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Privacy Policy Privacy Notice for California Residents Fair Processing Notice


PRIVACY POLICY LAST UPDATED: 9TH DECEMBER 2021


1. INTRODUCTION

At Selling Simplified Group, Inc. (Reg. No. 27-4882798) (“SSG”), we take your
privacy seriously. This Privacy Notice (this “Notice”) states our policy and
practices regarding the collection and use of personal data you submit to us, or
which we collect via various channels (including our websites; through written
correspondence, including e-mail; or through any of our offices or websites
globally). When we refer to SSG, “we”, “us” or “our” we mean our entire company,
including our divisions, subsidiaries and affiliates.

Through this Notice we aim to inform you about the types of personal data we
collect, the purposes for which we use the data and the ways in which the data
is handled. We also aim to satisfy the obligation of transparency (and the
equivalent under applicable data protection laws) under the EU General Data
Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR.

Please read this Notice carefully to understand our policies and practices
regarding your data and how we will treat it. If you do not agree with our
policies and practices, your choice is not to use our websites or services. By
accessing or using our websites, you agree to this Notice, subject to your
rights as provided by this Notice or applicable law. This Notice may change from
time to time (see Section 16: “Changes to Our Notice”).


2. THE DATA WE COLLECT

Generally, we collect personal data from two groups of people: our marketing
customers and our subscribers. “Personal data” means information that personally
identifies someone or that relates to an identified or identifiable person.

i. Business Customer Data – When we enter into a relationship with our business
customers, we will collect the personal data that we need to provide our
services to them, including name; business contact information, including phone
number, email address, and mailing address; company name; job title; and billing
and transaction information. We may also collect additional information provided
by our customers when they communicate with us.

ii. Subscriber Data – We collect certain data about individuals when they
subscribe to our content, including name; business contact information, such
phone number, email address, and mailing address; company name; and job title.
This information may be publicly available or provided directly to us, such as
by our customers or other third-party providers, as permitted by applicable law.
This data may include potential subscribers or other parties that have
demonstrated an interest in our services or that have registered to attend our
corporate events.


3. HOW WE COLLECT YOUR PERSONAL DATA

i. Through the SSG Websites – Both customers and leads may access our websites
and/or communicate with us. In general, you can visit the SSG websites without
identifying yourself or revealing any personal data. However, you may choose to
provide us with personal data (e.g., via our ‘say hello’ or ‘let’s connect’ web
forms). Within the SSG websites, you can make requests for information, register
to receive materials, and in some cases, order products or services.

ii. From You – You may provide us additional personal data, such as when you
contact us by phone or mail, or when you register for or attend corporate
events. In these cases, we will collect your contact information as well as
information regarding your communications with us.

iii. From Other Sources – We may collect information, including personal data,
from publicly available sources or from other third parties. To the extent that
we collect your personal data from these sources, we will treat it in accordance
with this Notice, and we will honor your rights regarding your personal data as
outlined in this Notice.

iv. Through Your Browser or Device –We also collect certain data automatically
when you use our websites. For more information, see Section 9 “Aggregate
Information About SSG Online Visitors” and Section 10 “Use of Cookies.”


4. HOW WE USE YOUR PERSONAL DATA

The information you provide voluntarily will only be used in connection with
your business relationship with SSG. All personal data will only be processed
and used for lawful and legitimate business purposes specified below.

 * To present our websites and their contents to you;
 * To provide the services, products, or information you request. For example,
   if you fill out our ‘let’s connect’ web form, we will use the information
   provided to contact you about your interest in our services;
 * Respond to your questions and comments and provide customer support;
 * Communicate with you about our products, services, offers, and promotions;
 * To better understand your needs and to provide better service;
 * To plan and host corporate events and to populate online profiles for
   attendees on SSG’s websites;
 * From time to time, to contact you for market research or to provide you with
   marketing information we think would be of particular interest. At a minimum,
   we will always give you the choice to opt-out of receiving such direct
   marketing or market research contact;
 * To carry out our obligations and enforce rights arising from any contracts
   entered into between you and us;
 * To protect against and prevent fraud, unauthorized transactions, claims, and
   other liabilities, and manage risk exposure, including by identifying
   potential hackers and other unauthorized users;
 * To notify you about changes to our websites, products, or services;
 * To comply with applicable legal requirements and industry standards; and
 * Otherwise with your consent or as described to you when you provide the data.


5. THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

This Section 5 is only applicable to you if you are located in the European
Economic Area (“EEA”).

The main grounds that we rely upon in order to process personal data of
customers, leads, other users of our websites, and event attendees are the
following:

i. Necessary for entering into, or performing, a contract – In order to perform
obligations that we undertake in providing a service to you, or in order to take
steps at your request to enter into a contract with us, it will be necessary for
us to process your personal data.

ii. Necessary for compliance with a legal obligation – We are subject to certain
legal requirements which may require us to process your personal data. We may
also be obliged by law to disclose your personal data to a regulatory body or
law enforcement agency.

iii. Necessary for the purposes of legitimate interests - Either we, or a third
party, will need to process your personal data for the purposes of our (or a
third party’s) legitimate interests, provided we have established that those
interests are not overridden by your rights and freedoms, including your right
to have your personal data protected. Our legitimate interests include
responding to requests and inquiries from you or a third party, optimising our
websites and customer experience, our market research, informing you about our
or our customers' products and services, and ensuring that our operations are
conducted in an appropriate and efficient manner. Our legitimate interests also
include the following activities:

(a) building datasets by collecting professionals' contact information from a
variety of sources, including publicly available information, so that we can
market events, products and services, run surveys or research projects on behalf
of our customers and share that collected data with our customers as necessary;

(b) verifying and/or enriching our existing datasets;

(c) sending promotional emails to a carefully selected campaign database of
business contacts on behalf of our customers; and

(d) sharing personal data with our customers in respect of those contacts who
have engaged with the relevant promotional e-mail including by clicking through
to the web content or downloading assets.

iv. Consent – We may also ask for your consent to process your personal data in
a particular way.


6. HOW WE SHARE YOUR PERSONAL DATA

Personal data will be kept confidential but, subject to the provisions of any
applicable law, may be provided to the third parties specified below (“Third
Parties”). Third Parties may be located outside of your jurisdiction and, as a
result, such disclosures may involve the transfer of personal data outside of
your jurisdiction.

i. To SSG affiliates – We may share it with SSG both inside and outside the EEA.
For more information regarding our affiliate locations, please see the “Contact
Us” section below.

ii. To third-party service providers and contractors – We will share your
personal data with trusted third parties where we have retained them to support
our business and who are bound by contractual obligations to keep personal data
confidential and to use it only for the purposes for which we disclose it to
them. To the extent you are located in the EEA and personal data is provided to
third parties outside the EEA, or who will access the information from outside
the EEA, we will use approved frameworks, including, with respect to any
transfers outside of the EEA or access to the information as above, entering
into standard contractual clauses as approved by the European Commission, copies
of which are available here.

iii. To our customers – We may share certain lead information with our customers
in accordance with applicable law to allow our customers to connect with
potential leads for their products or services. We will not share sensitive
personal data with our customers, nor do we share personal data with data
brokers.

iv. As required by law – We may disclose your personal data as required by
applicable law, regulation or as part of a legal process. If we receive a
request from a regulatory body or law enforcement agency, and if permitted under
GDPR and other applicable laws, we may disclose certain personal data to such
bodies or agencies.

v. To new business owners – If we or our business merges with or is acquired by
another business or company, we will share your personal data with the new
owners of the business or company and their advisors, provided that we inform
the buyer it must use your personal data only for the purposes disclosed in this
Notice.

Where we disclose personal data to Third Parties, we do so:

i. To fulfil the purpose for which you provide it.

ii.To carry out our obligations and enforce rights arising from this Notice and
any other contracts entered into between you and us; or

iii. Otherwise with your consent or as described to you when you provide the
data.

We also reserve the right to transfer your personal data to a buyer or other
transferee in the event of a merger, divestiture, restructuring, reorganization,
dissolution, sale, or other transfer of some or all our assets, equity or
similar transaction. Should such a sale, merger, or transfer occur, we will use
reasonable efforts to direct the transferee to use your data in a manner that is
consistent with this Notice.


7. HOW LONG WE WILL HOLD YOUR INFORMATION

Unless otherwise required to do so under applicable law, we will retain your
personal data for the time necessary to provide the services we perform for you
or fulfil the purposes outlined in this Notice, and you can always request that
we stop processing or delete your personal data (if you are located in the EEA).
The next section sets out more information on your rights.


8. YOUR RIGHTS REGARDING THE INFORMATION WE HOLD ABOUT YOU

Depending on where you are located, you have certain rights in relation to
personal data we hold about you. Details of these rights and how to exercise
them are set out below. We will require evidence of your identity before we are
able to act on your request.

i. Right of Access – You have the right at any time to ask us for a copy of the
personal data about you that we hold. Where we have good reason, and as
permitted by law, we can refuse your request for a copy of your personal data,
or certain elements of the request. If we refuse your request or any element of
it, we will provide you with our reasons for doing so. To exercise this right,
please contact us by us using the details in the “Contact Us” section below.

ii. Right of Correction or Completion – If personal data we hold about you is
not accurate, out of date or incomplete, you have a right to have the data
rectified, updated or completed. To exercise this right, please contact us by us
using the details in the “Contact Us” section below.

iii. Right of Erasure – In certain circumstances, you have the right to request
that personal data we hold about you is erased, e.g., if the data is no longer
necessary for the purposes for which it was collected or processed or our
processing of the data is based on your consent and there are no other legal
grounds on which we may process the personal data. To exercise this right,
please contact us by us using the details in the “Contact Us” section below.

iv. Right to Object to or Restrict Processing – In certain circumstances, you
have the right to object to our processing of your personal data, for example,
if we are processing your data on the basis of our legitimate interests and
there are no compelling legitimate grounds for our processing which override
your rights and interests. You also have the right to object to use of your
personal data for direct marketing purposes. You may also have the right to
restrict our use of your personal data, such as in circumstances where you have
challenged the accuracy of the data and during the period where we are verifying
its accuracy. To exercise these rights, please contact us by us using the
details in the “Contact Us” section below.

v. Right of Data Portability – In certain instances, you have a right to receive
any personal data that we hold about you in a structured, commonly used and
machine-readable format. You can ask us to transmit that data to you or directly
to a third-party organisation. This right exists only in respect of personal
data that:

 * you have provided to us previously; and
 * is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee
technical compatibility with a third-party organisation’s systems. We are also
unable to comply with requests that relate to personal data of others without
their consent. To exercise this right of data portability, please contact us by
us using the details in the “Contact Us” section below.

vi. Right to Revoke Consent – To the extent that we are processing your personal
data based on your consent, you have the right to withdraw your consent at any
time. To exercise this right, please contact us by us using the details in the
“Contact Us” section below.

Most of the above rights are subject to limitations and exceptions. We will
provide reasons if we are unable to comply with any request for the exercise of
your right.


9. AGGREGATE INFORMATION ABOUT SSG ONLINE VISITORS

We gather information and statistics collectively about all visitors to our
websites for example:

 * which area users access most frequently,
 * which services users access the most,
 * the type of operating system and browser software,
 * the geographical location of browsers,
 * broad demographic information, and
 * to monitor mouse clicks and movements and scrolling activity.

We only use such data in the aggregate form. The information and statistics we
collect helps us determine what is most beneficial for our users and how we can
continually improve our online services to create a better overall experience
for our users. Although such data may be shared with third parties, such as
advertisers, the underlying data is not shared with anybody else.


10. USE OF COOKIES

We do automatically track certain information about your behaviour while
visiting our webpages. We use this information in order to measure our website’s
performance, user traffic, improve its design and functionality and other
internal management purposes. Most browsers will tell you how to stop accepting
new cookies, how to be notified when you receive a new cookie, and how to
disable existing cookies. Please note, however, that without cookies you may not
be able to take full advantage of our website.

The session cookie is never saved nor written to disk, and the information
contained in the session cookie is only valid for that particular session and is
discarded when the browser is closed. The information we collect in this way
does not identify you personally and you remain anonymous unless you voluntarily
choose to provide SSG with personal data.


11. COMPLAINTS

If you are unhappy about our use of your personal data, you can contact us using
the details in the “Contact Us” section below. You are also entitled to lodge a
complaint with a relevant data protection regulator. The details for the
regulators in the UK and Ireland are as follows:

United Kingdom
Information Commissioner's Office
Telephone: 0303 123 11113
Website: https://ico.org.uk/concerns/

Post:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF



Ireland
Data Protection Commission
Telephone: 076 110 4800
Website: https://www.dataprotection.ie/

Post:

Data Protection Commission
21 Fitzwilliam Square
Dublin 2
D02 RD28
Ireland



You may prefer to lodge a complaint with a different supervisory authority. A
list of relevant authorities in the EEA and the European Free Trade Area can be
accessed here.


12. SECURITY

We have implemented measures designed to secure the information we collect and
store about you and will use our reasonable efforts to protect your personal
data from unauthorised disclosure and/or access including through the use of
network and database security measures, but these cannot guarantee the security
of any data which is collected and stored. We use encryption when collecting or
transferring sensitive data. The safety and security of your information also
depends on you. Where we have given you (or where you have chosen) a password
for access to certain parts of the SSG websites, you are responsible for keeping
this password confidential. We ask you not to share your password with anyone.


13. OTHER WEBSITES

Please note that clicking on links and banner advertisements on our websites can
result in your browser accessing a third-party website, where data privacy
practices are different to that of SSG. These third parties may use cookies
alone or in conjunction with other tracking technologies to collect information
about you, such as your IP address, pages you visit, and when you view a page or
open an email in which a tag is embedded. We do not control these third parties’
tracking technologies or how they may be used. The information practices of
these third parties are governed by their own privacy policies and are not
covered by this Notice. If you have any questions about an advertisement or
other targeted content, you should contact the responsible provider directly.

We are not responsible for, and have no control over, data that is submitted to
or collected by these third parties, and if you have any questions about their
privacy practices, you should consult their privacy policies.


14. INTERNET-BASED TRANSFERS

Given that the Internet is a global environment, using the Internet to collect
and process personal data necessarily involves the transmission of data on an
international basis. Unfortunately, the transmission of data via the Internet is
not completely secure. Although we take commercially reasonable measures to
protect your personal data, we cannot guarantee the security of your data
transmitted to our websites via third party networks. Any transmission is at
your own risk. Once we have received your data, we will use strict procedures
and security features to try to prevent unauthorised access.


15. DO NOT TRACK

Your web browser may let you choose your preference as to whether you want to
allow the collection of information about your online activities over time and
across different websites or online services. At this time, our websites do not
respond to the preferences you may have set in your web browser regarding such
collection of your information, and our websites may continue to collect
information in the manner described in this Notice.


16. CHANGES TO OUR NOTICE

It is our policy to post any changes we make to our Notice on this page. If we
make material changes to how we treat our users' personal data, we will notify
you by email to the primary email address specified in your account or through a
notice on the SSG websites. The date the Notice was last revised is identified
at the top of the page. You are responsible for ensuring we have an up-to-date
active and deliverable email address for you, and for periodically visiting our
websites and this Notice to check for any changes.


17. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may find more information about the rights
available to you in our Privacy Notice for California Residents.


18. HONG KONG PRIVACY RIGHTS

If you are located in Hong Kong, under the Personal Data (Privacy) Ordinance,
you (i) are entitled to make a subject access request (to receive a copy of the
data we process about you); (ii) may exercise your right to correct any data
that is inaccurate; (iii) may object to the use of your personal data for direct
marketing purposes; (iv) may request to be informed of the type of personal data
held by us; and (v) may withdraw consent at any time by written notice.

A reasonable fee may be charged in order for us to comply with your data access
request.

If you wish to request access and/or correct your personal data held by us or
for information regarding our privacy practices, you may contact us using the
details in the “Contact Us” section below.


19. CHILDREN’S INFORMATION

Our services are not directed to, and SSG does not knowingly collect or solicit
personal data from, children under the age of 16 (or the legal minimum age under
the relevant jurisdiction) (“Minimum Age”). If we learn we have collected or
received personal data from a child under the Minimum Age, we will delete that
information. If you believe we might have any information from or about a child
under the Minimum Age, please let us know by contacting us at
privacy@ssgcorp.com


20. CONTACT US

If you have any enquires or if you would like to contact us about our processing
of your personal data, including to exercise your rights as outlined above,
please contact us centrally by any of the methods below. When you contact us, we
will ask you to verify your identity.

Contact name: Privacy Team
Email: privacy@ssgcorp.com
Telephone: +1 (720) 638-8500
Post: 7400 E Orchard Road, Suite 350S, Greenwood Village, CO 80111, USA

Our registered office is at:

Selling Simplified Group Inc.
7400 E Orchard Road,
Suite 350S,
Greenwood Village,
Colorado,
USA
80111


In the European Union, Selling Simplified (Ireland) Limited serves as the
primary data controller. Selling Simplified (Ireland) Limited’s data controller
is registrated with the Irish Data Protection Commissioner is and its address is
Block D, Iveagh Court, Harcourt Road Dublin 2, Dublin, Dublin D02.

In the UK, Selling Simplified Limited’s data controller registration number with
the UK Information Commissioner’s Office is: ZA559047, and its address is: 16
Great Chapel Street, London W1F 8, England, United Kingdom

SSG’s other affiliates are located at the following addresses:

 * Selling Simplified Inc., located at 7400 E Orchard Rd, Suite 350S, Greenwood
   Village, CO 80111, USA
 * Selling Simplified (Singapore) Pte. Ltd., located at 30 Prinsep Street
   #06-01, Singapore, 188647, Singapore
 * Selling Simplified (Auckland) Pte. Ltd., located at DFK Oswin Griffiths
   Carlton Limited, Level 4, 52 Symond Street, Auckland 1010
 * Selling Simplified (Australia) Pty. Ltd., located at Level 3, Suite B, 51
   Walker St, North Sydney, NSW 2060, Australia
 * Selling Simplified India Pvt. Ltd., located at:
   * WeWork Galaxy, 43, Residency Rd, Shanthala Nagar, Ashok Nagar, Bengaluru,
     Karnataka 560025, India
   * Office no. 1, 1st Floor, "Shalini Heights" 312 Shivajinagar ( Bhambhurda)
     Pune Maharashtra- 411005, India
   * WeWork, Berger Tower Delhi One, Office number 19A105, 19th Floor, Sector
     16B, Noida – 201301, India
   * G-92, basement, Kalkaji, New Delhi-110019, India
 * Selling Simplified (Ireland) Ltd., located at Block D, Iveagh Court, Harcourt
   Road Dublin 2, Dublin, Dublin D02
 * Selling Simplified (Hong Kong) Ltd., located at 7/F, Eib Centre, 40-44 Bonham
   Strand, Sheung Wan, Hong Kong
 * Selling Simplified Korea Ltd., located at Ferrum tower 23F, 19 Eulji-ro
   5-gil, Jung-Gu, Seoul, Korea - 04539
 * Selling Simplified Ltd., located at 16 Great Chapel Street, London W1F 8,
   England, United Kingdom
 * Selling Simplified Nippon GK, 11F, KDX Toranomon 1-Chome Building, 1
   Chome−10−5, Toranomon, Minato City, Tokyo 105-0001
 * Selling Simplified (Toronto) Ltd., located at 100 University Ave, Office
   05-115, Toronto ON, M5J 1V6
 * Selling Simplified (Vietnam) Ltd., located at Floor 25, E. Town Central, 11
   Doan Van Bo, Ward 13, District 4 Ho Chi Minh, SG 70000

Selling Simplified insights



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EMEA headquarters Selling Simplified Group
16 Great Chapel Street, London W1F 8, England, United Kingdom


contact us EMEA: +44 (0) 207 566 1000
Email: sales@ssgcorp.com


Copyright © 2022 IDG Communications, Inc.
Privacy Policy | Fair Processing Notice
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