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BRIGHTTALK PRIVACY POLICY

Last Updated April 1, 2022


1. THIS POLICY

This Policy is issued by BrightTALK Inc. (“BrightTALK”) and is addressed to
individuals outside  our organization with whom we interact, including visitors
to our website and other users of our  services (together, “you”). BrightTALK is
a wholly-owned subsidiary of TechTarget, Inc. Defined  terms used in this Policy
are explained in Section (13) below. For the purposes of this Policy,
 BrightTALK is acting solely as the Controller of the Personal Data. Contact
details are provided in  Section (12) below. This Policy may be amended or
updated from time to time to reflect changes in  our practices with respect to
the Processing of Personal Data, or changes in applicable law. We  encourage you
to read this Policy carefully, and to regularly check this page to review any
changes  we might make in accordance with the terms of this Policy.


2. PROCESSING YOUR PERSONAL DATA

Collection of Personal Data: We may collect Personal Data about you as provided
in this Policy.  Examples of sources from which we may collect Personal Data
include the following:

 1. We may obtain your Personal Data when you provide it to us (e.g., where you
    contact us via  email or telephone, or by any other means).
 2. We may collect your Personal Data in the ordinary course of our relationship
    with you (e.g., in  the course of administering your BrightTALK account).
 3. We may collect Personal Data that you manifestly choose to make public,
    including via our  website.
 4. We may receive your Personal Data from third parties who provide it to us
    (e.g., social media  platforms via plugins).
 5. We may collect or obtain Personal Data when you visit our website, or use
    any features or  resources available on or through our website. When you
    visit our website, your device and browser will automatically disclose
    certain information, some of which may constitute Personal Data (see below).

Creation of Personal Data: We may also create Personal Data about you, such as
records of your  interactions using our website, and details of your account
history.

Categories of Personal Data: The categories of Personal Data about you that we
may Process include:

 1. Personal details: given name(s); preferred name; gender; nationality;
    photograph;  preferences; personal photo/image; and account settings.
 2. Contact details: telephone number; email address; mailing address; and
    social media profile  details.
 3. Professional details: professional profile details; association memberships;
    qualifications and  company insight data.
 4. Device details: device type, operating system, browser type, browser
    settings, browsing  information, IP address, language settings, dates and
    times of connecting to our website and  other technical communications
    information.
 5. Payment details: billing address; bank account number or credit card number;
    cardholder or  accountholder name; card or account security details; card
    ‘valid from’ date; card expiry date.
 6. Usage details: records of your use of our website and other services,
    including: registrations;  details of content with which you interact;
    votes; questions; downloads; ratings; feedback;  profile views; search
    queries; anonymous viewings; page views; player clickstream; chapters;  and
    favorite moments.
 7. Analysis data: keywords, communities, trends, content quality and content
    importance.
 8. Views, opinions and interests: any comments, ratings, views or opinions that
    you choose to  send to us, post via our website, via a survey, or publicly
    post via social media platforms;  your community interests and solution
    interests.

Lawful basis for Processing Personal Data: In Processing your Personal Data in
connection with the purposes set out in this Policy, we may rely on one or more
of the following legal bases,  depending on the circumstances:

 1. we have obtained your prior express consent to the Processing (this legal
    basis is only used in  relation to Processing that is entirely voluntary –
    it is not used for Processing that is necessary or obligatory in any way);
 2. the Processing is necessary in connection with any contract that you may
    enter into with us;
 3. the Processing is required by applicable law;
 4. the Processing is necessary to protect the vital interests of any
    individual; or
 5. we have a legitimate interest in carrying out the Processing for the purpose
    of managing, operating or promoting our business, and that legitimate
    interest is not overridden by your  interests, fundamental rights, or
    freedoms.

Processing your Sensitive Personal Data: We do not seek to collect or otherwise
Process your  Sensitive Personal Data, except where:

 1. the Processing is required or permitted by applicable law (e.g., to comply
    with our diversity  reporting obligations);
 2. the Processing is necessary for the detection or prevention of crime
    (including the prevention  of fraud);
 3. the Processing is necessary for the establishment, exercise or defense of
    legal rights; or we have, in accordance with applicable law, obtained your
    prior explicit consent prior to  Processing your Sensitive Personal Data (as
    above, this legal basis is only used in relation to Processing that is
    entirely voluntary – it is not used for Processing that is necessary or
    obligatory in any way).

Purposes for which we may Process your Personal Data: The purposes for which we
may Process  Personal Data, subject to applicable law, include:

 1. Our website: operating and managing our website; providing content to you;
    displaying  advertising and other information to you; and communicating and
    interacting with you via our website.
 2. Provision of services to you: providing our website and other services to
    you (including  suggesting content that may be of interest to you, based on
    your past activity);  communicating with you in relation to those services;
    recommending content that may be of  interest to you; and recommending your
    content to others.
 3. Marketing communications: communicating with you via any means (including
    via email,  telephone, text message, social media, post or in person) news
    items and other information in  which you may be interested, subject to
    ensuring that such communications are provided to  you in compliance with
    applicable law.
 4. Disclosing Personal Data to our clients: in accordance with the provisions
    of this Policy and  applicable law, we may disclose certain Personal Data to
    our clients. Our clients may contact  you with information that may be of
    interest to you, provided that such communication is not  otherwise in
    breach of applicable laws.
 5. Communications and IT operations: management of our communications systems;
    operation  of IT security; and IT security audits.
 6. Health and safety: health and safety assessments and record keeping; and
    compliance with  related legal obligations.
 7. Financial management: sales; finance; corporate audit; and vendor
    management.
 8. Surveys: engaging with you for the purposes of obtaining your views on our
    website or our  services.
 9. Improving our website and our services: identifying issues with existing
    website and our  services; planning improvements to existing website and our
    services; creating new website and our services.


3. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We may disclose your Personal Data to other entities within the BrightTALK
group, in accordance  with applicable law. In addition, we may disclose your
Personal Data to:

 1. our clients, subject always to compliance with the terms of this Policy and
    the requirements  of applicable law;
 2. other users, pursuant to our User Agreement, who may see your profile
    details in your public  profile setting, such as name, job title,
    organization, country, photos, website activity and  history, and comments,
    unless you choose to hide yourself from other users upon viewing a
     particular webcast;
 3. legal and regulatory authorities, upon request, or for the purposes of
    reporting any actual or  suspected breach of applicable law or regulation;
 4. accountants, auditors, lawyers and other outside professional advisors to
    BrightTALK, subject to binding contractual obligations of confidentiality;
 5. third party Processors (such as IT service providers or other third party
    service providers we use for operational purposes), located anywhere in the
    world, subject to the requirements  noted below in this Section (3);
 6. any relevant party, law enforcement agency or court, to the extent necessary
    for the establishment, exercise or defense of legal rights;
 7. any relevant party for the purposes of prevention, investigation, detection
    or prosecution of criminal offences or the execution of criminal penalties,
    including the safeguarding against  and the prevention of threats to public
    security; and
 8. any relevant third party acquirer(s), in the event that we sell or transfer
    all or any relevant  portion of our business or assets (including in the
    event of a reorganization, dissolution or liquidation)

‍

If we engage a third-party Processor to Process your Personal Data, the
Processor will be subject to  binding contractual obligations to: (i) only
Process the Personal Data in accordance with our prior  written instructions;
and (ii) use measures to protect the confidentiality and security of the
Personal  Data; together with any additional requirements under applicable law.


4. TRANSFER OF PERSONAL DATA

We may disclose your Personal Data to other entities within the BrightTALK group
website, in  accordance with applicable law. In addition, we may disclose your
Personal Data to:

 1. our clients, subject always to compliance with the terms of this Policy and
    the requirements  of applicable law;
 2. other users, pursuant to our User Agreement, who may see your profile
    details in your public  profile setting, such as name, job title,
    organization, country, photos, website activity and  history, and comments,
    unless you choose to hide yourself from other users upon viewing a
     particular webcast;
 3. legal and regulatory authorities, upon request, or for the purposes of
    reporting any actual or suspected breach of applicable law or regulation;
 4. accountants, auditors, lawyers and other outside professional advisors to
    BrightTALK, subject to binding contractual obligations of confidentiality;
 5. third party Processors (such as IT service providers or other third party
    service providers we use for operational purposes), located anywhere in the
    world, subject to the requirements  noted below in this Section (4);
 6. any relevant party, law enforcement agency or court, to the extent necessary
    for the establishment, exercise or defense of legal rights;
 7. any relevant party for the purposes of prevention, investigation, detection
    or prosecution of criminal offences or the execution of criminal penalties,
    including the safeguarding against  and the prevention of threats to public
    security; and
 8. any relevant third party acquirer(s), in the event that we sell or transfer
    all or any relevant  portion of our business or assets (including in the
    event of a reorganization, dissolution or liquidation)

If we engage a third-party Processor to Process your Personal Data, the
Processor will be subject to binding contractual obligations to:

(i) only Process the Personal Data in accordance with our prior written
instructions; and

(ii) use measures to protect the confidentiality and security of the Personal
Data; together with any additional requirements under applicable law.

In accordance with applicable laws, your Personal Data may be transferred to,
stored at and processed  by us and our third party providers outside the country
in which you reside, including the United  States, where data protection and
privacy regulations may not offer the same level of protection as in  other
parts of the world. We have adopted Standard Contractual Clauses and/or another
appropriate  legal basis for transfers of Personal Data, as applicable.  


5. DATA SECURITY

We have implemented appropriate technical and organizational security measures
designed to protect  your Personal Data against accidental or unlawful
destruction, loss, alteration, unauthorized disclosure, unauthorized access, and
other unlawful or unauthorized forms of Processing, in  accordance with
applicable law. These measures include, but are not limited to, the
 implementation of current security technologies and processes to protect your
Personal Data  from loss, misuse and unauthorized access, disclosure, alteration
or destruction. Our security systems include authenticated access to internal
databases, regular audits of processes and  procedures, scheduled reviews of
overall web security, and the use of restrictions of access to  Personal Data in
our possession. Additionally, we use encryption (HTTPS/TLS) to protect data
 transmitted to and from our website. While BrightTALK maintains secure methods
of transferring  Personal Data, we are not responsible for other methods that
you may choose to send data, and you shall ensure that any Personal Data you
send to us is securely sent.


6. DATA RETENTION

We will retain copies of your Personal Data in a form that permits
identification only for as long as is  necessary in connection with the purposes
set out in this Policy, unless applicable law requires a  longer retention
period. To determine the appropriate retention period for Personal Data, we
consider  the amount, nature, and sensitivity of the Personal Data, potential
risk of harm from unauthorized use  or disclosure of your Personal Data,
purposes for which we process your Personal Data and whether  we can achieve
those purposes through other means, and applicable legal requirements. We will
retain users of our services Personal Data for so long as a user’s account
remains in existence or  as needed to provide our services, to comply with our
legal obligations, to resolve disputes, and  to enforce our agreements.  


7. LEGAL RIGHTS FOR EEA AND UK RESIDENTS

Subject to applicable law, you may have a number of rights regarding the
Processing of your Personal Data as a resident of the European Economic Area
(“EEA”) or United Kingdom (“UK”), including:

 1.  the right to be informed of the processing of your Personal Data;  
 2.  the right to request access to, or copies of, your Personal Data that we
     Process or control;
 3.  the right to request rectification of any inaccuracies in your Personal
     Data that we Process or  control;
 4.  the right to request, on legitimate grounds:
 5.  erasure of your Personal Data that we Process or control; or
 6.  restriction of Processing of your Personal Data that we Process or control;
 7.  the right to object, on legitimate grounds, to the Processing of your
     Personal Data by us or on  our behalf;
 8.  the right to have your Personal Data that we Process or control transferred
     to another  Controller, to the extent applicable;
 9.  where we Process your Personal Data on the basis of your consent, the right
     to withdraw that consent; and
 10. the right to lodge complaints with a Data Protection Authority regarding
     the Processing of  your Personal Data by us or on our behalf

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights
or any other provision of this Policy, or about our Processing of your Personal
Data, please use this form or the contact  details provided in Section (12)
below.


8. LEGAL RIGHTS FOR CALIFORNIA RESIDENTS

California consumers may have additional rights as described in the California
Consumer Privacy Notice found here, which is hereby incorporated into this
Policy by reference.


9. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies and other tracking technologies or other similar solutions
(“Tracking Technologies”) to collect or receive certain information when you
visit or use the BrightTALK  website, read an email, newsletter, or otherwise
interact with content from us.  

Cookies are small data files which are placed on your computer or mobile device
when you visit a  website or use an online service. For example, cookies enable
us to identify and authenticate you and  remember your preferences so we can
enhance your experience on our websites. They also help us  serve you ads
relevant to your professional interests, understand and improve our service, and
know  when content has been shown to you. Most browsers are initially set up to
accept cookies, but you can  reset your browser to refuse all cookies or to
indicate when a cookie is being sent.

We strongly recommend that you leave the cookies activated, however, because
cookies enable you to take advantage of some of the website features and if you
decline or delete them then parts of our  website and services may not work
properly.

BrightTALK uses several different types of cookies on our website, including the
following.

 1. Strictly Necessary Cookies. Strictly necessary cookies facilitate the
    operation of our website.  Without the use of these cookies, portions of our
    websites would not function properly. For example, we use essential cookies
    to help us identify which of our visitors have previously  registered in
    order to access our services.  
 2. Performance Cookies. Performance cookies help us monitor the performance of
    our website and  how users interact with them. These cookies collect
    information such as how often users visit our  website, what pages they
    visit when they do so, and what other websites they used prior to  coming to
    our website and provide us with information that allows us to improve our
    website and  services.
 3. Functional Cookies. Functional cookies are used to remember your preferences
    on our website and to authenticate your identity. For example, we use
    functional cookies to recognize and save  your name and password on our
    website.
 4. Behavioral Advertising Cookies. BrightTALK may use behavioral advertising
    cookies in order to  provide you with advertising which is tailored to your
    interests when you visit websites on and  off our network. Behavioral
    advertising cookies analyze information about your interests and your
    browsing history and provide you with advertisements on and off our network
    that match  these interests. Behavioral advertising is a type of advertising
    that is based upon your web  browsing activity over a period of time – so
    it’s different than advertising you may see when  you’re looking for
    something online using a search engine (e.g., Google, Yahoo, or Bing) or on
    a website you may be visiting at a particular time. As an example, you may
    be doing research on  products and services related to data center
    virtualization. If a data center virtualization provider  is conducting an
    advertising campaign on our network, as you browse the relevant portions of
    our  website, then we may serve you with an advertisement of one of their
    solutions.

Although our website currently does not respond to “do not track” browser
headers, you can limit tracking through third-party programs and by taking the
other steps discussed in this section. You  may opt-out of internet-based
advertising by removing cookies or by setting your web browser  settings to
refuse cookies and similar Tracking Technologies. Please note that web browsers
operate using different identifiers. As such, you must adjust your settings in
each web browser and for each  computer or device that you would like to opt-out
on. Further, if you simply delete your cookies, you  will need to remove cookies
from your device after every visit to the website. You may download a  browser
plugin that will help you maintain your opt-out choices by visiting
www.aboutads.info/pmc.  You may block cookies entirely by disabling cookie use
in your browser or by setting your browser to  ask for your permission before
setting a cookie. Blocking cookies entirely may cause some websites  to work
incorrectly.

Please note that the use of online tracking mechanisms by third parties is
subject to those third  parties’ own privacy policies, and not this Policy. You
may remove yourself from the targeted  advertising of companies within the
Network Advertising Initiative by opting out here, or of  companies
participating in the Digital Advertising Alliance program by opting out here,
the Digital  Advertising Alliance of Canada (DAAC) (for Canadian users) by
opting out here; or the European  Interactive Digital Advertising Alliance
(EDAA) (for users in the EU) by opting out here.

In addition to the foregoing, in order to protect our registration forms and
other website features, we  may use Google reCAPTCHA provided by Google Inc.
(“reCAPTCHA”). We employ  reCAPTCHA to check whether data is entered into our
forms by a person or by an automated  program, script or bot. reCAPTCHA analyzes
the behavior of the person entering the data using  various features. This
analysis starts automatically as soon as the website is accessed. For analysis,

reCAPTCHA evaluates various information (e.g., IP address, browser type,
settings, and plugins,  URL of the referring website, time spent on the
respective website, mouse movements, input  characteristics of the data entry,
including speed, sequence and selection of inputs, etc.). The data  collected
during the analysis is forwarded to a Google server in the USA, where it is
stored and  evaluated. We carry this processing out based on our legitimate
interest in preventing the misuse of  our websites through automated means. You
can find Google’s current privacy policy  at:
https://policies.google.com/privacy. Detailed information about Google reCAPTCHA
can be  found at the following address: https://www.google.com/recaptcha.


10. MINORS

Our products, services, events and offerings are directed to professionals. Our
business is not  directed at children, and we do not solicit or knowingly
collect any Personal Data from children  under the age of 16. If you are not 18
or older, you are not authorized to use our website or  services. Parents should
be aware that there are parental control tools available online that you can use
to prevent children from submitting information online without parental
permission or  from accessing material that is harmful to minors. If you learn
that a child under 16 has  provided us with Personal Data without consent,
please contact us via the information provided  in Section 12 below.


11. USER AGREEMENT

All use of our website is subject to our User Agreement.

‍


12. CONTACT DETAILS AND DATA SUBJECT REQUESTS

If you have any comments, questions or concerns about any of the information in
this Policy, or any  other issues relating to the Processing of Personal Data by
BrightTALK, please contact:

BrightTALK Inc.

703 Market St., 15th Floor, San Francisco, CA, 94103

Email: privacy@brighttalk.com

Phone: (617)-431-9200

General Privacy Rights Request Form

EU and UK GDPR Rights Request Form

California CCPA Rights Request Form


13. DEFINITIONS

 * ‘BrightTALK group’ means BrightTALK and its affiliates and parent company.
 * ‘Controller’ means the entity that decides how and why Personal Data is
   Processed. In many  jurisdictions, the Controller has primary responsibility
   for complying with applicable data  protection laws.
 * ‘Data Protection Authority’ means an independent public authority that is
   legally tasked  with overseeing compliance with applicable data protection
   laws.
 * ‘Personal Data’ means information that is about any individual, or from which
   any  individual is identifiable. Examples of Personal Data that we may
   Process are provided in  Section (2)
 * ‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any
   Personal Data,  whether or not by automated means, such as collection,
   recording, organization, structuring,  storage, adaptation or alteration,
   retrieval, consultation, use, disclosure by transmission,  dissemination or
   otherwise making available, alignment or combination, restriction, erasure
    or destruction.
 * ‘Processor’ means any person or entity that Processes Personal Data on behalf
   of the  Controller (other than employees of the Controller).
 * ‘Sensitive Personal Data’ means Personal Data about race or ethnicity,
   political opinions,  religious or philosophical beliefs, trade union
   membership, physical or mental health, sexual  life, any actual or alleged
   criminal offences or penalties, national identification number, or  any other
   information that may be deemed to be sensitive under applicable law.


14. EU REPRESENTATIVE  

In accordance with Article 27 of the GDPR, we have appointed a representative
within the European  Union.

The contact details of our EU representative are below.

Postal Address: E-Magine Medias SAS, 29 rue du Colisée, 7th Floor, 750008 Paris
Email address: eurep_ttgt@techtarget.com

Telephone: +33 (0)1 77 32 13 00.

E-Magine Medias role in this respect is limited solely to being a contact point
for questions from  European residents and data protection supervisory
authorities regarding data protection. E-Magine  Medias cannot respond to other
communications or legal processes on BrightTALK’s behalf. This  designation does
not alter BrightTALK’s role with respect to the personal data in its control nor
does  it affect BrightTALK’s responsibility or obligations under GDPR.


‍

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