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IN PRINT. ONLINE. IN PERSON.

INCORPORATING: Credit Strategy | Reward Strategy


PRIVACY NOTICE


SHARD FINANCIAL MEDIA LIMITED PRIVACY NOTICE


This policy applies to personal information collected on websites owned or
controlled by Shard Financial Media Limited and its UK group companies and their
brands - for a list of these brands click here (collectively referred to in this
policy as "we", "us" or "our").

This Privacy Notice explains how we use your information and how you can limit
our use of that personal data. The data controller in respect of this website is
Shard Financial Media Limited.

We comply with applicable data protection legislation such as the UK’s Data
Protection Act 2018, and the General Data Protection Regulation as it applies in
the UK. These regulate the processing of personal data relating to you and grant
you various rights in respect of your personal data.


INFORMATION WE COLLECT FROM YOU


We have set out in the tables below the categories of personal data we collect
about you:



Categories of personal data Description of category Account Registration Data
This is the personal data that is provided by you or collected by us to enable
you to sign up for and use our services. This includes your email address,
company, job title, first name and last name.

Some of the personal data we will ask you to provide is required in order to
create your account. You also have the option to provide us with some additional
personal data in order to make your account more personalized. Someone from your
organisation may provide some of this information on your behalf in order for us
to set up your account. Marketing and Events Data This personal data is used to
enable us and our partners / service providers / sponsors to send you marketing
communications or information about events either:


 * Via email; and/or
 * Direct from the third party.


You can find out more about the personal data collected and the controls you
have in relation to the marketing communications you receive via the Preferences
Center on our websites such as www.creditstrategy.co.uk or
www.reward-strategy.com. Generally this information will include your name and
email address.

We may use third party data companies who provide us with lead information on
businesses. This means they may send us business email addresses for potential
customers.

Buzzing Lab Solutions
The Data Business Contests, Surveys and Sweepstakes Data This personal data is
used to allow you to sign up and participate in these types of promotions. The
exact personal data collected will vary depending on the promotion.


HOW WE GATHER INFORMATION

Information is gathered in three ways:

 * through third parties (e.g. someone from your organisation provides us with
   your information on your behalf, or a third party data company provides us
   with your information);
 * indirectly from you (e.g. using website technology or technology when you use
   a Shard application for a mobile device); and
 * directly from you (e.g. when you buy one of our products, register to access
   parts of our websites or download a whitepaper or surveys


USE OF YOUR INFORMATION

We use your personal information to:

 1. remember you when you visit our website and track your browsing patterns by
    using cookies.
 2. ensure any products or services you receive are correctly administered
    (including subscriptions).
 3. contact you by email, mail, SMS or other electronic/online message, or
    telephone to let you know about any of our products, services or promotions
    (which, in some cases may be provided by third parties), you can always
    opt-out of this, and our emails will include a way for you to unsubscribe.
 4. allow partners or sponsors of events/content you are attending to contact
    you (although we will require those sponsors to comply with data protection
    law when using your information, they will be acting as controllers in their
    own right and if you need more information on how they use your information,
    you should contact them).
 5. ensure materials on the website are presented in the most effective manner
    for you and your computer.
 6. collate and log numeric internet addresses to improve the website and to
    monitor website usage.

We have described below which legal basis we use to process your data for our
purposes.



Description of why we process your personal data ('processing purpose') Legal
Basis for the processing purpose (where we rely on a Legitimate Interest, the
interest in question is set out in the description of why we use your data)
Categories of personal data used by us for the processing purpose To communicate
with you for our Service-related purposes.
 * Performance of a Contract
 * Legitimate Interest

 * Account Registration Data

To communicate with you, either directly or through one of our partners or
sponsors, for:

 * marketing,
 * research,
 * participation in contests, surveys and sweepstakes,
 * promotional purposes,

via emails, notifications, or other messages, including (where applicable) as is
consistent with any preferences you may have communicated to us (e.g., through
your Account Settings page).
 * Consent (in limited circumstances where we specifically request your consent)
 * Legitimate Interest

 * Contests, Surveys and Sweepstakes Data
 * Marketing and Events Data

To allow our partners, or sponsors of events or content (including webinars,
white papers, on-demand video content, surveys, case studies, masterclasses and
round tables) you are attending, using or viewing (either in person or
digitally) to contact you about that event or content or their services, as
necessary for their interests in contacting you for those purposes.
 * Legitimate Interest
 * Consent (in some circumstances, we may ask you for your consent to share your
   information with a specific partner or sponsor, in which case our sharing of
   that information will be based on consent, rather than a legitimate
   interest).

 * Marketing and Events Data

To provide, personalise, and improve your experience with our services and
products, for example by providing customised, personalised, or localised
content, recommendations, features, and advertising on or outside of our Service
(including for third party products and services).

 * Performance of a Contract
 * Legitimate Interest

 * Account Registration Data

To understand how you access and use our website to ensure technical
functionality of the services we provide, develop new products and services, and
analyze your use of the website, including your interaction with applications,
advertising, products, and services that are made available, linked to, or
offered through the website.
 * Performance of a Contract
 * Legitimate Interest

 * Account Registration Data



If you require further information about the balancing tests that we have
undertaken to justify its reliance on the legitimate interest legal basis under
the GDPR, please contact us for further details at
dataprotection@shardfinancialmedia.com

If at any point, you would like to stop receiving such marketing communications
from us, please click on the unsubscribe link at the bottom of any emails you
receive. You can also manage your preferences at the Preferences Centre on your
Account page. Alternatively, email us stating your preferences at
marketing@shardfinancialmedia.com

If you have any questions about your privacy, your rights, or how to exercise
them, please contact our Data Protection Officer using the 'Contact Us' form on
the Privacy Center.


ACCESSING YOUR PERSONAL INFORMATION

You can update your details and marketing preferences by accessing your account
pages on the website here, by emailing dataprotection@shardfinancialmedia.com or
by writing to us at Shard Financial Media, Axe & Bottle Court, 70 Newcomen
Street, London, SE1 1YT.

If you have not purchased our products, engaged with us at any of our events or
shown any activity on our website for more than two years, we will remove your
information from our database to ensure we are only keeping data we need.

You have the right to access the personal information held about you. To find
out more about your rights as a data subject, click here for a guide provided by
the Information Commissioner's Office. In summary, your rights include:

 1. Right of Access - the right to be informed of and request access to the
    personal data we process about you;
 2. Right to Rectification - the right to request that we amend or update your
    personal data where it is inaccurate or incomplete;
 3. Right to Erasure - the right to request that we delete your personal data;
 4. Right to Restrict - the right to request that we temporarily or permanently
    stop processing all or some of your personal data;
 5. Right to Object -the right, at any time, to object to us processing your
    personal data on grounds relating to your particular situation; the right to
    object to your personal data being processed for direct marketing purposes;
 6. Right to Data Portability - the right to request a copy of your personal
    data in electronic format and the right to transmit that personal data for
    use in another party's service; and
 7. Right not to be subject to Automated Decision-making - the right to not be
    subject to a decision based solely on automated decision making, including
    profiling, where the decision would have a legal effect on you or produce a
    similarly significant effect.

To obtain a copy of the personal information we hold about you, please fill in
our Subject Access Request form. If you wish to exercise your Right to
Object/Restrict processing, please fill in this form. Lastly, if you would like
to exercise your Right to be Forgotten, please fill in this form. Alternatively,
you can contact us using the details in this Privacy Notice (but please note we
may take longer to respond). Our Data Protection team will aim to respond to
your request within 48 hours.


SECURITY

The password you provide when registering with the website is encrypted to
ensure protection against unauthorised access to your personal information.

We invest in high-quality security and do our utmost to protect user privacy. No
data transmission over the Internet can be entirely secure, and therefore we
cannot guarantee the security of your personal information and/or use of the
website. Any information that you send is at your own risk and may be read by
others. However, once we have received your personal information we use strict
procedures to protect the security of your personal information.


DISCLOSING YOUR INFORMATION

We may disclose your personal information if we are approached by a potential
buyer of our business, if we are required to do so by law or in good-faith
believing such action is necessary to comply with the law.

As well as sharing details with sponsors and partners as set out above, we may
share your details with our third party service providers so they may provide
their services to us (for instance, we may need to share your details with our
webinar provider to ensure you can access the relevant webinar). In particular,
we use Affino, Swapcard, SurveyMonkey and GoToWebinar to provide our services,
and will share limited personal data with them as necessary for their provision
of services to us.

If you give us consent to receive Third Party communications, the following
carefully-screened Third Parties will be given your information. These Third
Parties can be found on the following marketplace/ Directory:

Credit Strategy's marketplace - You can withdraw this consent any time on your
account here.

Reward Strategy's directory - You can withdraw this consent any time on your
account here. 

We always try to ensure that you will only receive communications that are
relevant to your interest(s) and/or to an event that you've attended.


WHERE WE STORE YOUR PERSONAL INFORMATION

The personal information that we collect from you may be sent and stored outside
the European Economic Area ("EEA") in order to carry out the activities listed
in "Use of Your Information".


CAREERS

How your personal data will be used

We hold and process personal data about you in order to assess and verify
suitability for a role. For successful and unsuccessful candidates, we usually
keep this information for one year and information may be shared with any
recruiting managers and Human Resources. You have a number of rights with
regards to how your data is protected.

By providing us with your information you will have the right to access and
rectify your personal details. If you did wish to access your data, you shall
have the right to view or receive a copy of the information in a commonly used
format such as a pdf document or an e-mail. You may also have the right to ask
for the processing of your personal data to be restricted or even erased.
Whether or not you exercise the right to erasure, the Company will erase your
personal data in certain situations and particularly when the data is no longer
required.

At any time, you may have the right to object to the processing of your personal
data where processing is conducted for legitimate business reasons. If you
exercise this right, then unless we have compelling reasons not to, we shall
cease to process your data wherever data protection laws allow.


MORE INFORMATION

If you have any queries or you wish to speak to us about how your information
will be used, then please contact us at Shard Financial Media on 020 7940 4840

In the event that you should have a complaint about how your data has been
processed by us, we would like to hear from you so that we may put it right.
However, you will always have the right to lodge a complaint with the
Information Commissioner's Office.


CHANGES TO THIS POLICY

If we change our Policy, we will post the changes on this page and email you
regarding any updates. Please check the website regularly for any changes to
this Policy. Where the changes are significant, we may also choose to email all
our registered users with the new details. Where required by law, we will obtain
your consent to make these changes. 

If you believe that we have not adhered to this Policy, please notify us by
email at dataprotection@shardfinancialmedia.com and we will try to solve the
problem promptly.

This Policy was last updated on 15th March 2021.

Shard Financial Media, a fast-growing business serving key communities in UK and
Pan-European financial services.We have a respected presence in consumer and
commercial lending, collections and credit management, payroll and rewards, and
turnaround, restructuring and insolvency (TRI) – and the list is growing all the
time.
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