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PRIVACY POLICY

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Last updated: August 26th 2021

ON24 Online Privacy Policy

ON24, Inc. and our subsidiaries (collectively, “ON24,” “our,” “us” or “we”)
recognize the importance of privacy.  ON24 is committed to protecting the
personal information of our clients and prospective clients, as well as other
users of our websites and services.

When ON24 collects and processes personal information in order to provide our
services to clients, we will only process such personal information on behalf of
the particular client in order to provide our services to that client.  Our
collection, use, disclosure and other processing of personal information on
behalf of clients is subject to the privacy policy of our respective clients.

Overview

We think transparency is important.  In this overview, we summarize the personal
information we collect and how we use it, which is further explained in our
Privacy Policy below.  Keep in mind that the actual personal information we
collect and how we use it varies depending upon the nature of our relationship
and interactions with you.  Also, in some cases (such as where required by law),
we ask for your consent or give you certain choices prior to collecting or using
certain personal information.

Categories of Personal Information Collected. Generally, we collect the
following types of personal information:

 * Identifiers: includes direct identifiers, such as name, username, account
   name, address, phone number, email address, online identifier, IP address, or
   other similar identifiers.
 * Customer Records: includes personal information, such as name, signature,
   contact information, and payment information, that individuals provide us in
   order to purchase or obtain our products and services.
 * Commercial Information: includes records products or services purchased,
   obtained or considered, or other purchasing or use histories.
 * Usage Data: includes browsing history, clickstream data, search history,
   access logs and other usage data and information regarding an individual’s
   interaction with our websites and services, and our marketing emails and
   online ads.
 * Geolocation Data: includes precise location information about a particular
   individual or device.
 * Audio, Video and Electronic Data: includes audio, electronic, visual,
   thermal, olfactory, or similar information, such as CCTV footage (e.g.,
   collected from visitors to our offices) and call recordings (e.g., of
   customer support calls).
 * Professional Information: includes professional and employment-related
   information, such as current and former employer(s) and position(s) and
   business contact information.
 * Protected Classifications: includes characteristics of protected
   classifications under applicable laws, such as disability information and
   medical conditions provided by you when you register for events and other
   activities.
 * Inferences: includes inferences drawn from other personal information that we
   collect to create a profile reflecting an individual’s preferences, behavior
   or other characteristics. For example, we may analyze personal information in
   order to identify the offers and information that may be most relevant to
   clients, so that we can better reach them with relevant offers and ads.

Use of Personal Information.  In general, we may use and disclose the personal
information we collect for the following business and commercial purposes:

/

 * Operating Site and services and providing related support
 * Responding to requests
 * Analyzing and improving the Site, our services, and our business
 * Personalizing experiences
 * Advertising and marketing
 * Protecting our legal rights and preventing misuse
 * Complying with legal obligations
 * Related to our general business operations

If you are a California resident, please be sure to review the section
“Additional Information for Individuals in Certain Jurisdictions” below for
important information about our privacy practices and your rights under
California privacy laws, including your right to submit a “Do Not Sell My Info”
request.

You can review more detailed information about our privacy practices and your
rights and choices below in our Privacy Policy, which is organized into the
following sections:

 * Introduction and Scope
 * Controller and Responsible Party
 * Information We Collect
 * Purposes and Legal Bases of Use
 * Disclosures of Personal Information
 * Cookies and Similar Devices
 * Interest-Based Advertising
 * International Transfers
 * Protection of Children’s Personal Information
 * Security
 * Your Choices and Rights
 * Retention
 * Changes to the Policy
 * Contact Us
 * Additional Information for Individuals in Certain Jurisdictions

Introduction and Scope

This ON24 Online Privacy Policy (“Policy”) explains how we process information
that we collect from users of our website at www.on24.com and the services
available on our website (together, the “Site”), as well as from our former,
current and prospective clients and other individuals that access the Site, or
communicate or engage with us about our products and services.   This Policy
should be read in conjunction with the ON24 Terms of Use located on our website,
which are incorporated herein by reference.

Personal Information. In this Policy, our use of the term “personal information”
includes other similar terms under applicable privacy laws—such as “personal
data” and “personally identifiable information.”  In general, personal
information includes any information that identifies, relates to, describes, or
is reasonably capable of being associated, or reasonably linked or linkable with
a particular individual.

Not Covered by Policy.  This Policy does not apply to the Platform content or
personal information that our clients collect, submit, manage, create, or record
via the Platform, or the personal information we collect, access, store, use or
otherwise process (collectively, “process”) via the Platform registrants,
participants and other end users of client events (the “Platform Data”). Please
see the ON24 Digital Experience Platform Privacy Policy for information about
our processing of Platform Data and for the definition of “Platform.”  As set
out in the ON24 Digital Experience Platform Privacy Policy, ON24 is a processor
of the Platform Data; we only use the personal information that we process as
part of the Platform Data subject to our agreements with clients and their
written instructions, or where otherwise required by law. This Policy also does
not apply to job applicants and candidates who apply for employment through our
job application portal, or to employees and non-employee workers, whose personal
information is subject to different privacy notices.

Controller and Responsible Party

For the purposes of the EU General Data Protection Regulation (the “GDPR”) and
other relevant applicable laws (such as the UK Data Protection Act 2018 (“UK
DPA”) and the Brazilian General Data Protection Law (the “LGPD”)), ON24 is the
controller of your personal information collected pursuant to this Policy.  With
respect to any Platform Data, our clients are the data controllers or businesses
for their respective Platform Data, and we are a data processor or service
provide, as defined under applicable privacy laws.

Information We Collect 

The personal information that we collect and process will vary depending upon
the circumstances.  You do not have to provide us with your personal information
to access much of the Site. If you choose not to disclose certain information,
you can still visit our Site, but you will not be able to create an account with
us, you may be unable to access certain options and services, and we may be
unable to fully respond to your inquiries.

Information Collected Directly. We may collect personal information about you
directly from you or from your company.   For example, when you fill out a
‘Contact Us’ form, signup for our mailing lists, register for events we host or
sponsor, or otherwise provide us information through the Site, we may collect
personal information such as:

 * Name, company name, and title/position
 * Payment and billing information
 * Email address, phone number, mailing address and contact details
 * Job title, other company information (such as country and industry sector)
 * Contact preferences and interests
 * Business affiliations
 * Customer (and authorized user) account information (to access various parts
   of the Platform, and to create events and webinars) – name, email address,
   telephone number, company name, and other information necessary to confirm
   that you are an authorized user of a client (where relevant)
 * Other information related to your request or inquiry

Automatically-Collected Information. We use cookies, log files, pixel tags,
local storage objects, and other tracking technologies to automatically collect
information when users access or use the services or visit the Site, such as IP
address, general location information, domain name, page views, a date/time
stamp, browser type, device type, device ID, Internet service provider,
referring/exit URLs, operating system, language, clickstream data, and other
information about the links clicked, features used, size of files uploaded,
streamed or deleted, and similar device and usage information.  For more
information, see the Cookies and Similar Devices section below.

Information Collected from Third Parties.  We may collect personal information
about you from third party sources, such as business partners, social media
platforms, public sources, joint marketing partners, our resellers (so that we
can deliver our Platform and related services) and third parties to whom you
have expressed interest in our products and services, as well as information
that you shared on social media platforms (subject to the respective platform
terms and applicable laws).

Purposes and Legal Bases of Use

Certain laws, including the GDPR, require that we inform you of the legal bases
for our processing of your personal information.  Pursuant to the GDPR (and
other similar laws), we process personal information for the following legal
bases:

 * Performance of contract: as necessary to enter into or carry out the
   performance of our contract with you.
 * Compliance with laws: for compliance with legal obligations and/or defense
   against legal claims, including those in the area of labor and employment
   law, social security, and data protection, tax, and corporate compliance
   laws.
 * Our legitimate interests: in furtherance of our legitimate business
   interests, which are not overridden by your interests and fundamental rights,
   including:
   * Performance of contracts with clients and other parties
   * Implementation and operation of global support (e.g., IT) services for our
     business operations
   * Improving our Site, developing trend and benchmark reports, and similar
     purposes
   * Customer relationship management and improving our Site and Services,
     including other forms of marketing and analytics
   * Fraud detection and prevention, including misuse of Services or money
     laundering
   * Physical, IT, and network perimeter security
   * Internal investigations
   * Mergers, acquisitions, and reorganization, and other business transactions
 * With your consent: where we have your consent the GDPR (where it applies) and
   other applicable laws give you the right to withdraw your consent, which you
   can do this at any time by contacting us using the details at the end of this
   privacy notice. In some jurisdictions, your use of the services may be taken
   as implied consent to the collection and processing of personal information
   as outlined in this privacy notice.

In addition, we may process your personal information where necessary to protect
the vital interests of any individual.

Purposes for Using Personal Information. The purposes for which we may process
personal information will vary depending upon the circumstances. In general, we
use personal information for the business and commercial purposes set forth
below, and where the GDPR or other relevant laws apply, we have set forth the
legal bases for such processing in parenthesis (see above for further
explanation of our legal bases):

 * Operating Site and services and providing related support: to provide and
   operate the Site and services, communicate with you about your use of the
   Site and our services, provide troubleshooting and technical support, respond
   to your inquiries, fulfill your orders and requests, process your payments,
   communicate with you, and for similar service and support purposes. (Legal
   bases: performance of our contract with you; and/or our legitimate interests)
 * Responding to requests: to respond to your inquiries and requests and
   consider your request or application. (Legal basis: performance of our
   contract with you)
 * Analyzing and improving the Site, our services, and our business: to better
   understand how users access and use the Site and our services, as well as
   other products and offerings, both on an aggregated and individualized basis,
   to administer, monitor, and improve our services, for our internal purposes,
   and for other research and analytical purposes. (Legal basis: our legitimate
   interests)
 * Personalizing experiences: to tailor content we may send or display on the
   Site, including to offer location customization and personalized help and
   instructions, and to otherwise personalize your experiences. (Legal basis:
   our legitimate interests)
 * Advertising and marketing: to promote ON24’s products and services on
   third-party websites, as well as for direct marketing purposes, including to
   send you newsletters, client alerts and information we think may interest
   you. If you are located in a jurisdiction that requires opt-in consent to
   receive electronic marketing messages, we will only send you such messages if
   you opt-in to receive them.  (Legal bases: our legitimate interests; and/or
   with your consent)
 * Protecting our legal rights and preventing misuse: to protect the Site and
   our business operations; to prevent, detect and investigate fraud, misuse,
   harassment or other types of unlawful activities; where we believe necessary
   to investigate, prevent or take action regarding illegal activities,
   suspected fraud, situations involving potential threats to the safety or
   legal rights of any person or third party, or violations of this Policy and
   our applicable terms of service and agreements. (Legal bases: our legitimate
   interests; and/or compliance with laws)
 * Complying with legal obligations: to comply with the law or legal
   proceedings. For example, we may disclose information in response to
   subpoenas, court order, and other lawful requests by regulators and law
   enforcement, including responding to national security or law enforcement
   disclosure requirements. (Legal bases: our legitimate interests; and/or
   compliance with laws)
 * Related to our general business operations: to consider and implement
   mergers, acquisitions, reorganizations, and other business transactions, and
   where necessary to the administration of our general business, accounting,
   recordkeeping and legal functions. (Legal bases: our legitimate interests;
   and/or compliance with laws)

Aggregate, De-identified or Anonymous Data. We also create and use aggregate,
anonymous and de-identified data to assess, improve and develop our business,
products and services, and for similar research and analytics purposes.  This
information is not generally subject to the restrictions in this Policy,
provided it does not identify and could not be used to identify a particular
individual.

Disclosures of Personal Information

In general, we disclose the personal information we collect for the business and
commercial purposes explained below:

 * Subsidiaries: to our subsidiaries, whose handling of your personal
   information is subject to this Policy.  A list of our subsidiaries is
   available here.
 * Enterprise users: if you use, access or communicate with us about our
   Platform or related services on behalf of your company (our client), we may
   share personal information about your access, and your communications or
   requests, with the relevant enterprise client.
 * Service providers: to third party service providers who perform functions on
   our behalf. Third party service providers will only process your personal
   information in accordance with our instructions and will implement adequate
   security measures to protect your personal information.
 * Advertising and analytics partners: to third parties we engage to provide
   advertising, campaign measurement, online and mobile analytics, and related
   services to us (with your consent, where required by applicable laws).
 * In response to legal process: in order to comply with the law, judicial
   proceedings, a court order, or other legal process, such as in response to a
   subpoena.
 * To protect our rights: where we believe it is necessary to investigate,
   prevent or take action regarding illegal activities, suspected fraud,
   situations involving potential threats to the safety of any person,
   violations of the ON24 Terms of Use or this Policy, to respond to claims
   asserted against us or, or as evidence in litigation in which we are
   involved.
 * Business transfers: as part of any merger, sale, and transfer of our assets,
   acquisition or restructuring of all or part of our business, bankruptcy, or
   similar event, including related to due diligence conducted prior to such
   event where permitted by law.

Aggregate, De-identified or Anonymous data. We may share aggregate, anonymous or
de-identified data with third parties for research, marketing, analytics and
other purposes, provided such information does not identify a particular
individual.

Cookies and Similar Devices

We and our third party service providers use “cookies,” pixels, java script, log
files, and other mechanisms on the Site. For more detailed information about the
use of cookies on the Site and how you can manage your cookie preferences, you
can review our Cookie Policy found here.

Cookies. A “cookie” is a small text file that may be used, for example, to
collect information about website activity. Some cookies allow us to make it
easier for you to navigate the Site, while others are used to enable a faster
log-in process or to allow us to track your activities while using the Site. 
Most browsers allow you to control cookies, including whether or not to accept
them, and how to remove them.  See our Cookie Policy for more information.

Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with
a unique identifier, similar in function to cookies. In contrast to cookies,
which are stored on your computer’s hard drive, clear GIFs are embedded
invisibly on web pages. We may use clear GIFs (also referred to as web beacons,
web bugs or pixel tags), in connection with our services to, among other things,
track the activities users of our services, help us manage content, and compile
statistics about usage of our services. We and our third party service providers
also use clear GIFs in HTML emails to our customers, to help us track email
response rates, identify when our emails are viewed, and track whether our
emails are forwarded.

Log Files. Most browsers collect certain information, such as your IP address,
device type, screen resolution, operating system version, and internet browser
type and version. This information is gathered automatically and stored in log
files.

Third-Party Analytics. We also use automated devices and applications, such as
Google Analytics (more info here) to evaluate use of our Services. We use these
tools to gather non-personal information about users to help us improve our Site
and services, as well as user experiences. These analytics providers may use
cookies and other technologies to perform their services and may combine the
information they collect about you on the Site with other information they have
collected for their own purposes. This Policy does not cover such uses of data
by third parties.

Do-Not-Track Signals. The Site does not respond to do-not-track signals. You
may, however, disable certain tracking as discussed above (e.g., by disabling
cookies) and set out in our Cookie Policy.  You many also use our preference
manager to manage your cookie preferences on our Site.

Interest-Based Advertising

We work with third party ad networks, analytics companies, measurement services
and others (“third party ad companies”) to manage our advertising on third party
sites, mobile apps and online services. We and these third party ad companies
may use cookies, pixels tags, and other tools to collect activity information on
our Services (as well as on third party sites and services), as well as IP
address, device ID, cookie and advertising IDs, and other identifiers, general
location information, and, with your consent, your device’s geolocation
information; we and these third party ad companies use this information to
provide you more relevant ads and content and to evaluate the success of such
ads and content. In addition, these third parties may combine the information
collected from us and our Sites with information collected about you from
third-party sites, apps, and services, in order to make inferences about you and
your interests, to better tailor advertising and content to you across multiple
sites, apps, and services and to collect associated metrics.

You many also use our preference manager to opt-out of third party advertising
cookies or manage your cookie preferences on our Site. Please note, that your
preferences are applied on a browser and device basis. So, you will need to set
your cookie preferences for each browser and device you use to access our Site.
Further, if you subsequently delete cookies, your preferences may be lost and
need to be reset.

See our Cookie Policy for information on the third parties that we work with,
and how you can opt out of ads from them.  For more information about third
party ad networks and to opt out of interest-based ads from many ad networks go
to:

Canada: www.youradchoices.ca

EU: www.youronlinechoices.eu

U.S.: www.aboutads.info

International Transfers

ON24 is headquartered in the United States and has operations and service
providers in the United States and throughout the world. As such, we and our
service providers may transfer your personal information to, or access it in,
jurisdictions (including the United States, the United Kingdom (“UK”) and the
European Union (“EU”), Australia and Singapore) that may not provide equivalent
levels of data protection as your home jurisdiction. We will take steps to
ensure that your personal information receives an adequate level of protection
in the jurisdictions in which we process it, including through appropriate
written data processing terms and/or data transfer agreements.

If you are in the European Economic Area (“EEA”), and we process your personal
information in a jurisdiction that the European Commission has deemed to not
provide an adequate level of data protection (a “third country”), we will
implement measures to adequately protect your personal information, such as
putting in place standard contractual clauses approved by the European
Commission or another measure that has been approved by the EU Commission as
adducing adequate safeguards for the protection of personal information when
transferred to a third country.   You have a right to obtain details of the
mechanism under which your personal information is transferred outside of the
EEA; you may request such details by contacting us as set forth in the Contact
Us section below.

Protection of Children’s Personal Information

ON24 does not publish content that is targeted at children. The Site is not
intended for minors under the age 16. We do not knowingly or specifically
collect information about minors under the age of 16. If you believe we have
unintentionally collected such information, please notify us as set out in
the Contact Us section below.

Security

Wherever your personal information may be held within ON24 or on its behalf, we
take reasonable steps to protect the personal information that you share with us
from unauthorized access or disclosure, including, without limitation,
restricting access to certain portions of our website through access controls,
and using firewalls. Regardless of the precautions taken by us, ON24 cannot
ensure or warrant the security of any information you transmit to us, and you
transmit such information at your own risk. You are responsible for all actions
taken with your User ID and password, if any. Therefore, we recommend that you
do not disclose your password to anyone. If you lose control of your password,
you may lose substantial control over your personally identifiable information
and may be subject to legally binding actions taken on your behalf.

Your Choices and Rights

Access, Amend and Correct. If you wish to access personal information that you
have submitted to us, to request the correction of any inaccurate information
you have submitted to us, or to request deletion of your information, please
send your request to dsr@on24.com.  We will review your request and make
reasonable efforts to respond to it as soon as practicable. We may ask you for
additional information so that we can confirm your identity.

Direct Marketing. You may always opt-out of direct marketing emails. If you
would like to unsubscribe from ON24 email subscriptions or otherwise change your
email preferences with ON24, please click here or follow the instructions in any
ON24 promotional email that we send to you. We may continue to send you
transactional or service-related communications, such as service announcements
and administrative messages.

Complaints. We will take steps to try to resolve any complaint you raise
regarding our treatment of your personal information.  You also have the right
to raise a complaint with the privacy regulator in your jurisdiction.

Additional Information for Certain Jurisdictions. In the section “Additional
Information for Individuals in Certain Jurisdictions” below, we provide
additional information as required under California privacy laws, as well as the
GDPR, UK DPA and the LGPD.  Users in California, the EEA, the UK, and Brazil
should review this section for more information regarding their rights under
these respective laws.

Retention

As a general rule, we retain your personal information for as long as necessary
to fulfill the purposes for which it was collected or as necessary to comply
with our legal obligations, resolve disputes, maintain appropriate business
records, and enforce our agreements.  In general, for example, we will retain
relevant contact information of clients, prospective clients and Site visitors
for three years from the date of our last interaction with you and in compliance
with our obligations under applicable laws.  Our clients instruct us on how long
to retain Client Data, which we handle as a data processor.  We may retain
personal information for longer where required by our regulatory obligations,
professional indemnity obligations, or where we believe necessary to establish,
defend, or protect our legal rights and interests or those of others.

Changes to the Policy

ON24 may update this Policy to reflect new or different privacy practices or to
reflect changes in industry standards or legal requirements. Revisions will be
posted on our website. This statement of privacy is for the information of our
users and does not constitute a contract or modification of any contract. When
changes are made to this Policy, ON24 will post a new version of this
Policy here. If the changes will materially affect the way we use or disclose
your personal information, we will endeavor to notify you in advance of the
change, such as by sending a notice to the primary email address associated with
your account or by posting a notice on the Site. We encourage you to
periodically review this Policy for the latest information on our privacy
practices.

Contact Us

ON24 welcomes your comments regarding this Policy. Please feel free to email us
at privacy@on24.com or via postal mail at ON24, Attn: Privacy, 50 Beale Street,
8th Floor, San Francisco, CA 94105.

EU Representative.  If you are in the European Union, you may address privacy
related enquiries to our EU representative, pursuant to Article 27 GDPR, by
emailing on24@datarep.com, or via postal mail at DataRep, Calle de Manzanares 4,
Madrid, 28005, Spain.

Additional Information for Individuals in Certain Jurisdictions

California Residents

In this section, we provide additional information for California residents
about how we handle their personal information, as required under California
privacy laws, including the California Consumer Privacy Act (“CCPA”). This
section does not address or apply to our handling of publicly available
information lawfully made available by state or federal government records or
other personal information that is exempt under the CCPA.

 1. Categories of Personal Information Under the CCPA

While our collection, use and disclosure of personal information varies based
upon our relationship and interactions with you, in this section we describe,
generally, how we have collected and disclosed personal information about
consumers in the prior 12 months.

Categories of Personal Information Collected and Disclosed. The table below
identifies the categories of personal information (as defined by the CCPA) we
have collected about consumers, as well as how we have disclosed such
information for a business purpose. For more information about the business and
commercial purposes for which we collect, use and disclose personal information,
please see the Purposes and Legal Bases and the Disclosures of Personal
Information sections above.

Personal Information Collected May We Disclose this Information? Categories of
Third Parties Categories Description Identifiers includes direct identifiers,
such as name, username, account name, address, phone number, email address,
online identifier, IP address, or other similar identifiers. Yes •  service
providers



•  advisors and agents

•  government entities and law enforcement

•  affiliates and subsidiaries

•  advertising networks

•  data analytics providers

•  social networks

•  internet service providers

•  operating systems and platforms

•  enterprise clients

Customer Records includes personal information, such as name, signature, contact
information, and payment information, that individuals provide us in order to
purchase or obtain our products and services. Yes •  service providers



•  advisors and agents

•  government entities and law enforcement

•  affiliates and subsidiaries

•  operating systems and platforms

•  enterprise clients

Commercial Information includes records products or services purchased, obtained
or considered, or other purchasing or use histories. Yes •  service providers



•  advisors and agents

•  government entities and law enforcement

•  affiliates and subsidiaries

•  advertising networks

•  data analytics providers

•  social networks

•  operating systems and platforms

•  enterprise clients

Usage Data includes browsing history, clickstream data, search history, access
logs and other usage data and information regarding an individual’s interaction
with our websites and Services, and our marketing emails and online ads. Yes • 
service providers



•  advisors and agents

•  government entities and law enforcement

•  affiliates and subsidiaries

•  advertising networks

•  data analytics providers

•  social networks

•  internet service providers

•  operating systems and platforms

•  enterprise clients

Geolocation Data includes precise location information about a particular
individual or device. Yes •  service providers



•  advisors and agents

•  government entities and law enforcement

•  affiliates and subsidiaries

Audio, Video and Electronic Data includes audio, electronic, visual, thermal,
olfactory, or similar information, such as CCTV footage (e.g., collected from
visitors to our offices) and call recordings (e.g., of customer support calls).
Yes •  service providers



•  advisors and agents

•  government entities and law enforcement

•  affiliates and subsidiaries

•  operating systems and platforms

•  enterprise clients

Professional Information includes professional and employment-related
information, such as current and former employer(s) and position(s) and business
contact information. Yes •  service providers



•  advisors and agents

•  government entities and law enforcement

•  our affiliates and subsidiaries

•  enterprise clients

Protected Classifications includes characteristics of protected classifications
under applicable laws, such as disability information and medical conditions
provided by you when you register for events and other activities. Yes • 
service providers



•  advisors and agents

•  government entities and law enforcement

•  our affiliates and subsidiaries

Inferences includes inferences drawn from other personal information that we
collect to create a profile reflecting an individual’s preferences, behavior or
other characteristics. For example, we may analyze personal information in order
to identify the offers and information that may be most relevant to customers,
so that we can better reach them with relevant offers and ads. Yes •  service
providers



•  advisors and agents

•  government entities and law enforcement

•  our affiliates and subsidiaries

 

Do We “Sell” Personal Information? Under the CCPA, a “sale” includes disclosing
or making available personal information to a third-party in exchange for
monetary compensation or other benefits or value. While we do not disclose
personal information to third parties in exchange for monetary compensation, we
may disclose or make available certain categories of personal information to
third parties in order to receive certain benefits or services, such as when we
make browsing information available to third party ad companies (through third
party tags on our Sites) in order to improve and measure our ad campaigns and
reach users with more relevant ads and content. As defined by the CCPA, we may
“sell” Usage Data and Identifiers to third party advertising networks, social
networks and data analytics providers.

Sources of Personal Information. As further described in the “Information We
Collect” section above, we may collect personal information from the following
sources:

 * Our enterprise customers
 * Directly from the individual
 * Advertising networks
 * Data analytics providers
 * Social networks
 * Internet service providers
 * Operating systems and platforms
 * Publicly available sources
   1. California Residents’ Rights

CCPA Rights. In general, California residents have the following rights with
respect to their personal information:

 * Do-not-sell (opt-out): to opt-out of our sale of their personal information.
   While we may “sell” personal information as defined by the CCPA, we do not
   sell personal information about California consumers who we know are younger
   than 16 years old. California residents may opt out of sales of their
   personal information by us, by using our preference manager.
 * Right of deletion: to request deletion of their personal information that we
   have collected about them and to have such personal information deleted
   (without charge), subject to certain exceptions.
 * Right to know: with respect to the personal information we have collected
   about them in the prior 12 months, to require that we disclose the following
   to them (up to twice per year and subject to certain exemptions):
   * categories of personal information collected;
   * categories of sources of personal information;
   * categories of personal information about them we have disclosed for a
     business purpose or sold;
   * categories of third parties to whom we have sold or disclosed for a
     business purpose their personal information;
   * the business or commercial purposes for collecting or selling their
     personal information; and
   * a copy of the specific pieces of personal information we have collected
     about them.
 * Right to non-discrimination: the right not to be subject to discriminatory
   treatment for exercising their rights under the CCPA.

Submitting Verifiable Requests. Requests to Know and Requests to Delete may be
submitted:

 * Online at www.on24.com/ccpa-submit-data-request
 * By email at dsr@on24.com

When you submit a request to know or a request to delete, we will take steps to
verify your request by matching the information provided by you with the
information we have in our records.  You must complete all required fields on
our webform (or otherwise provide us with this information via the above
toll-free number) and verify your email address.  In some cases, we may request
additional information in order to verify your request or where necessary to
process your request. If we are unable to adequately verify a request, we will
notify the requestor.  Authorized agents may initiate a request on behalf of
another individual by contacting us as set forth in the Contact Us section
above; authorized agents will be required to provide proof of their
authorization and we may also require that the relevant consumer directly verify
their identity and the authority of the authorized agent.

For more information about our privacy practices, you may contact us as set
forth in the Contact Us section above.

Individuals in the European Union / European Economic Area / Brazil

Below, we inform about other rights, including the GDPR, the LGPD and similar
applicable laws, that may apply to you. Subject to the conditions set out in the
applicable law, individuals in in the EU/EEA, UK, and Brazil have the following
rights regards our processing of their personal information:

 * Right of access: You can ask us to: confirm whether we are processing your
   personal information; give you a copy of that information; provide you with
   other information about your personal information such as what data we have,
   what we use it for, who we disclose it to, whether we transfer it abroad and
   how we protect it, how long we keep it for, what rights you have, how you can
   make a complaint, where we got your information from and whether we have
   carried out any profiling, to the extent that such information has not
   already been provided to you in this Policy.

 * Right to rectify and complete personal information: You can ask us to rectify
   inaccurate information. We may seek to verify the accuracy of the data before
   rectifying it.

 * Right of erasure: You can ask us to erase your personal information, but only
   where: it is no longer needed for the purposes for which it was collected;
   you have withdrawn your consent (where the data processing was based on
   consent); following a successful right to object (see ‘Objection’ below); it
   has been processed unlawfully; or to comply with a legal obligation to which
   we are subject. We are not required to comply with your request to erase your
   personal information if the processing of your personal information is
   necessary: for compliance with a legal obligation; or for the establishment,
   exercise or defense of legal claims. There are certain other circumstances in
   which we are not required to comply with your erasure request, although these
   two are the most likely circumstances in which we would deny that request.
   Brazilian users may also request the anonymization, blocking or erasure of:
   unnecessary or excessive personal information, or personal information
   processed in violation of the LGPD.

 * Right of restriction: You can ask us to restrict (i.e. keep but not use) your
   personal information, but only where: its accuracy is contested, to allow us
   to verify its accuracy; the processing is unlawful, but you do not want it
   erased; it is no longer needed for the purposes for which it was collected,
   but we still need it to establish, exercise or defend legal claims; you have
   exercised the right to object, and verification of overriding grounds is
   pending. We can continue to use your personal information following a request
   for restriction, where: we have your consent; to establish, exercise or
   defend legal claims; or to protect the rights of another natural or legal
   person.

 * Right to object to our use of your personal information for direct marketing
   purposes: You can request that we change the manner in which we contact you
   for marketing purposes. You can request that we not transfer your personal
   information to unaffiliated third parties for the purposes of direct
   marketing or any other purposes.
 * Right to object for other purposes: You have the right to object at any time
   to any processing of your personal information which has our legitimate
   interests as its legal basis. You may exercise this right without incurring
   any costs. If you raise an objection, we have an opportunity to demonstrate
   that we have compelling legitimate interests which override your rights and
   freedoms. The right to object does not exist, in particular, if the
   processing of your personal information is necessary to take steps prior to
   entering into a contract or to perform a contract already concluded.
 * Right not to be subject to automated decision-making: You have the right not
   to be subject to a decision when it is based on automatic processing if it
   produces a legal effect or similarly significantly affects you, unless it is
   necessary for entering into or performing a contract between us. Brazilian
   users may also request the revision of any decision made solely on the basis
   of automatic processing, to the extent such decision affects your interests. 
   We do not engage in automated decision-making.
 * Right to (data) portability: You can ask us to provide your personal
   information to you in a structured, commonly used, machine-readable format,
   or you can ask to have it ‘ported’ directly to another Data Controller, but
   only where our processing is based on your consent and the processing is
   carried out by automated means.

 * Right to withdraw consent: You can withdraw your consent in respect of any
   processing of personal information which is based upon a consent which you
   have previously provided.

 * Right to obtain a copy of safeguards: you can ask to obtain a copy of, or
   reference to, the safeguards under which your personal information is
   transferred outside the EU/EEA. We may redact data transfer agreements to
   protect commercial terms.

 * Right to lodge a complaint with your local supervisory authority: You have a
   right to lodge a complaint with your local supervisory authority if you have
   concerns about how we are processing your personal information. We ask that
   you please attempt to resolve any issue with us first, although you have a
   right to contact your supervisory authority at any time.

Submitting a GDPR or LGPD Request. Please contact us as set out in the Contact
Us section above to exercise one of these rights.  If we receive any requests
from individuals related to the Platform Data, we will forward the request to
the relevant clients.



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