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PRIVACY POLICY


1. INTRODUCTION

This privacy statement applies to the following companies:

 * Inbox Insight Group Limited (registered in England under number 10499998
   whose address is Inbox Insight Limited, 1 Exchange Square, Jewry Street,
   Winchester, Hampshire, SO23 8FJ);
 * Inbox Insight Limited (registered in England under number 7179598 whose
   address is Inbox Insight Limited, 1 Exchange Square, Jewry Street,
   Winchester, Hampshire, SO23 8FJ); and
 * Inbox Insight Inc (registered in Delaware under number 6243428) whose Address
   of Incorporation is at 2711 Centerville Road, Suite 400, Wilmington, New
   Castle, Delaware 19808, United States of America and whose Registered Address
   is at 1661 Worcester Road, Suite 207, Framingham, MA, 01701, United States of
   America.

Inbox Insight (together referred to as “we”) are committed to protecting and
respecting your privacy. We gather and process data in accordance with the
prevailing European and North American data protection legislation, including
the General Data Protection Regulation (GDPR) 2016 and the Data Protection Act
(2018).

It covers the following websites:

 * advisorsforbusiness.co.uk
 * businessexpertise.co.uk
 * ifp-resources.com
 * ifp-knowledge.com
 * inboxinsight.com
 * inboxinsightbi.com
 * inboxinsightmail.com
 * industrybulletins.co.uk
 * insight-for-business.com
 * insights-africa.com
 * insights-argentina.com
 * insights-australia.com
 * insights-belgie.com
 * insights-brasil.com
 * insights-colombia.com

 * insights-czechia.com
 * insights-danmark.com
 * insightsdatanetwork.com
 * insights-deutsch.com
 * insights-espana.com
 * insights-europe.com
 * insightsforprofessionals.com
 * insightsforprofessionals.co.uk
 * insights-for-professionals.com
 * insights-francais.com
 * insights-hellas.com
 * insights-hindistan.com
 * insights-ireland.com
 * insights-italiana.com
 * insights-letzebuerg.com

 * insights-mexico.com
 * insights-middleeast.com
 * insights-nederland.com
 * insights-newzealand.com
 * insights-nippon.com
 * insights-norge.com
 * insights-osterreich.com
 * insights-polska.com
 * insights-portugal.com
 * insights-romania.com
 * insights-schweiz.com
 * insights-sea.com
 * insights-see.com
 * insights-suomi.com
 * insights-sverige.com

This policy, together with our terms and conditions (a copy of which can be
found here: https://www.insightsforprofessionals.com/terms ), sets out the basis
on which we will process personal data we collect about you, or that you provide
to us. Please read the following carefully to understand our views and practices
regarding your data.


2. INFORMATION WE MAY COLLECT ABOUT YOU

We may collect and process the following data about you:

 * Information that you provide:
   * Registering to use our website.
   * Subscribing to our services.
   * When attending trade shows or events.
   * Requesting further information, services or content.
   * Completing surveys that we use for research purposes.

This includes your title, gender, full name, address and other communication
contact information, job title, company affiliation and attributes concerning
your job.

 * Details of your visits to our website. This includes, but is not limited to:
   * Details of the computer or other device that you are using.
   * Details of the web browser you are using.
   * Details of your language settings.
   * Traffic data.
   * Location data.
   * Weblogs.
   * Other communication data.

If you contact us, we may keep a record of that correspondence, including any
information provided or required to resolve your enquiry or issue.


3. IP ADDRESSES

We may collect information about your computer, including your IP address,
operating system and browser type. We use this for system administration
purposes.

We may aggregate such information and provide it to our advertisers. This is
statistical data concerning browsing actions and patterns, and does not identify
you as an individual.


4. COOKIES

We use Cookies on our websites in order to optimise functionality.

You may block cookies by adjusting setting on your browser. Please note that if
you restrict all cookies you may not be able to access all or parts of our site.
Unless you have configured your browser to refuse cookies, our system will issue
cookies as soon you visit our websites.

When you first visit any of our sites a pop-up header will be generated alerting
you to our cookie policy. It will re-appear in the event that you change your
cookie settings from time to time.

A copy of our cookie policy, including details of how to opt-out, can be found
here Cookie Policy.


5. STORAGE OF PERSONAL DATA

We have implemented appropriate security measures to protect information from:

 * Loss.
 * Misuse.
 * Unauthorised access.
 * Disclosure.
 * Alteration.
 * Destruction.

Our security systems include authenticated access to internal databases. We also
encrypt and anonymise data wherever it is appropriate to do so. We regularly
take back-ups of our data. We regularly review overall Web security and audit
procedures.

In conforming with data protection laws, we endeavour to implement appropriate
procedures to protect your personal data and to prevent any unauthorised access
or misuse of it. Our servers, on which your personal data is kept, are located
in the United Kingdom.

Please be aware that the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal data,
we cannot guarantee the security of your data when transmitted via the internet
to our site: any such transmission is at your own risk.


6. USES MADE OF THE INFORMATION

We use information held about you in the following ways:

 * To ensure that content from our site is presented in the most effective
   manner for you and for your computer.
 * To provide you with relevant information, products or services of a type that
   you request from us or which we feel may interest you.
 * To carry out the requirements of any contracts entered into between you and
   us.
 * To allow you to use the interactive features of our service, when you choose
   to do so.
 * To notify you about changes to our service.

We are committed to responsible email sending practices. We only send email to
individuals whose data has been lawfully and fairly obtained. If at any time you
do not wish to receive emails from us, please use the unsubscribe functionality
contained in all of our communications.

Alternatively, please contact us by email at privacy@inboxinsight.com; by post
to Data Protection Co-ordinator, Inbox Insight Limited, 1 Exchange Square, Jewry
Street, Winchester, Hampshire, SO23 8FJ; or by telephone on +44 (0) 1962 831200.

We may also use your data, or permit selected third parties to use your data, to
provide you with information about goods and services but only where you have
requested us or indicated to us to do so: for example where we have sent you an
offer that you have responded to.


7. DISCLOSURE OF YOUR INFORMATION

The members of our Group are our parent company Inbox Insight Group Limited
(registered in England under number 10499998 whose address is Inbox Insight
Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ); and
its subsidiaries, (registered in England under number 7179598 whose address is
Inbox Insight Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire,
SO23 8FJ); and Inbox Insight Inc (registered in Delaware under number 6243428)
whose Address of Incorporation is at 2711 Centerville Road, Suite 400,
Wilmington, New Castle, Delaware 19808, United States of America and whose
Registered Address is at 1661 Worcester Road, Suite 207, Framingham, MA, 01701,
United States of America. We allow any company in the group to process your
personal information. Where we do so we confirm that those recipient companies
will abide by the provisions of this Privacy Policy and accordingly this Privacy
Policy also applies to each of those companies.

Where we have sent you an offer that you have responded to, we may pass your
details to the relevant third party who has made that offer.

We may pass your details to our partners, or future partners, based on your
access to the content on any of our services. This may include information about
your interests derived from you activity on our websites. We may disclose
information in the form of market research, aggregating it into reports or
dashboards, which show trends in content consumption across our services. It may
include a description of your activity on our websites and engagement with
advertising, editorial and partner content. We may also provide our partners
with your contact information and details of your interests for the purpose of
further marketing, and they may use this information to contact you via email,
telephone, mail, digital marketing or other means of communication. Our partners
are subject to change so please check back regularly for updates.

We may share the details of our current and prospective clients with Reachdesk
Ltd, for the purpose of sending you promotional gifts.

If you wish to opt out of this process please contact us by email at
privacy@inboxinsight.com; by post to Data Protection Co-ordinator, Inbox Insight
Limited, 1 Exchange Square, Jewry Street, Winchester, Hampshire, SO23 8FJ; or by
telephone on +44 (0) 1962 831200.

Please contact our partners directly if you would like to opt out of their
communications, but wish to continue to receive marketing communications from
us, or making use of our services.

We use HubSpot Inc, Salesforce.com Inc., Yesware Inc., Unbounce Marketing
Solutions Inc., and Citrix Systems Inc. to assist us in managing your data.
While some of these companies are located in the United States, they have joined
the Privacy Shield system allowing the processing of data by that company in
accordance with the GDPR.

We may disclose your personal information to the extent that we are under a duty
to disclose or share your personal data in order to:

 * Comply with any legal obligation.
 * Enforce or apply our terms of use and other agreements with you.
 * Protect the rights, property, or safety of Inbox Insight, our customers, or
   others.
 * This includes exchanging information with other companies and organisations
   for the purposes of fraud protection.

We may disclose your personal information to third parties to whom we may be
considering selling or who may be considering buying the whole or part of our
business or assets.


8. YOUR RIGHTS

The data protection legislation gives you a number of rights. These rights
include:

 * Right to make a “Subject Access Request”, which is a request for a copy of
   the data which we hold about you.
 * Right of correction (or where appropriate erasure) of data which we hold
   about you where this is inaccurate.
 * Right to data erasure.
 * Right to data portability.
 * Right to withdraw your future consent to our processing your personal data.
 * Right to contact and make enquiries of our Data Protection Co-ordinator via:
   * Email: privacy@inboxinsight.com
   * Post: Data Protection Co-ordinator, Inbox Insight Limited, 1 Exchange
     Square, Jewry Street, Winchester, Hampshire, SO23 8FJ.
   * Telephone: +44 (0) 1962 831200.
 * Right to complain to the Office of the Information Commissioner.

Please be aware that if you exercise one of these rights, that in order to
protect your privacy, we may require you to undergo some verification tests to
ensure that we are dealing with you.

You have the right to be informed of the matters stated in this privacy policy.

There are three legal bases upon which we collect, process and transfer your
personal data as described in this privacy policy including:

 * Contract – to consider potential or to fulfil actual contracts with you. If
   you are not able to provide this data, it is possible that we will be unable
   properly to perform our side of any contract with you.
 * Legitimate Interest – In order to consider potential or to fulfil actual
   contracts with you and others, we need to collect and process personal data
   about you. We also have a separate legitimate interest to engage in direct
   marketing with you where you have ascribed to our service. As indicated in
   section 9 you may unsubscribe for this service at any time.
 * Consent – We may also rely on your consent to use your personal data.


9. CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

Under the California Consumer Privacy Act, California Civil Code Section
1798.100, if you are a resident of California you may contact us with regard to
the following rights in relation to your personal data:

 * Right of Access and Disclosure: You have a right to request access to the
   personal data we may hold on you for the past twelve (12) months. You may
   submit up to two (2) requests per year of access to your personal data.
 * Right to Deletion: You have the right to ask us to delete personal data we
   may hold on you. There may be exceptions to the right to deletion for
   specific legal reasons which, if applicable, we will set out for you in
   response to your request.
 * Right to Opt-Out of Sale of Personal Data: You have the right to opt-out of
   sale of personal data we may hold on you. You can exercise this right at any
   time.
 * Right to Non-Discrimination: We will not discriminate against you for
   exercising any of your California Consumer Privacy Act rights.

If you wish to make any of these requests, please contact
privacy@inboxinsight.com . We will deal with requests for access to your
personal data, or deletion requests, within forty-five (45) days for
California-specific requests.

To help us respond as you expect, please specify that you are making a request
under the California Consumer Privacy Act (CCPA). We may need to request
specific information from you to help us confirm your identity.


10. DATA RETENTION

We normally hold and process your data for a maximum of seven (7) years from the
date when you last interacted with our services. If you have never interacted
with our services, we will normally hold and process your data for forty eight
months from the date when we first contact you about our services. In this
context “interact” means following a link which we send you, or authenticating
yourself on one of our websites. We will delete your data earlier where you
request us to do so as provided for below.

In any event we will stop the processing of your data where you ask us to do so
by contacting us by email at privacy@inboxinsight.com; by post to Data
Protection Co-ordinator, Inbox Insight Limited, 1 Exchange Square, Jewry Street,
Winchester, Hampshire, SO23 8FJ; or by telephone on +44 (0)1962 831200. The only
circumstances in which we will not do so are where we have a legal obligation or
a legitimate interest to continue processing your data.

Our websites and email bulletins frequently contain links to and from the
websites of our partner networks, advertisers and affiliates. If you follow a
link to any of these websites, please note that these websites have their own
privacy policies. We do not set and are not responsible for those policies.


11. ANALYTIC SUPPLIERS

In common with the majority of comparable trading companies that use the
internet we occasionally use your personal data to help Analytic Suppliers match
relevant ads to you using the data analytics of those Analytic Suppliers.
However, we only use the data in that way where you are a subscriber to the
services of Analytic Suppliers and have therefore agreed to this service by
acceding to the relevant Agreements of those Analytic Suppliers.

Analytic Suppliers supply us with statistical information on how users interact
with our website to help us improve our user experience. This can include the
use of online information from third parties who may not have a relationship
with you and who collect online information using cookies or similar
technologies, such as pixels tags and device identifiers, as you browse the
Internet and interact with websites. We use this information to understand your
interests and needs, making your advertising and communications more relevant.
For more information on how we use cookies please view our Cookie Policy.

We mean by Analytic Suppliers: Facebook; Google; Twitter and Microsoft.
By third parties we mean: AdRoll/NexRoll; Avocet; Eyeota; Google; Outbrain;
Taboola.

We do not control the countries outside the United Kingdom in which those
Analytic Suppliers process data. Where you have acceded to use the services of
those Analytic Suppliers that accession includes our right to use that data in
the manner described above.


12. HOTJAR

We use Hotjar in order to better understand our users’ needs and to optimize
this service and experience. Hotjar is a technology service that helps us better
understand our users experience (e.g. how much time they spend on which pages,
which links they choose to click, what users do and don’t like, etc.) and this
enables us to build and maintain our service with user feedback.

Hotjar uses cookies and other technologies to collect data on our users’
behaviour and their devices (in particular device's IP address (captured and
stored only in anonymized form), device screen size, device type (unique device
identifiers), browser information, geographic location (country only), preferred
language used to display our website).

Hotjar stores this information in a pseudonymized user profile. Neither Hotjar
nor we will ever use this information to identify individual users or to match
it with further data on an individual user. For further details, please see
Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data
about your usage of our site and Hotjar’s use of tracking cookies on other
websites by following this opt-out link.


13. PRIVACY SHIELD

Inbox Insight complies with the EU-U.S. Privacy Shield Framework as set forth by
the U.S. Department of Commerce regarding the collection, use, and retention of
personal information transferred from the European Union and the United Kingdom
to the United States in reliance on Privacy Shield. Inbox Insight has certified
to the Department of Commerce that it adheres to the Privacy Shield Principles
with respect to such information. If there is any conflict between the terms in
this privacy policy and the Privacy Shield Principles, the Privacy Shield
Principles shall govern. To learn more about the Privacy Shield program, and to
view our certification, please visit https://www.privacyshield.gov.

With respect to Personal Information received or transferred pursuant to the
Privacy Shield Framework, Inbox Insight is subject to the regulatory enforcement
powers of the U.S. Federal Trade Commission. In certain situations, Inbox
Insight may be required to disclose Personal Information in response to lawful
requests by public authorities, including to meet national security or law
enforcement requirements.

In compliance with the Privacy Shield Principles, Inbox Insight commits to
resolve complaints about our collection or use of your personal information. EU
individuals with enquiries or complaints regarding our Privacy Shield policy
should first contact Inbox Insight via: privacy@inboxinsight.com.

Inbox Insight has further committed to cooperate with the panel established by
the EU data protection authorities (DPAs) with regard to unresolved Privacy
Shield complaints concerning data transferred from the EU. EU individuals may
invoke binding arbitration when other dispute resolution procedures have been
exhausted.


14. EU AUTHORISED REPRESENTATIVE

Our representative in EEA under article 27 GDPR is Elena Riazanova, with their
registered address at: Calle de Cullera 11, 3C, Madrid, Spain.


15. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on
this page. Please therefore check this page on a regular basis.


16. CONTACT

Questions, comments and requests regarding this privacy policy are welcome and
should be addressed to privacy@inboxinsight.com.

Should you wish to request access to a whitepaper without completing the survey
on our landing pages, please send your request to: whitepaper@inboxinsight.com.

Issue: 20210517.1


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