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BRIGHTTALK PRIVACY POLICY

(date of last revision: June 10, 2021)


1.

INTRODUCTION

BrightTALK recognizes that privacy is important when using the Web for
communications. This policy explains how BrightTALK collects, stores, uses and
shares Personal Data.

2.

THIS POLICY

This Policy is issued by BrightTALK Inc. (“BrightTALK”) and is addressed to
individuals outside our organisation with whom we interact, including visitors
to our website (our “Site”) 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 (15) below.For the purposes of this
Policy, BrightTALK is the Controller. Contact details are provided in Section
(14) 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.

3.

PROCESSING YOUR PERSONAL DATA

Collection of Personal Data: We may collect Personal Data about you, such as
your name, address and contact details. Examples of sources from which we may
collect Personal Data include the following:

 * 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).
 * 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).
 * We may collect Personal Data that you manifestly choose to make public,
   including via our Site.
 * We may receive your Personal Data from third parties who provide it to us
   (e.g., social media platforms via plugins).
 * We may collect or obtain Personal Data when you visit our Site, or use any
   features or resources available on or through our Site. When you visit our
   Site, 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 Site, and details of your account
history.

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

 * Personal details: given name(s); preferred name; gender; date of birth / age;
   nationality; photograph; preferences; and account settings.
 * Contact details: telephone number; email address; and social media profile
   details.
 * Professional details: professional profile details; association memberships;
   qualifications and company insight data.
 * Device details: device type, operating system, browser type, browser
   settings, IP address, language settings, dates and times of connecting to our
   Site and other technical communications information.
 * 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.
 * Usage details: records of your use of our Site 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 favourite moments.
 * Analysis data: keywords, communities, trends, content quality and content
   importance.
 * Views, opinions and interests: any comments, ratings, views or opinions that
   you choose to send to us, post via our Site, 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:

 * 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);
 * the Processing is necessary in connection with any contract that you may
   enter into with us;
 * the Processing is required by applicable law;
 * the Processing is necessary to protect the vital interests of any individual;
   or
 * 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:

 * the Processing is required or permitted by applicable law (e.g., to comply
   with our diversity reporting obligations);
 * the Processing is necessary for the detection or prevention of crime
   (including the prevention of fraud);
 * the Processing is necessary for the establishment, exercise or defence 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:

 * Our Site: operating and managing our Site; providing content to you;
   displaying advertising and other information to you; and communicating and
   interacting with you via our Site.
 * Provision of services to you: providing our Site 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.
 * 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.
 * Disclosing Personal Data to our customers: in accordance with the provisions
   of this Policy and applicable law, we may disclose certain Personal Data to
   our customers. Our customers may contact you with information that may be of
   interest to you, provided that such communication is not otherwise in breach
   of applicable laws.
 * Communications and IT operations: management of our communications systems;
   operation of IT security; and IT security audits.
 * Health and safety: health and safety assessments and record keeping; and
   compliance with related legal obligations.
 * Financial management: sales; finance; corporate audit; and vendor management.
 * Surveys: engaging with you for the purposes of obtaining your views on our
   Site or our services.
 * Improving our Site and our services: identifying issues with existing Site
   and our services; planning improvements to existing Site and our services;
   creating new Site and our services.


‍

4.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We may disclose your Personal Data to other entities within the BrightTALK
group, for legitimate business purposes (including providing services to you and
operating our Site), in accordance with applicable law. In addition, we may
disclose your Personal Data to:

 * our customers, subject always to compliance with the terms of this Policy and
   the requirements of applicable law;
 * 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, brighttalk.com activity and history, and comments, unless
   you choose to hide yourself from other users upon viewing a particular
   webcast;
 * legal and regulatory authorities, upon request, or for the purposes of
   reporting any actual or suspected breach of applicable law or regulation;
 * accountants, auditors, lawyers and other outside professional advisors to
   BrightTALK, subject to binding contractual obligations of confidentiality;
 * 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);
 * any relevant party, law enforcement agency or court, to the extent necessary
   for the establishment, exercise or defence of legal rights;
 * 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
 * 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.

‍

5.

INTERNAL TRANSFER OF PERSONAL DATA

We may disclose your Personal Data to other entities within the BrightTALK
group, for legitimate business purposes (including providing services to you and
operating our Site), in accordance with applicable law. In addition, we may
disclose your Personal Data to:

 * our customers, subject always to compliance with the terms of this Policy and
   the requirements of applicable law;
 * 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, brighttalk.com activity and history, and comments, unless
   you choose to hide yourself from other users upon viewing a particular
   webcast;
 * legal and regulatory authorities, upon request, or for the purposes of
   reporting any actual or suspected breach of applicable law or regulation;
 * accountants, auditors, lawyers and other outside professional advisors to
   BrightTALK, subject to binding contractual obligations of confidentiality;
 * 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);
 * any relevant party, law enforcement agency or court, to the extent necessary
   for the establishment, exercise or defence of legal rights;
 * 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
 * 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.

‍

6.

DATA SECURITY

We have implemented appropriate technical and organizational security measures
designed to protect your Personal Data against accidental or unlawful
destruction, loss, alteration, unauthorised disclosure, unauthorised access, and
other unlawful or unauthorised forms of Processing, in accordance with
applicable law.

You are responsible for the ensuring that any Personal Data that you send to us
are sent securely.

7.

DATA ACCURACY

We take every reasonable step to ensure that:

 * your Personal Data that we Process are accurate and, where necessary, kept up
   to date; and
 * any of your Personal Data that we Process that are inaccurate (having regard
   to the purposes for which they are Processed) are erased or rectified without
   delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

8.

DATA MINIMIZATION

We take every reasonable step to ensure that your Personal Data that we Process
are limited to the Personal Data reasonably required in connection with the
purposes set out in this Policy.

9.

DATA RETENTION

The criteria for determining the duration for which we will keep your Personal
data are as follows: 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. In particular, we may retain your Personal Data for the
duration of any period necessary to establish, exercise or defend any legal
rights.

10.

YOUR LEGAL RIGHTS

Subject to applicable law, you may have a number of rights regarding the
Processing of your Personal Data, including:

 * the right to request access to, or copies of, your Personal Data that we
   Process or control;
 * the right to request rectification of any inaccuracies in your Personal Data
   that we Process or control;
 * the right to request, on legitimate grounds:
 * erasure of your Personal Data that we Process or control; or
 * restriction of Processing of your Personal Data that we Process or control;
 * the right to object, on legitimate grounds, to the Processing of your
   Personal Data by us or on our behalf;
 * the right to have your Personal Data that we Process or control transferred
   to another Controller, to the extent applicable;
 * where we Process your Personal Data on the basis of your consent, the right
   to withdraw that consent; and
 * 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 the contact details provided in Section (14) below.

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.

11.

COOKIES

A cookie is a small file that is placed on your device when you visit a website
(including our Site). It records information about your device, your browser
and, in some cases, your preferences and browsing habits. We may Process your
Personal Data through cookie technology, in accordance with our Cookie Policy.

12.

MINORS

Minors under the age of eighteen years old are not eligible to use our Site and
we therefore ask that minors do not submit any Personal Data to us, or use any
of the services provided on, through or via our Site.

13.

USER AGREEMENT

All use of our Site is subject to our User Agreement

14.

CONTACT DETAILS

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:

SUPPORT DEPARTMENT

BRIGHTTALK INC.
703 MARKET ST., 15TH FLOOR, SAN FRANCISCO, CA, 94103

SUPPORT@BRIGHTTALK.COM

415 625 1500

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.

‍

15.

DEFINITIONS

 * ‘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 (3)

 * ‘Process’, ‘Processing’ or ‘Processed’ means anything that is done with any
   Personal Data, whether or not by automated means, such as collection,
   recording, organisation, 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.

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