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WEBSITE PRIVACY AND COOKIES POLICY

Introduction

Welcome to GlobalData’s privacy policy.

Last Updated 10th August 2023.

GlobalData respects your privacy and is committed to protecting your personal
data. This privacy policy will inform you as to how we look after your personal
data when you contact us or visit one of our websites (regardless of where you
visit it from), or when you submit personal data to us pursuant to a
transaction, and it tells you about your privacy rights and how the law protects
you.

GlobalData is made up of different legal entities, details of which can be
found here.  This privacy policy is issued on behalf of the GlobalData Group so
when we mention “GlobalData”, “we”, “us” or “our” in this privacy policy, we are
referring to the relevant company in the GlobalData Group responsible for
processing your data.

We have appointed a Data Compliance Officer who is responsible for overseeing
questions in relation to this privacy policy. If you have any questions about
this privacy policy, including any requests to exercise your legal rights,
please contact the Data Compliance Officer at GlobalData, John Carpenter House,
John Carpenter Street, London, EC4Y 0AN, or email datacompliance@globaldata.com.

 1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we, GlobalData, collect
and process your personal data through your use of our websites, including any
data you may provide through our websites when you sign up to our newsletter,
purchase services from us, or interact with us in any way.

Our websites and services are primarily intended for other businesses rather
than consumers.  This website is not intended for children and we do not
knowingly collect data relating to children.

It is important that you read this privacy policy together with any other
privacy policy or fair processing notices we may provide on specific occasions
when we are collecting or processing personal data about you so that you are
fully aware of how and why we are using your data. This privacy policy
supplements other such notices and privacy policies and is not intended to
override them.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.  We encourage users to
frequently check this page for any changes to stay informed about how we are
helping to protect the personal data we collect. This version was last updated
on the date specified at the top of this page.

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy policy of every
website you visit.

 2. The data we collect about you

Personal data, or personal information, means any information about an
individual from which that person can be identified. It does not include data
where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about
you which we have grouped together as follows:

 * Identity Data includes your name, username or similar identifier, title and
   gender.
 * Contact Data includes your address, email address and telephone numbers.
 * Financial Data includes bank account and payment card details.
 * Transaction Data includes details about payments to and from you and other
   details of products and services you have purchased from us.
 * Technical Data includes internet protocol (IP) address, your login data,
   browser type and version, time zone setting and location, browser plug-in
   types and versions, operating system and platform, and other technology on
   the devices you use to access this website.
 * Profile Data includes your username and password, purchases or orders made by
   you, your interests, preferences and feedback.
 * Usage Data includes information about how you use our website, products and
   services.
 * Marketing and Communications Data includes your preferences in receiving
   marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data could be derived from your
personal data but is not considered personal data in law as this data
will not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data with
your personal data so that it can directly or indirectly identify you, we treat
the combined data as personal data which will be used in accordance with this
privacy policy.

We do not routinely collect any Special Categories of Personal Data about you
(this includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data),
unless strictly required (for example, dietary or access requirements in
relation to an event). Nor do we collect any information about criminal
convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract
we have with you, and you fail to provide that data when requested, we may break
the law, or we may not be able to perform the contract we have or are trying to
enter into with you (for example, to provide you with goods or services). In
this case, we may have to cancel a product or service you have with us but we
will notify you if this is the case at the time.

 3. How is your personal data collected?

We use different methods to collect data from and about you including through:

 * Direct interactions. You may give us your Identity, Contact, Financial and
   Marketing and Communications Data by filling in forms, placing an order,
   subscribing to our newsletters & whitepapers, registering for an event,
   webinar, seminar or workshop or by responding to a survey or by corresponding
   with us by post, phone, email or otherwise.
 * Automated technologies or interactions. As you interact with our website, we
   will automatically collect Technical Data about your equipment, browsing
   actions and patterns. We collect this personal data by using cookies and
   other similar technologies. Please see our Cookie Policy for further details.
 * Third parties We will receive personal data about you from various third
   parties as set out below:
 * Technical Data from analytics providers such as Google LLC and Permutive Inc
   based outside the UK;
 * Contact Data from Clearbit Inc based outside the UK, who resolve a company
   name from your IP address when possible.
 * Contact Data from publicly available sources (such as your organisation’s
   website) in connection with business opportunities which might be relevant to
   you.
 * Contact Data and Identity Data from your employer in order that we can
   provide you with access to a service we are providing to your employer.
 * From time to time, we may work with third parties (for example, marketing
   agents such as Sopro) to identify individuals who may be interested in our
   products and services or in some cases our clients’ or partners’ products and
   services. These third parties may give us access to your Contact Data, where
   they are lawfully permitted to do so.

We also use Google LLC (based outside the UK) to serve advertisements and use
cookies for ad personalisation.

If it is not disproportionate or prejudicial, we’ll contact you to let you know
we are processing your personal data and, if we have obtained your personal data
from a third party, we will let you know where we obtained your personal data
from.

 4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:

 * Where we need to perform the contract we are about to enter into or have
   entered into with you.
 * Where it is necessary for our legitimate interests (or those of a third
   party) and your interests and fundamental rights do not override those
   interests.
 * Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

 * If you place an order with us

If you have placed an order with us, we will use the Identity, Contact,
Financial and Profile Data supplied to perform our obligations under our
contract with you (for example, to set up individual user accounts to enable
such users to access our services).  You warrant that you are lawfully permitted
to submit any third-party data to us.

We might also use Identity, Contact, Financial and Transaction Data to process
the order where necessary for the performance of the contract (for example, to
manage payments, fees and charges), or where it is necessary for our legitimate
interests (for example, to recover debts owed to us, and/or to administer and
protect our business).

 * If you access or use our subscription or consultancy services

If you access or use our services, we may use Identity, Contact, Profile,
Technical, Usage, Profile and Marketing and Communications Data in order to
manage our relationship with you.  For example, to monitor how our services are
being used, to contact you in connection with our services with advice and
assistance, or to ask you to complete a review or take a survey.  We will only
do this where it is in our legitimate interest to do so (for example, to study
how our services are being used to make improvements), or where it is necessary
in connection with our performance of a contract with you.

From time to time, we might also make suggestions and recommendations to you
about additional services that may be of interest to you based on the services
you are using and/or to contact you in connection with potential business
opportunities that may be of interest to you.  We will only do this where it is
necessary for our legitimate interests in order to develop our products/services
and to grow our business and our relationship with you.

 * If you access one of our websites

We may use your Identity, Contact, Profile, Usage, Marketing and Communications
and Technical Data to deliver relevant website content and advertisements to you
and to measure or understand the effectiveness of the advertising we serve to
you.  We will only do this where you have given consent, or where it is
necessary for our legitimate interests (please also refer to the Cookies section
below).

We may use data analytics to improve our website, products/services, marketing,
customer relationships and experiences.  This may involve us using Technical and
Usage Data where it is necessary for our legitimate interests, for example, to
define types of customers for our products and services, to keep our website
updated and relevant, to develop our business and to inform our marketing
strategy.

We might also use Identity, Contact and Technical Data to administer and protect
our websites (including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data).  We will only do this when
it is necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security, to prevent fraud
and in the context of a business reorganisation or group restructuring
exercise), or necessary to comply with a legal obligation.

 * If you subscribe to our newsletter(s) or updates, or if you request to
   receive free content via one of our websites (for example, a white paper)

We will use your Identity, Contact, Transaction, Profile, and Marketing and
Communications Data in order to set up your account (if applicable) and to
provide you with content which might be of interest to you.  If you have
requested specific content, the lawful basis will be your consent.

We may also use your Identity, Contact, Technical, Usage and Profile Data to
form a view on what we think you may want or need, or what may be of interest to
you in order to decide which content may be relevant for you.  We will do this
only for corporate subscribers with a corporate e-mail address and/or contact
number where it is in our legitimate interests to do so and your interests and
fundamental rights do not override those interests.

If you have requested content provided by a third party, we may share your
details with that third party where you have consented to us doing so, or where
it is in our or that third party’s legitimate interests to do so.  We will
notify you if we intend to share your personal data with the relevant
third-party content provider(s) at the point of collecting your personal data
and you can withhold consent, or alternatively opt-out of us sharing your
personal data by emailing us at unsubscribe@globaldata.com  at that point.

From time to time we may also share your details with other carefully selected
third parties who operate within your industry, and who may be able to provide
additional content and services to help grow or provide value to your and/or
that third party’s business.  Such third parties may contact you via your
corporate email address with business-to-business related correspondence, which
you can opt-out of at any time.  We will only share your information in
accordance with the above where we have determined that it is in our or that
third party’s legitimate interests to do so and your interests and fundamental
rights do not override those interests, and we ensure appropriate safeguards are
in place to protect your personal data.

If you wish to object to us sharing your personal data with any third parties as
set out above you can do so by emailing us at unsubscribe@globaldata.com .

 * If you sign up to an event, seminar or workshop

If you sign up to an event, seminar or workshop, we will collect your Identity,
Contact, and Financial Data so that we can facilitate the event, provide an
acceptable service, and respond to you.  The lawful basis we rely upon for
collecting this information is consent.  If relevant for the event, we may also
need information about dietary or access requirements, in which case we also
need your consent as this type of information is classed as special category
data.

Some events may be recorded, in which case presenters may have their image and
audio captured in the recording. If you are an attendee and choose to interact
with the event your comments may also form part of the recording.  If an event
is being recorded we will always notify you in advance.  Our purpose for
collecting this information is so we can facilitate the event and provide wider
access to its content.  The lawful basis we rely on for processing your personal
data is our legitimate interests.

Attendee Contact Data may be shared with event sponsors, with other attendees,
and with third parties who run similar events which may be of interest to you. 
We will only do this where you have given us consent to share your Contact Data,
or where it is in our legitimate interests to do.  If you wish to object to us
sharing your personal data with any third parties as set out above you can do so
by emailing us at unsubscribe@globaldata.com.

 * If you participate in a prize draw, competition or complete a survey

We may use your Identity, Contact, Profile, Usage, Marketing and Communications
Data if you have signed up to participate in a prize draw or competition, or if
you have completed a survey.  We will only use your data to the extent necessary
to perform our obligations under a contract with you, or where it is necessary
for our legitimate interests (for example, to study how customers use our
products/services, to develop them and grow our business).

 * If you contact us with an enquiry or complaint (for example, via our website,
   by email, or be telephone)

If you contact us to make an enquiry or complaint, we may collect information,
including your personal data, so that we can respond to the enquiry/complaint
(as the case may be). We need enough information from you to answer your enquiry
or respond to the complaint. If you contact our helpline, we may make an audio
recording of the conversation, but will inform you of this at the time.  This is
so we have an accurate account of the request/complaint so that we can ensure
that we are taking appropriate action.

The lawful basis we rely on to process your personal data is our legitimate
interests to respond to the enquiry/complaint and to improve our services.

 * Personal data captured within one of our Information Centres

From time to time, personal data may be captured within one of our Information
Centres made available to paying clients.  This will typically be publicly
available corporate contact information linked to a particular project or
business venture.  If personal data may be captured, we will undertake a Data
Protection Impact Assessment to ensure the personal data is captured and
processed lawfully and that appropriate steps are taken to minimise any impact.

 * When you become a shareholder

If you become a shareholder we may collect your Identity, Contact, and Financial
Data to comply with our regulatory and legal obligations in relation to
shareholders, to communicate with you and to facilitate the payment of
dividends.  The lawful basis we rely upon to process your personal data is: (i)
necessary to comply with a legal obligation; (ii) performance of a contract with
you; and (iii) our legitimate interests (to effectively run our business and
keep you informed of developments and provide notice about AGM’s etc.).

 * If you apply for a job with us

If you apply for a job with us, we may use you Identity and Contact Data and
information contained within your CV and application form to consider you for
the vacancy.  The lawful basis we rely upon to process your personal data is
your consent and our legitimate interest (for running and improving our
business).  Further information is contained within our candidate privacy
policy, which is provided to candidates.

Marketing

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.  We do not intend to market to
non-corporate subscribers and ask that you provide your corporate subscriber
information when submitting your information to us. As above, we refer to a
corporate subscriber as an individual within an organisation that possesses a
corporate e-mail address and/or contact telephone number.

Opting out

If you are receiving any marketing messages from us, you can ask us to stop
sending you marketing messages or ask us to stop sharing your personal data with
any third parties for marketing purposes at any time by emailing us
at unsubscribe@globaldata.com or by following the opt-out links on any marketing
message sent to you.  We will process your request as promptly as practical,
however you may receive communications for a transitional period whilst we
update your records.

Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service purchase,
product/service experience or other transactions.

If you are receiving marketing messages from any third party in respect of whom
we have shared your personal data, that third party will be the controller in
respect of your personal data and you will need to contact that third party in
order to unsubscribe to their marketing messages.

Cookies

A cookie is a small file of letters and numbers that we store on your browser or
the hard drive of your computer if you agree. Cookies contain information that
is transferred to your computer’s hard drive.

We use the following cookies:

 * Strictly necessary cookies. These are cookies that are required for the
   operation of our website. They include, for example, cookies that enable you
   to log into secure areas of our website, use a shopping cart or make use of
   e-billing services.
 * Analytical or performance cookies. These allow us to recognise and count the
   number of visitors and to see how visitors move around our website when they
   are using it. This helps us to improve the way our website works, for
   example, by ensuring that users are finding what they are looking for easily.
 * Functionality cookies. These are used to recognise you when you return to our
   website. This enables us to personalise our content for you, greet you by
   name and remember your preferences (for example, your choice of language or
   region).
 * Targeting cookies. These cookies record your visit to our website, the pages
   you have visited and the links you have followed. We will use this
   information to make our website and the advertising displayed on it more
   relevant to your interests.

You can find more information about the individual cookies we use and the
purposes for which we use them in the table below:

Service Description Privacy Policy Google Analytics (Google LLC) We use the data
collected by Google Analytics to track and examine the use of this application
and to prepare reports on



user activities

Privacy Policy Permutive (Permutive Inc) We use data collected by Permutive to
track and analyse customer interactions with our website. User’s IP addresses
are received and processed but raw IP’s are not stored. Privacy Policy Facebook
(Facebook Inc) This Cookie is placed by Facebook. It enables us to measure,
optimise and build audiences for advertising campaigns served on Facebook.
Privacy Policy Clearbit (Clearbit Inc) We use Clearbit to resolve a company name
from your IP address when possible Privacy Policy Intercom We use data collected
by Intercom to track and analyse customer interactions with our services. We may
also use Intercom as (1)



a medium for communications, either through email, or through messages within
our product(s); and (2) to provide help information to our customers.

Privacy Policy HubSpot We use a cookie from HubSpot to track and analyse
customer interactions with our services. We also use HubSpot as a communications
platform to send messages to our users, including over email. Privacy Policy
Content Square We use a cookie from Content Square to track and analyse customer
interactions with our websites. Privacy Policy

You can block cookies by activating the setting on your browser that allows you
to refuse the setting of all or some cookies. However, if you use your browser
settings to block all cookies (including essential cookies) you may not be able
to access all or parts of our website.

Except for essential cookies, we will only place cookies where you have given us
consent to do so.

Change of purpose

We will only use your personal data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted
by law.

 5. Disclosures of your personal data 

GlobalData engages different types of processors to perform various functions in
connection with the services we provide to you as explained below.  With regard
to all third parties with whom GlobalData shares personal data, we have
undertaken a commercially reasonable selection process to evaluate the security,
privacy and confidentiality practices of those processors to ensure the
integrity, confidentiality and availability of our data (including any personal
data).  Processors are required to enter into an agreement with us which
includes the personal data processing provisions stipulated under Article 28 of
the UK GDPR.  Additional safeguards, such as Standard Contractual Clauses and
additional due diligence, is also undertaken if the processor is located in a
country which does not have an ‘adequacy’ decision (i.e.  the country does not
have the benefit of a decision from the EU that is has an ‘essentially
equivalent’ level of data protection to that which exists within the EU), but in
any event we carry out the required Data Transfer Risk Assessments prior to
making a restricted transfer.

 * Infrastructure Processors

GlobalData owns or controls access to the infrastructure that GlobalData uses to
host and process client personal data.  The relevant infrastructure is located
in the UK, US, and European Union.  GlobalData uses the processors listed below
for hosting and infrastructure services.  GlobalData may also use additional
services provided by these processors to process data as needed for GlobalData
to provide its services:

Processor Jurisdiction Purpose Google USA, European Union Customer Service /
Infrastructure & Hosting Ensono United Kingdom Infrastructure & Hosting Amazon
Web Services European Union Infrastructure & Hosting Amazon Web Services USA
Infrastructure & Hosting New Relic USA Infrastructure & Hosting

 * Service Specific Processors

GlobalData works with a number of third parties to provide specific
functionality within the services we provide. The relevant processors’ use of
personal data is limited to the services indicated below.  Please note this list
is not exhaustive and GlobalData may engage additional third parties from time
to time to improve the services provided by GlobalData.

Processor Jurisdiction Purpose Intercom USA Customer service and communications
Salesforce European Union Customer services and relationship management
Freshworks European Union Customer service Permutive USA Advertising customer
service New Relic USA Infrastructure analytics Cybereason USA Security Gong USA
Customer service and product development Zoom USA Customer service (video
conferencing)

 * Intra-group Transfers

GlobalData may share personal data internally with other group companies to
assist with the provision of the services (for example, to assist with
responding to an IT request) in which case such group company will be acting as
a processor.  We will only do this where it is in our legitimate interests to do
so, or where it is necessary for the performance of a contract.

In addition, if you have requested information or services from a group company,
personal data may be shared internally with that group company in order for that
group company to respond to the request.  In such a scenario, the relevant group
company will be operating as a separate controller.

Some of our group companies are located outside of the UK.  We have implemented
appropriate protections to meet the requirements of transferring personal data
to third countries in accordance with applicable data protection laws.

 * Other third parties

We may also share your personal data with external third parties such as:

 * Professional advisers including, but not limited to, lawyers, bankers,
   auditors and insurers who provide consultancy, banking, legal, insurance and
   accounting services.
 * HM Revenue & Customs, regulators and other authorities who require reporting
   of processing activities in certain circumstances.
 * In the case of shareholders, with our shareholder registrar.
 * Other third parties where we have consent to do so.
 * Third parties to whom we may choose to sell, transfer or merge parts of our
   business or our assets. Alternatively, we may seek to acquire other
   businesses or merge with them. If a change happens to our business, then the
   new owners may use your personal data in the same way as set out in this
   privacy policy.

As detailed above, if you sign up to an event, or if you sign up to receive a
report, marketing, or updates on a particular topic, we may share relevant
corporate subscriber information with third party organisations linked to that
event or third-party organisations operating on our platform that can provide
information that may be of interest to you.  Such third parties will be
independent controllers of your data.  We will only do this when: (i) it is
required for the operation of the event; or (ii) we have your consent; or (iii)
when it is in our, or the third party’s legitimate interests.  If we intend to
share your personal data with third party controllers, we will communicate this
to you at the point at which we collect your personal data so that you can
withhold consent or object to receiving such communications (if applicable).

 6. International Transfers

We share your personal data within the GlobalData Group as set out above. This
will involve transferring your data outside the UK.  GlobalData has a global
workforce with employees located throughout the world.  Employees of GlobalData
Group may be located in territories outside of the UK and may have remote access
to personal data from third countries.  This does not qualify as a restricted
transfer as such employees are not separate controllers, but employees, and thus
an integral part of GlobalData Group.  Therefore, the disclosure is carried out
within the same controller.  The processing, including the remote access and the
processing activities carried out by such employees after the access, are
performed by GlobalData Group, i.e., a controller in a country subject to the UK
GDPR and with an adequacy decision.

Many of our external third parties are based outside the UK so their processing
of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar
degree of protection is afforded to it by ensuring that appropriate safeguards
are implemented.  For example, we will only transfer your personal data to
countries that have been deemed to provide an adequate level of protection for
personal data, where we have adopted standard contractual clauses approved for
use in the UK to safeguard the data, or where a derogation applies (for example,
if you have given consent to the transfer).

 7. Data Security

We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered
or disclosed.  For example, sensitive and private data exchange between the
website and its users happens over an SSL secured communication channel and is
encrypted and protected with digital signatures. Our websites are also in
compliance with PCI vulnerability standards in order to create as secure of an
environment as possible for users.  In addition, we limit access to your
personal data to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal data on
our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.

 8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, regulatory, tax, accounting or reporting requirements. We
may retain your personal data for a longer period in the event of a complaint or
if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.

To determine the appropriate retention period for personal data, we consider the
amount, nature and sensitivity of the personal data, the potential risk of harm
from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal, regulatory, tax, accounting or
other requirements.  For further information, please contact our Data Compliance
Officer using the contact details set out above.

In some circumstances we will anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes, in which
case we may use this information indefinitely without further notice to you.

 9. Your legal rights

If you have given us consent for processing your personal data,  you can
withdraw your consent at any time.  However, this will not affect the lawfulness
of any processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain products or services to you.
We will advise you if this is the case at the time you withdraw your consent.

In addition, under certain circumstances, you have the following rights under
data protection laws in relation to your personal data.

 * Request access to your personal data (commonly known as a “data subject
   access request”). This enables you to receive a copy of the personal data we
   hold about you and to check that we are lawfully processing it.
 * Request correction of your personal data. This enables you to have any
   incomplete or inaccurate data we hold about you corrected, though we may need
   to verify the accuracy of the new data you provide to us.
 * Request erasure of your personal data. This enables you to ask us to delete
   or remove personal data where there is no good reason for us continuing to
   process it. You also have the right to ask us to delete or remove your
   personal data where you have successfully exercised your right to object to
   processing (see below), where we may have processed your information
   unlawfully or where we are required to erase your personal data to comply
   with local law. Note, however, that we may not always be able to comply with
   your request of erasure for specific legal reasons which will be notified to
   you, if applicable, at the time of your request.
 * Object to processing of your personal data where we are relying on a
   legitimate interest (or those of a third party) and there is something about
   your particular situation which makes you want to object to processing on
   this ground as you feel it impacts on your fundamental rights and freedoms.
   You also have the right to object where we are processing your personal data
   for direct marketing purposes. In some cases, we may demonstrate that we have
   compelling legitimate grounds to process your information which override your
   rights and freedoms.
 * Request restriction of processing your personal data. This enables you to ask
   us to suspend the processing of your personal data in the following
   scenarios:
 * If you want us to establish the data’s accuracy.
 * Where our use of the data is unlawful but you do not want us to erase it.
 * Where you need us to hold the data even if we no longer require it as you
   need it to establish, exercise or defend legal claims.
 * You have objected to our use of your data but we need to verify whether we
   have overriding legitimate grounds to use it.
 * Request transfer of your personal data to you or to a third party. We will
   provide to you, or a third party you have chosen, your personal data in a
   structured, commonly used, machine-readable format. Note that this right only
   applies to automated information which you initially provided consent for us
   to use or where we used the information to perform a contract with you.

If you wish to exercise any of the rights set out above, please contact the Data
Compliance Officer at GlobalData, John Carpenter House, John Carpenter Street,
London, EC4Y 0AN, or email datacompliance@globaldata.com.

You also have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK regulator for data protection issues
(www.ico.org.uk) if you have a complaint about the way in which we have handled
your personal data. We would, however, appreciate the chance to deal with your
concerns before you approach the ICO so please contact us in the first instance.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any
of the other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we could refuse to
comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights). This is a security measure to ensure that personal data
is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to
speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it
could take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated.

CCPA Privacy Policy for California Residents

California Consumer Privacy Act (CCPA)

This Privacy Policy for California Residents supplements the information
contained in GlobalData’s Privacy Policy and applies solely to all users of our
service and products who reside in the State of California.  We adopt this
notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any
terms defined in the CCPA have the same meaning when used in this Policy.

The CCPA temporarily exempts personal information reflecting a written or verbal
business-to-business communication (“B2B personal information”) from some its
requirements.  As GlobalData will only process B2B personal information, this
means that it is currently exempt from a number of the CCPA requirements.

GlobalData will not typically process any personal data regarding California
Residents unless transacting with an entity which is located in California.  In
such circumstances, details regarding the personal data we collect, where from,
how we process personal data, who we share it with, and your rights (as required
under CCPA) are included above within GlobalData’s Privacy Policy.

If you are a California Resident, the CCPA prohibits us from reselling your
personal information unless you have received explicit notice and an opportunity
to opt-out of further sales.  You also have the right to direct us to not sell
your personal information at any time (the “right to opt-out”).  To opt-out, you
just need to email us at unsubscribe@globaldata.com.

We will not discriminate against you for exercising any of your CCPA rights.




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