or other Tech-CIO member organisations’
servers in the United States, EU and Africa.
– IT support, and services are provided by Tech-CIO’s IT services.

• Third-party organisations that provide us with applications/functionality,
data processing or IT services. We use third parties to support us in providing
our services and to help provide, run and manage our internal IT systems – for
example, providers of information technology, cloud-based software-as-a-service,
identity management, website hosting and management, data analysis, data
back-up, security and storage services. The servers powering and facilitating
that cloud infrastructure are located in data centres worldwide, and personal
information may be stored in any of them. Further details of these providers are
set out below.

Microsoft Corporation Cloud Services One Microsoft Way, Redmond, WA 98052, USA
Data centres are located in several locations around the world (see Microsoft
website)


• Auditors, professional advisors and insurers
We engage auditors and other professional advisors, for example, law firms, as
necessary to establish, exercise or defend our legal rights and obtain advice
concerning the running of our business. Personal information may be disclosed to
these auditors and other advisors as necessary concerning the products and
services they have been engaged to provide. We also have several business
insurance policies in place, and we may need to disclose personal information to
the insurer, for example, in the event of a claim.


• Law enforcement or other government and regulatory agencies or other third
parties as required by applicable law or regulation

Occasionally, we may receive requests from third parties with authority to
obtain disclosure of personal information, such as to check that we are
complying with applicable law and regulation, to investigate an alleged crime,
and to establish, exercise or defend legal rights. We will only fulfil requests
for personal information where we are permitted to do so following applicable
law or regulation.

• Third-party organisations in connection with a corporate transaction
We may disclose personal information to a third party as necessary concerning a
corporate reorganisation, merger, sale, joint venture, assignment, transfer or
other disposition of all or any portion of our business, assets or capital.


Individual Clients

Unsubscribe 
Should you wish to unsubscribe from our mailing list or any registrations, we
will provide instructions in the appropriate area of the Site or in
communications to you. Users of our websites and applications Please see the
Users of our websites and applications section of this privacy statement for
additional information about your choices regarding the personal information we
collect through the Site.


Individual privacy rights 
In certain circumstances under applicable law, you may have the right to access
your personal information (including in a portable format if so requested), to
correct your personal information, to delete your personal information, and/or
to opt out of the sale of your personal information. 

Please use our request form to submit a request relating to these rights. We
will respond to your request within a reasonable timeframe in accordance with
applicable law. We hope you won’t ever need to, but if you want to complain
about our use of personal information, please send us a message with the details
of your complaint by completing our general contact form. Applicable laws may
also give you the right to lodge a complaint with the data protection authority
in your country.


Personnel & Sourcing

Information Collection
We collect personal information concerning our own personnel (partners,
principals and staff) and individual contractors to administer the employment
relationship and manage our business. Please refer to the privacy statements
available on Tech-CIO’s intranet for information on collecting and processing
your personal information about your role with Tech-CIO.


Sourcing and recruitment of candidates 
We collect and use personal information concerning our sourcing activities and
recruitment. If you are formally applying for one of Tech-CIO’s open positions,
you will be presented with separate privacy statements at the point of data
collection during these processes. Should your formal application result in
being extended and accepting an opportunity to join the Tech-CIO, you will also
be presented with privacy statements during onboarding. Please review those
privacy statements for information about how Tech-CIO processes personal
information concerning recruitment and onboarding.
We may collect the following personal information from you:
• Contact details (e.g., name, email, telephone number);
• Education, academic and professional qualifications;
• Locations and interest in global opportunities;
• Employment history;
• Your responses to surveys and quizzes, if you choose to participate;
• Areas of interest and specialised knowledge/subject matter; and
• Other information on your resume/CV you choose to submit.

We may also obtain the following personal information about you from third-party
sources:
• Social media profile information, if you choose to provide us with a link to
your profile page; and
• Information from social media sites you are a member, specific to your
engagement with our recruitment campaigns.


Information Use
We use such personal information for the following business purposes:

 * To attract talent and market opportunities at Tech-CIO, including arranging,
   hosting and participating in events, marketing and advertising opportunities,
   having on social media, and using recruiters to help find talent for us.
   
 * To identify and source talent by searching our talent pool and publicly
   available sources (such as professional networking and job websites of which
   you are a member).
   
 * To evaluate you for open positions that match your interests and experience
   throughout the Tech-CIO network, manage your talent profile, send you email
   notifications, surveys, quizzes, and other announcements, request additional
   information or otherwise contact you regarding recruitment, events, thought
   leadership, or other opportunities we believe may be of interest to you.
   
 * Any other purposes stated when you provide the information to Tech-CIO.
   


Please review the Individual Rights section below for information about how you
may unsubscribe from our mailing lists and exercise other rights.


Information Retention
We retain the personal information processed by us for as long as is considered
necessary for the purpose(s) for which it was collected. Personal information
may be held for longer periods where extended retention periods are required by
law, regulation, or professional standards to establish, exercise or defend our
legal rights.


Information Disclosure
We may disclose personal information as described in the Information Disclosure
section below.


Suppliers

Information Collection
We collect and process personal information about our suppliers (including
subcontractors and individuals associated with our suppliers and subcontractors)
to manage our relationships with our suppliers, receive services from our
suppliers, and, where relevant, provide professional services to our clients.
The personal information we process about our supplier contacts is generally
business card information and includes name, employer, phone number, email and
other business contact details, and communications with us.

Concerning individuals subcontracted to work for or with Tech-CIO, please refer
to the relevant privacy statement available on Tech-CIO’s intranet for
information on the collection and processing of your personal information about
your role with Tech-CIO.


Information Use
We use such personal information for the following business purposes:
• Receiving services. We process personal information about our suppliers and
their staff as necessary to receive the relevant services. For example, when a
supplier provides us with facilities management or other outsourced services, we
will process personal information about those providing services.
• Providing professional services to clients. Where a supplier is helping us to
deliver professional services to our clients, we process personal information
about the individuals involved in providing the services to administer and
manage our relationship with the supplier and the relevant individuals and to
provide such services to our clients (for example, where our supplier is
providing people to work with us as part of a Tech-CIO team providing
professional services to our clients).
• Administering, managing and developing our businesses and services. We may
process personal information to run our business, including:
– managing our relationships with suppliers;
– developing our businesses and services (such as identifying client needs and
improvements in service delivery);
– maintaining and using IT systems;
– conducting surveys;
– hosting or facilitating the hosting of events; and
– administering and managing our website and systems, and applications.
• Security, quality and risk management activities. We have security measures to
protect our and our client’s information (including personal information), which
involves detecting, investigating and resolving security threats.
Personal information may be processed as part of our security monitoring; for
example, automated scans to identify harmful emails. We have policies and
procedures to monitor the quality of our services and manage risks concerning
our suppliers. We collect and hold personal information as part of our supplier
contracting procedures. We monitor the services provided for quality purposes,
which may involve processing personal information.
• Providing information about us and our range of services. Unless we are asked
not to, we use business contact details to provide information that we think
will be of interest about us and our services -- for example, industry updates
and insights, other services that may be relevant and invite to events.
• Complying with any requirement of law, regulation or a professional body we
are a member of. As with any professional services provider, we are subject to
legal, regulatory and professional obligations. We need to keep certain records
to demonstrate that our services are provided in compliance with those
obligations, and those records may contain personal information.



Information Retention
Personal information will be retained about our contacts at our suppliers for as
long as it is necessary for the purposes set out above (e.g., for as long as we
have, or need to keep a record of, a relationship with a contact which is for
the duration of our relationship with a contact or their organisation). Personal
information may be held for longer periods where extended retention periods are
required by law, regulation, or professional standards and to establish,
exercise or defend our legal rights.



Information Disclosure
We may disclose personal information as described in the Information Disclosure
section below.




Website Users


Information Collection
This section describes our privacy practices concerning https://www.Tech-CIO.com
and other Tech-CIO websites, applications and online services that link to this
privacy statement (together referred to as the “Site”). We may provide a
separate privacy statement concerning our websites and applications. Where we do
so, such privacy statements will apply to our collection and use of personal
information collected through such websites and applications.

For information about our collection and use of information, such as login
credentials, that we process to provide client users with access to the
websites, applications, and other online services that we make available to
clients in connection with our professional services, please see the Corporate
clients section of this privacy statement.

For information about our collection and use of information received as part of
an application for employment submitted through our Site or if you join our
Talent Network or Talent Community through our Site, please see the Sourcing and
Recruitment of Candidates section of this privacy statement.

When you access or otherwise use our Site, we will collect information about you
and how you interact with our Site. We may collect information about you through
the following:
(1) information you provide;
(2) automatic tracking technologies; and
(3) third parties.

Information you provide
When you visit our Site, you may provide information about yourself, such as
your name, address, email address, telephone number, fax number, job title, and
company name. By way of example, you may choose to provide your information in
the following circumstances:
• Subscription or ordering newsletters and publications;
• Participation in "join our mailing list" initiatives;
• Participation in bulletin boards, discussion, or message forums;
• Entering surveys (e.g., benchmarking) or quizzes;
• Registration for events and conferences;
• Registration for premium online services;
• Contacting us for further information; and
• Visiting our Site while logged into a social media platform.

Automatically collected information
We use online identification technologies on our Site, such as cookies, web
beacons, SDKs, pixels or similar technologies (“Tracking Technologies”). The
information we collect using these technologies includes the IP address, other
identifiers, and information about your internet activity and browsing behaviour
on our Site. We also use website analytics providers, who may set Tracking
Technologies on your device. Tracking Technologies allows us to customise your
interactions with our Site and Tech-CIO and measure our marketing campaigns'
efficacy. (For more information about our use of Tracking Technologies, please
review our Cookie Information page.)

To correctly manage our Site, we also log anonymous information on our
operational systems and identify categories of visitors by items such as domains
and browser types. These statistics are reported in the aggregate to our website
administrators. This is to improve the web experience of our Site’s visitors and
to provide us with a practical information resource.

When we send you emails, we may use technologies to determine whether the email
has been opened and whether the links contained within the message have been
clicked on. We may combine information collected through these means with other
information we maintain about you to measure interest in our specific offerings
and email campaigns, improve our offerings to specific target audiences, and
tailor our interactions with you.


Information Use
We use the information we collect, as described above, for various purposes
depending on the context in which we collect the information. For example, it
may be necessary for us to process your data to process a transaction or provide
a service you have requested or otherwise by a contract between us, or we may
process your information in accordance with your prior consent (where you have
provided such consent).

We also use the information we collect for the following business purposes:
• Operating and improving the Site;
• Fulfilling your orders and requests;
• Managing your registration preferences;
• Customizing the Site and your interactions with Tech-CIO;
• Understanding how the Site is being used;
• Exploring ways to develop and grow our business;
• Maintaining and improving the safety and security of the Site;
• Preventing and enhancing protection against fraud, spam, harassment,
intellectual property infringement, crime and security risks;
• Sending you renewal notifications and/or service notifications;
• Conducting customer satisfaction surveys;
• Improving our products and services;
• Running our operations;
• Complying with the law and legal obligations;
• Responding to your inquiries; and
• Sending marketing communications about Tech-CIO products, services, and
events.

Information Retention

We will retain the personal information collected by us through the Site for as
long as is necessary for the purpose(s) for which it was collected as set out
above, provided that personal information may be held for longer periods where
extended retention periods are required by law, regulation, or professional
standards, and to establish, exercise or defend our legal rights.



Information Disclosure
We may disclose personal information as described in the Information Disclosure
section below.
Also, business contacts stored in the Tech-CIO CRM may be accessed by other
Tech-CIO member organisations for the reasons described above.


Third-Party Sites
Our Site may link to other websites not operating under Tech-CIO’s privacy
practices. When you visit other websites, Tech-CIO’s privacy practices no longer
apply. We encourage you to review each site’s privacy policy before disclosing
personal information.


Children
Tech-CIO understands the importance of protecting children’s privacy, primarily
online. The Site is not intentionally designed for or directed at children under
the age of 13 years. Tech-CIO’s policy is never to knowingly collect or maintain
personal information about children under 13 in connection with the Site.



Your Choices

Unsubscribe
Should you wish to unsubscribe from our mailing list or any registrations, we
will provide instructions in the appropriate area of the Site or in
communications to you.

Managing cookies
If you are concerned about cookies, most browsers permit individuals to decline
cookies. In most cases, you may refuse or delete one or more cookies and still
access our Site, but Site functionality may be impaired. After browsing our
websites, you may delete Site cookies from your system.

To manage the cookies and similar technologies used (tracking pixels, web
beacons, etc.) and related consents, we use the consent tool "Real Cookie
Banner". Details on how "Real Cookie Banner" works can be found at
https://devowl.io/rcb/data-processing/

The legal bases for the processing of personal data in this context are Art. 6
(1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the
management of the cookies and similar technologies used and the related
consents.

The provision of personal data is neither contractually required nor necessary
for the conclusion of a contract. You are not obliged to provide the personal
data. If you do not provide the personal data, we will not be able to manage
your consents.

Do not track
Do Not Track (“DNT”) is a privacy preference you can set in your web browser to
send a message to the website operator requesting not to be tracked. Currently,
we do not respond to these DNT signals. For more information about DNT, visit
https://allaboutdnt.com.

Other rights
For information about other rights you may have under applicable law, please see
the Individual Rights section of this privacy statement.



Other Contacts

Information Collection
We collect personal information (such as name, contact details and contents of
the communication) when an individual gets in touch with us with a question,
complaint, comment, survey response or other feedback. In these cases, we will
only use the information to respond to and keep a record of the communication.
We may disclose personal data as described in the Information Disclosure section
below.

Cross-Border Transfers
We are part of a global network of organisations. In common with other
professional service providers, we use third parties in other countries to help
us run our business. As a result, personal information may be transferred
outside the countries where our clients and we are located. This includes
transfers to countries outside the European Economic Area (“EEA”) and countries
that may not have laws that provide the same degree of protection for personal
information as your home country. Following applicable legal requirements, we
take appropriate measures to facilitate adequate protection for any data
transferred. 

Where we transfer personal information outside of the EEA to a country or
framework not determined by the European Commission as providing an adequate
level of protection for personal information, the transfers will be under an
agreement which covers European Union requirements for such transfers, such as
standard contractual clauses. The European Commission-approved standard
contractual clauses are available here. 

Although not currently relied upon as an authorised mechanism for cross-border
transfers, Tech-CIO also adheres to the EU - U.S. Privacy Shield Framework and
the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of
Commerce.


Individual Rights

Unsubscribe
Should you wish to unsubscribe from our mailing list or any registrations, we
will provide instructions in the appropriate area of the Site or in
communications to you.

Users of our websites and applications Please see the Users of our websites and
applications section of this privacy statement for additional information about
your choices regarding the personal information we collect through the Site.

Individual privacy rights
In certain circumstances under applicable law, you may have the right to access
your personal information (including in a portable format if so requested), to
correct your personal information, to delete your personal information, and/or
to opt out of the sale of your personal information.

Please use our request form to submit a request relating to these rights. We
will respond to your request within a reasonable timeframe in accordance with
applicable law.

We hope you won’t ever need to, but if you want to complain about our use of
personal information, please send us a message with the details of your
complaint by completing our general contact form. Applicable laws may also give
you the right to lodge a complaint with the data protection authority in your
country.



Information Disclosure
We will only disclose personal information to others for business purposes and
when legally permitted. When we disclose information to others, we put
contractual arrangements and security mechanisms in place to protect the
information and comply with our information protection, confidentiality and
security standards. In addition to any information disclosure practices
described in the relevant section under Our processing activities, we disclose
personal information to the following categories of recipients:

• Other Tech-CIO member organisations
– For details of our member organisations’ locations, please click here.
– We may disclose personal information to other Tech-CIO member organisations
where necessary for administrative purposes and to provide professional services
to our clients (e.g., when providing services involving advice from Tech-CIO
member organisations in different territories).
– We store personal information on our or other Tech-CIO member organisations’
servers in the United States, EU and Africa.
IT support, and services are provided by Tech-CIO’s IT services.

• Third-party organisations that provide us with applications/functionality,
data processing or IT services. We use third parties to support us in providing
our services and to help provide, run and manage our internal IT systems – for
example, providers of information technology, cloud-based software-as-a-service,
identity management, website hosting and management, data analysis, data
back-up, security and storage services. The servers powering and facilitating
that cloud infrastructure are located in data centres worldwide, and personal
information may be stored in any of them. Further details of these providers are
set out below.

Microsoft Corporation Cloud Services One Microsoft Way, Redmond, WA 98052, USA
Data centres are located in several locations around the world (see Microsoft
website)

• Auditors, professional advisors and insurers
We engage auditors and other professional advisors, for example, law firms, as
necessary to establish, exercise or defend our legal rights and obtain advice
concerning the running of our business. Personal information may be disclosed to
these auditors and other advisors as necessary concerning the products and
services they have been engaged to provide. We also have several business
insurance policies in place, and we may need to disclose personal
information to the insurer, for example, in the event of a claim.

• Law enforcement or other government and regulatory agencies or other third
parties as required by applicable law or regulation
Occasionally, we may receive requests from third parties with authority to
obtain disclosure of personal information, such as to check that we are
complying with applicable law and regulation, to investigate an alleged crime,
and to establish, exercise or defend legal rights. We will only fulfil requests
for personal information where we are permitted to do so following applicable
law or regulation.

• Third-party organisations in connection with a corporate transaction
We may disclose personal information to a third party as necessary concerning a
corporate reorganisation, merger, sale, joint venture, assignment, transfer or
other disposition of all or any portion of our business, assets or capital.



Security

Tech-CIO has implemented generally accepted standards of technology and
operational security designed to protect personal information from loss, misuse,
alteration or destruction. Only authorised Tech-CIO personnel and the third
parties described in this privacy statement are provided access to personal
data. These employees and third parties have agreed to maintain the
confidentiality of this information. 

Please note that if we need to contact you about a matter involving your data,
we may email you about the issue.



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