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PRIVACY POLICY


PRIVACY POLICY

This Privacy Policy describes the ways in which information about you may be
collected, used, disclosed, transferred and stored by Penta Group, LLC and its
affiliates (such affiliates, the entities listed below in Section 2,
collectively with Penta Group, LLC “Penta”).

The Privacy Policy applies to any interaction with Penta, including through any
websites, platforms or applications (together hereinafter referred to as the
"Site" or "Sites").


1. CONTENTS

This Privacy Policy consists of the sections set out below. For ease of
reference, please click on the relevant section to go directly to that section.

 * Who we are
 * Purpose of this Privacy Policy
 * Children
 * What data we may collect from you
 * How we collect information from you
 * How we use your personal data
 * Marketing
 * Retention of your data
 * Accuracy of your data
 * Security of your data
 * Transfer of your data to third parties, international transfers of personal
   data and sharing your data
 * Third party links
 * Your rights - United Kingdom, European Economic Area (EEA) and Switzerland
 * Cookies
 * Amendments to this Privacy Policy
 * How to contact us


2. WHO WE ARE

Penta Group, LLC
805 15th Street, NW
Suite 200
Washington, D.C. 20005

Penta Group Europe Limited
Unit 5.10
The Printworks
164/180 Union St
London SE1 0LH

You may contact Penta at the following email address: info@pentagroup.co.

Our representative in the European Union is Taylor Vintners Europe Limited. You
can contact them by mail/post at: Clifton House, Fitzwilliam Street Lower,
Dublin, Dublin, D02 Xt91, Ireland, or by email at
representative@taylorvinters.com

When we refer to the “Company”, “we", “us" or “our" in this Privacy Policy, we
are referring to the relevant Penta entity that is processing your personal
data.

We are a leading provider of stakeholder solutions.


3. PURPOSE OF THIS PRIVACY POLICY

We ask that you read this Privacy Policy carefully as it contains important
information about:

 * what personal data we may collect from you;
 * how we will use, store and protect your personal data;
 * with whom we may share personal data; and
 * your rights under relevant data protection laws.

It is important that you read this Privacy Policy together with any other
privacy notice or fair processing notice we 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 Policy supplements the
other notices and is not intended to override them.

This Privacy Policy sits alongside the Terms of Use for our websites, which we
also encourage you to read.


4. CHILDREN

Our Sites are intended for use by adults, and we do not knowingly collect
information from or about children.  If you are a parent or guardian and your
child who is under 13 (or other ages as appropriate by country) may have
provided personal data to our Site, please contact us.  The age of consent for
processing personal data in the United Kingdom (the “UK”) is 13 and such age
varies from country to country and state to state.


5.WHAT PERSONAL DATA WE MAY COLLECT FROM YOU

We may collect and process the following personal data:

 * Identity data: your full name, title, username, job title, company name, and
   any other information you might include in a communication to us, including
   through our “Get in Touch” webform.
 * Contact data: billing address, delivery address (which could be your office
   address), personal email address, company email address, personal telephone
   number (mobile and landline) and company telephone number.
 * Transaction data: details about payments to and from you, placed order, order
   history and other details about the products and services you have purchased
   from us.
 * Technical data: device Internet Protocol (IP) address, geolocation, your
   behavior on the Site (e.g. number of visits, information about how you access
   our Sites, your domains of origin as well as what content you read and
   click), your login data, browser type and version, cookies, time zone setting
   and location (including geolocation), browser plug-in types and versions,
   operating system and platform and other technology on the devices you use to
   access our Site, vehicle registration details and images.
 * Profile data: your username and password, purchases or orders made by you,
   date, duration and time of your calls, a record of calls made to, or by, you,
   your interests and preferences and your feedback and survey responses.
 * Usage data: information about how you use of our Site, products and services.
 * Marketing and communications data: your preferences in receiving marketing
   from us and our business partners and your communication preferences.
 * Visitor data: information about your visits, including date and time, vehicle
   registration, account of any accidents and video footage from CCTV
   surveillance (if you visit one of our offices).


6. HOW WE COLLECT INFORMATION FROM YOU

We collect your personal data in a number of ways, including as follows:

 * Automatically: as you browse our Sites, certain information relating to your
   browsing patterns and technical data about the equipment you are using to
   access the Site is automatically collected using cookies, server logs and
   other similar technologies.
 * Directly from you:contact details, financial, identity data, transaction
   data, profile data or any other information directly provided by you or your
   employer when you or your employer request our services, you use our
   services, you fill in online forms or communicate with us in any way, for
   example when you:
   
   * call us in connection with our services;
   * enter into a contract with us (or someone does so on your behalf);
   * create or log into online accounts;
   * visit our offices;
   * submit a query;
   * request or consent to marketing materials being sent to you;
   * provide with feedback or contacting us for any reason; or
 * From Third Parties:
   * your employer, if you are identified as a contact for our services;
   * third party service providers and business partners engaged by us to
     provide services to you;
   * publicly available sources such as third party and regulatory body websites
     and social media.


7. HOW WE USE YOUR PERSONAL DATA

We have briefly set out below the purposes for which we may use your personal
data. We have also identified one or more legal bases on which we rely on for
processing your personal data.    

 * To provide the requested services. We may use independent contractors or
   consultants to provide and deliver our services to you. These individuals
   (and any related entities) may have access to your personal data only as
   needed to perform their functions and are obligated to maintain the
   confidentiality of your personal data. Legal bases: performance of a contract
   with you, to comply with a legal obligation (including health and safety),
   our and third party legitimate interests (performance of a contract with a
   third party like your employer, to manage our business relationship with you
   and third parties, to keep our records updated and to study how customers use
   our services). We may also share such details if you provide written
   permission to us to transmit this information on your behalf.
 * Processing of invoices/payment and collection of payments due to us: Legal
   bases: performance of a contract with you, our legitimate interests
   (performance of a contract with a third party like your employer, to manage
   our business relationship with you and third parties, to recover amounts due
   to us, to keep our records updated).
 * To improve our services and for quality and training purposes: Legal bases:
   our legitimate interests (to improve our business and services and to study
   how customers use our services/ to develop them and grow our business).
 * For benchmarking and statistical purposes: Legal bases: our legitimate
   interests (to improve our business and services, to study how customers use
   our services/ to develop them and grow our business, to improve marketing of
   our business and services).
 * To personalize your experience on our Sites and optimize and develop user
   experience on our Sites: Legal bases: our legitimate interests (to improve
   our business and services, to study how customers use our services/ to
   develop them and grow our business, to improve marketing of our business and
   services).
 * To provide customer service, including responding to your enquiries and
   fulfilling any of your requests for information or provision of services:
   Legal bases: performance of a contract with you, our legitimate interests
   (performance of a contract with a third party like your employer, to manage
   our business relationship with you and third parties, to improve our business
   and services, to study how customers use our services/ to develop them and
   grow our business, to improve marketing of our business and services).
 * To send you important information regarding our services and/or other
   technical notices, updates, security alerts, and support and administrative
   messages: Legal bases: to comply with a legal obligation, our legitimate
   interests (to improve our business and services, to keep our Sites updated
   and relevant, to study how customers use our services/ to develop them and
   grow our business, to improve marketing of our business and services).
 * To enable monitoring of behavior and trends that can support us in improving
   our content and services: Legal bases: to comply with a legal obligation, our
   legitimate interests (to improve our business and services, to keep our Sites
   updated and relevant, to study how customers use our services/ to develop
   them and grow our business, to improve marketing of our business and
   services).
 * For monitoring and evaluation of the sales of our services as well as
   marketing actions: Legal bases: your consent, our legitimate interests (to
   improve our business and services, to study how customers use our services/
   to develop them and grow our business, to improve marketing of our business
   and services).
 * To track and monitor usage and performance of our services so that we can
   improve our services and its delivery to you: Legal bases: our legitimate
   interests (to improve our business and services, to study how customers use
   our services/ to develop them and grow our business, to improve marketing of
   our business and services).
 * For marketing purposes, sometimes, at business events, we take situational
   photos which we can then present on our website or on social media: Legal
   bases: your consent, our legitimate interests (to improve our business and
   services, to study how customers use our services/ to develop them and grow
   our business, to improve marketing of our business and services).
 * To perform our contractual obligations to you or a third party (e.g. your
   employer): Legal bases: performance of a contract with you, our and third
   party legitimate interests (performance of a contract with a third party like
   your employer and to manage our business relationship with you and third
   parties).
 * To manage and protect our business and affairs: Legal bases: to comply with a
   legal obligation, our legitimate interests (to operate and manage our
   business, in the context of any purchase or sale of our business or company
   or any business or group restructuring or reorganization, improve our
   business and services, to study how customers use our services/ to develop
   them and grow our business).
 * To buy or sell any business, assets or shares or for our internal business
   and group restructurings: Legal bases: to comply with a legal obligation, our
   legitimate interests (to operate and manage our business, in the context of
   any purchase or sale of our business or company or any business or group
   restructuring or reorganization, improve our business and services, to study
   how customers use our services/ to develop them and grow our business).
 * For marketing purposes to personalize your experience and to allow us to
   deliver the type of content and service offerings in which you are most
   interested: Legal bases: your consent, our legitimate interests (to study how
   customers use our services/ to develop them and grow our business, to improve
   marketing of our business and services).
 * To administer and protect our Sites (including troubleshooting, data
   analysis, testing, system maintenance, support, reporting and hosting of
   data): Legal bases: to comply with a legal obligation, our legitimate
   interests (for provision of administration and online services and network
   security, to prevent fraud, to operate and manage our business, improve our
   business and services, to study how customers use our services/ to develop
   them and grow our business).
 * To deliver relevant Site content and advertisements to you and measure or
   understand the effectiveness of the advertising we serve to you: Legal bases:
   our legitimate interests (for provision of administration and online services
   and network security, to prevent fraud, to perform our contract with a third
   party, to operate and manage our business, improve our business and services,
   to study how customers use our services/ to develop them and grow our
   business, to improve marketing of our business and services).
 * To use data analytics to improve our Sites, services, marketing, customer
   relationships and experiences: Legal bases: to comply with a legal
   obligation, our legitimate interests (for provision of administration and
   online services and network security, to prevent fraud, to operate and manage
   our business, improve our business and services, to study how customers use
   our services/ to develop them and grow our business).
 * To show you relevant advertisements while you are browsing the internet or
   using social media: Legal bases: your consent, our legitimate interests (to
   operate and manage our business, improve our business and services, to study
   how customers use our services/ to develop them and grow our business, to
   improve marketing of our business and services).
 * To process any job application and/or deal with any recruitment process and
   enter into any employment relationship: Legal bases: to take steps at your
   request prior to entering into a contract with you, to comply with a legal
   obligation and our legitimate interests (to assess and evaluate job
   applicants and record our recruitment activities).
 * As we believe to be necessary or appropriate:
   * in order to comply with a legal obligation. This applies where the
     processing is necessary for us to comply with the law, regulations or any
     guidance or direction from any supervisory authority: Legal bases: to
     comply with a legal obligation;
   * to enforce or apply this Privacy Policy: Legal bases: to comply with a
     legal obligation, our legitimate interests (for provision of administration
     and online services and network security, to prevent fraud, to operate and
     manage our business, improve our business and services, to study how
     customers use our services/ to develop them and grow our business); and
   * to protect our legitimate rights, privacy, property or safety, and/or those
     of a third party as long as your rights do not override those interests:
     Legal bases: to comply with a legal obligation, our legitimate interests
     (for provision of administration and online services and network security,
     to prevent fraud, to operate and manage our business, improve our business
     and services, to study how customers use our services/ to develop them and
     grow our business).


8. MARKETING

We may collect your identity and contact details (such as your name, email
address, phone number or address) in order to send you information about our
products and services which you might be interested in. We may collect this
directly from you, or through a third party. If a third party collected your
name and contact details, we will process your professional data based on
legitimate interests to send you a fair processing notice and then respect any
communication preferences you give us.

You always have the right to “opt out” of receiving our marketing. You can
exercise the right at any time by contacting us at info@pentagroup.co. If we
send you any marketing emails, we will always provide an unsubscribe option to
allow you to opt out of any further marketing emails. If you “opt-out” of our
marketing materials, you will be added to our suppression list to ensure we do
not accidentally send you further marketing. Where you unsubscribe from any
postal marketing, you may initially still receive some content which has already
been printed or sent, but we will remove you from any future campaigns. We may
still need to contact you administrative or operational purposes, but we will
make sure that those communications do not include direct marketing.

If you are an existing customer or are acting as a business we use your contact
details as necessary for our legitimate interests in marketing to you and
maintaining a list of potential customers.

We never share your name or contact details with third parties for marketing
purposes. We do use third party service providers to send out our marketing, but
we only allow them to use that information on our instructions and where they
have agreed to treat the information confidentially and to keep it secure.

We retain your details on our marketing list until you “opt-out”, at which point
we add you to our suppression list. We keep that suppression list indefinitely
to comply with our legal obligations to ensure we don’t accidentally send you
any more marketing.


9. RETENTION OF YOUR DATA

When calculating the appropriate retention period for your data, we consider the
nature and sensitivity of the data, the purposes for which we are processing the
data, and any applicable statutory retention periods. Using these criteria, we
regularly review the personal data which we hold and the purposes for which it
is held and processed. Job applicant data is retained for up to one year. Other
types of personal data are retained for up to seven years. After we have ceased
to provide you with services, your data will be processed only for technical
reasons (system integrity, back-ups) while it remains inactive in our systems.

Where we need to retain your personal data to comply with our legal or
contractual obligations, we will retain such personal data for the duration
necessary to comply with such legal or contractual obligations.

We store your personal data as long as you wish to receive marketing content
from us (you have right to withdraw your consent or object processing at any
time) or after seven years if you remain inactive in our marketing
communications.

We retain information collected by a cookie until that cookie expires or is
disabled by you.


10. ACCURACY OF YOUR DATA

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.


11. SECURITY OF YOUR DATA

In order to protect your personal data, we put in place appropriate
organizational and technical security measures. These measures include ensuring
our internal IT systems are suitably secure and implementing procedures to deal
with any suspected data breach.

In the unlikely event of a data breach, we will take steps to mitigate any loss
or destruction of data and, if required by law, will notify you and any
applicable authority of such a breach.

Although we use appropriate security measures once we have received your
personal data, you will appreciate that the transmission of data over the
internet (including by e-mail) is never completely secure. We endeavor to
protect personal data, but we cannot guarantee the security of data transmitted
to or by us.


12. TRANSFER OF YOUR DATA TO THIRD PARTIES, INTERNATIONAL TRANSFERS OF PERSONAL
DATA AND SHARING YOUR PERSONAL DATA

Please read this section if you are accessing our services from the UK, the
European Economic Area (the “EEA”) or Switzerland. Our business and that of the
third parties we use to deliver our services to you is international in nature.
The Penta entities operate from a number of locations around the world.
Consequently, Penta entities may transfer data between them to ensure the most
efficient data processing. However, Penta entities will comply by national and
other regulation and ensure adequate and appropriate technical, organizational
and legal safeguards for international data transfers. If we transfer data to
countries or organisations outside of the UK, the EEA or Switzerland which the
EU or the UK do not consider to have an adequate data protection regime in
place, we will ensure that appropriate safeguards (for example, standard
contractual clauses approved by the EU, UK or a data protection authority) are
put in place where required. If you would like more information regarding the
safeguards we put in place for international data transfers from the UK, EEA or
Switzerland please contact us at info@pentagroup.co.

Our business and operations (including data servers) are primarily based in the
United States of America (the “USA”). When you access our services and provide
us with your personal details (by logging in on-line), you will in effect be
providing us your personal data for processing in the USA.

Your personal data is shared with third party service providers who process the
information on our behalf so that we can provide our services to you. Our third
party providers may use their own subcontractors who may be given access to your
personal data in order to provide our services to you. Our main third party
providers are located outside of the UK, EEA and Switzerland and therefore your
personal data will be transferred to countries outside of the UK, EEA and
Switzerland. 

We may share your personal data with other third parties, for example in the
context of the possible sale or restructuring of the business where necessary in
connection with the purposes which your information was collected for. We may
also need to share your personal data with a regulator or to otherwise comply
with the law.


13. THIRD PARTY LINKS

Our Sites contain links to and from other applications, plug-ins and websites of
other networks, advertisers and affiliates. If you follow a link to any of these
websites, please note that they (and any services that may be accessible through
them) have their own privacy policies and, unless we have expressly agreed
otherwise with you, we do not accept any responsibility or liability for the
content of these applications or websites or their policies or for any personal
data that may be collected through these applications, websites or services. We
encourage you to read these privacy policies before you submit any personal data
to these applications or websites or use such services.

Please note you have the opportunity to participate in discussions on social
media platforms administered by us. The goal of these social media platforms is
to enable you to share content. We are not responsible if you share data and
personal information on social media platforms and then this information is used
or misappropriated by other users on the relevant platform. Any disclosures made
on a social media platform will be governed by the privacy policy and terms of
use of that platform.


14. YOUR RIGHTS – UNITED KINGDOM, EUROPEAN ECONOMIC AREA (EEA) AND SWITZERLAND

If you are located in the UK, the EEA or Switzerland, you have certain rights in
relation to the personal data we process and hold about you. These rights are:

 * Right of access: you have the right to request access to personal data that
   we may process about you.
 * Right to rectification: you have the right to require us to correct any
   inaccuracies in your personal data.
 * Right to erasure: you have the right to require us to delete your personal
   data, subject to certain legal requirements.
 * Right to restriction of processing: you have the right to require us to
   restrict the way in which we process your personal data. You may wish to
   restrict processing if, for example:
   * you contest the accuracy of the data and wish to have it corrected; or
   * you would prefer restriction to erasure.
 * Right to object to processing: you have the right to object to our processing
   of your personal data.
 * Right to data portability: you have the right to obtain from us the personal
   data we hold on you.
 * Right to withdraw consent: where we have relied upon your consent to process
   your personal data, you have the right at any time to withdraw your consent.
 * Right to lodge a complaint with a supervisory authority: you have the right
   to complain to a supervisory authority (the Information Commissioner’s Office
   is the relevant supervisory authority in the UK).

With the exception of lodging a compliant directly with a supervisory authority
(such as the Information Commissioner’s Office), if you are located in the UK,
EEA or Switzerland and would like to contact us to exercise any of the other
rights set out above, please put your request in writing; include proof of your
identity (such as a copy of your driver’s license or passport) and address (such
as a recent utility or credit card bill) and specify the right you wish to
exercise.  We will not use this information for any purpose other than to
authenticate your identity.


15. COOKIES

We employ “cookies” to provide visitors with tailored information to facilitate
your use of the website. A “cookie” is an element of data that a website sends
to a visitor’s browser which, in turn, may store that element on the visitor’s
hard drive or memory. Any cookies sent by us will be marked so that they will be
accessible only by our websites. A visitor may block or delete our cookies from
the hard drive. However, by disabling cookies, certain features and
functionality of our websites may no longer work properly, or at all.


16.AMENDMENTS TO THIS PRIVACY POLICY

We may at any time change, modify, or otherwise update this Privacy Policy
without prior notification, so check this page frequently for updates.

This privacy policy was last updated: September 28, 2022.


17. HOW TO CONTACT US

You should be aware that you have the right to raise any concerns with the
Information Commissioner's Office in relation to how we process your personal
data if you are in the UK or, with your local supervisory authority if you are
anywhere else in the EEA or Switzerland. 

Alternatively, you may also contact us if you have questions or concerns about
this Privacy Policy, our Term of Use, the website or if you wish to update,
correct or delete any information you have provided to us. Please contact us via
info@pentagroup.co or through the details provided below.

805 15th Street NW, Suite 200

Washington, DC 20005

+1 (202) 822-1205 (in the United States)

+44 (0) 203 735 9780 (outside the United States)  

© 2022 Penta Group, LLC

New York City Washington DC San Francisco London

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 * Privacy Policy