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PRIVACY POLICY

Last Updated: [November 25, 2024]

We, at Dialectica Limited, along with our affiliates (collectively, “Dialectica”
or “we” or “us”) value your privacy. This Privacy Policy sets out how we
collect, use, share and protect personal information obtained from Clients,
Specialists and visitors to our website www.dialecticanet.com, and applies to
said Clients, Specialists and visitors. 

By visiting and using our website in any way, you become subject to the Terms of
Use,  integral Part of which is this Privacy Policy. If you do not agree to this
Privacy Policy, please do not register with us or use the Dialectica website or
the services provided through it. 

Dialectica Limited is a company registered in England and Wales (company number
9605745). Dialectica is the “Data Controller” as this term is defined in the
General Data Protection Regulation (GDPR) and the UK Data protection Act and
relevant legislation, for personal information collected from European Economic
Area (“EEA”) and United Kingdom (“UK”) residents. For the purposes of this
Privacy Policy, the terms “personal information” and “personal data” are used
interchangeably and mean any information relating to an identified or
identifiable individual.

1. Scope

This Privacy Policy applies to users of Dialectica’s services anywhere in the
world, including Clients, Specialists and visitors to our website
www.dialecticanet.com. In addition, this Privacy Policy is in accordance with
the General Data Protection Regulation (GDPR) (2018), the Data Protection Act
(2018), the UK-GDPR, the Personal Information Protection and Electronic
Documents Act (PIPEDA) (2004) and any other data protection regulations
applicable to states in which the Company operates.

2. Our key data processing principles

We are committed to ensuring that your personal data are processed in a fair and
transparent way, in compliance with the applicable legal framework, as described
above.  Specifically:

 * We process your data only for specified, explicit and legitimate purposes, as
   defined in this policy. We do not further process your data for purposes
   incompatible to the original ones (purpose limitation).
 * We only process data which are adequate, relevant and limited to what is
   necessary in relation to the purposes that we have set (data minimisation).
 * We make every effort to ensure that your data are accurate and that you can
   ask for their correction or deletion where applicable (data accuracy).
 * We keep your data in a form which permits your identification only for as
   long as it is necessary for the purposes that we have determined in advance,
   as described in this policy (storage limitation).
 * We make every effort to ensure the security of your data, and to prevent,
   among others, any unauthorized or unlawful processing, and accidental loss,
   destruction or damage (integrity and confidentiality).

 

To ensure the adequate protection of your data, Dialectica implements internal
security policies, takes appropriate technical and organizational measures
designed to protect the personal information in our systems and trains its staff
regularly, which is bound by confidentiality and privacy clauses. Following the
ISO 27001 standards, we use technologies which maximize the security of your
data, e.g. Encryption in Transit and at Rest, Backup Policies, Password Policy,
Physical Security Controls etc.

Our goal is to integrate information security and data protection principles in
all aspects of the Company’s operation. In this context, we monitor the security
measures on a regular basis and, if deemed necessary, we align them with the new
best practices.

3. How we collect the data 

a. Directly from you

We collect information directly from you when:

 * You submit your information to become a client of Dialectica
 * You submit your information to become an expert with Dialectica and join our
   network of specialists. 
 * You interact with Dialectica either as a client, an expert or an
   employee/candidate, in the ordinary course of our business relationship with
   you. Please note that experts who agree to work with Dialectica and its
   clients are subject to the Terms of Engagement and the applicable data
   protection clauses included therein.
 * You communicate with us via any means (email, telephone, website “contact us”
   form etc).

 

Candidates applying for a job opening at Dialectica are subject to our
Recruiting Policy.

b. Automatically from Your Use of our website 

When you use the Dialectica website, we may collect data from you based on your
browsing and using our services. This data may include search history, IP
address, screen resolution, type of browser used, operating system and settings,
access times and URL reference, cookie data, and other website usage
information.

c. From Third Parties. 

Dialectica may also collect data (especially on experts) from third parties and
publicly available sources. Such data mainly constitute business contact
information, business expertise and qualifications, and may be collected, for
instance, from professional/ business websites, business registries,
Specialists’ publications or other business information they have made publicly
available about themselves, research conducted internally by Dialectica (e.g. on
LinkedIn) and other companies and data partners that license information to
us. In the latter case Dialectica has partnered with reputable third parties,
data or marketing partners, after a careful evaluation of such partner’s
credentials and assurances as to the lawfulness of the data collection
processes.

4. What personal data do we process? 

4.1. The personal data we process varies depending on the nature of your
interaction with Dialectica.

In general, when using our service, we collect the following information: 

 * Identifying and business contact information such as your name, mailing
   address, email address, phone number;
 * Profile data including your username and password, comments, feedback and
   survey responses;
 * Financial data such as payment information (e.g. VAT orTax ID information);
 * Other details/information you provide to us in connection with the services
   offered by Dialectica or in the course of your communication with us;
 * Cookies and similar technologies. We use cookies and other similar
   technologies. For more information on our use of these technologies, see our
   Cookie Policy;
 * Information contained in any communications that you send to us by email or
   through our website contact form including the communication content and
   metadata;
 * Data collected automatically from your use of our website such as search
   history, IP address, screen resolution, type of browser used, operating
   system and settings, access times and URL reference, cookie data, and other
   website usage information.

 

4.2. In addition, we may collect the following information for: 

Specialists 

Specialists registering with Dialectica are required to provide personal
information including name, address, and other contact information, as well as
detailed information in respect of their academic and professional background
and employment history. Specialists will also be required to provide their
payment information so that they can be compensated following a consultation.
Furthermore, we may also collect data from publicly available sources and our
partners concerning your business contact information and professional
background and relevant qualifications.

Clients 

When a client wishes to enquire or register with us, we will collect their
contact details (e.g. name, address, title and position) as well as a brief
description of the client’s business. 

Job Applicants

If you apply for a job opening, we collect and process personal information as
described in our Recruiting Policy.

4.3. Special Category Personal Data

Dialectica does not intend to collect any special category personal data about
you (this includes details about your religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership, and
information concerning your health and genetic and biometric data). Kindly
abstain from sharing any Special Categories of Personal Data with us.

5. Purposes: Why and How We Use Your Data?

We may use the information we obtain for the following purposes:

a. To Provide Our Services

 * Operate, maintain and improve our website; 
 * Communicate with you, provide you with updates and other information relating
   to our services, provide information that you request, respond to comments
   and questions, and otherwise provide support; 
 * Use Specialists’ information to facilitate their participation in projects; 
 * Identify Projects which may be within the field of expertise and of interest
   to a Specialist; 
 * Identify the most suitable Specialists for a Client’s project; 
 * Properly inform Clients who may wish to consult with a Specialist;
 * Process payments; 
 * Perform necessary operations to maintain our services, including software
   maintenance and fixing operational problems.

 

b. To Market, Improve our Services, and other Legitimate Business Interests 

 * Provide Specialists’ professional expertise to prospective clients to
   demonstrate the quality and coverage of our specialist network; 
 * Identify events, actual and potential projects of interest to Clients; 
 * Understand and analyze how you use our services, improve and develop new
   products and services; 
 * Communicate about new services or other information which we think you may
   find interesting; 
 * Operate, evaluate and improve our business; 
 * Anonymize information collected through our services and use it for our
   business purposes; 
 * For other purposes for which we provide specific notice at the time the
   personal information is collected. 

 

c. To Comply with Applicable Law 

 * Protect against any prohibited or illegal activity, claims and other
   liabilities;
 * Enforce our legal rights; 
 * Comply with applicable legal requirements and internal policies; 
 * Establish, exercise and defend a legal claim.

 

6. Legal Bases for Data Processing (EU, EEA and UK Data Subjects)

If you are located in the EEA or the UK, we only process your personal data
under certain legal bases:

 * Contractual necessity: processing is necessary for the performance of a
   contract to which the data subject is party or in order to take steps at the
   request of the data subject prior to entering into a contract. We need your
   personal data/information to provide you with the services you have
   requested, or to respond to your inquiries;
 * Consent. You have consented to the use of your personal information, for
   example to use non-essential cookies;
 * Compliance with law: processing is necessary for compliance with a legal
   obligation to which the controller is subject. We have a legal obligation to
   use your personal data, for example to comply with our tax and accounting
   obligations;
 * Legitimate interests: processing is necessary for the purposes of the
   legitimate interests pursued by the controller or by a third party. We or a
   third party have a legitimate interest in using your personal information,
   such for monitoring and conducting analytics on website/platform use,
   pages/links clicked, traffic demographics, patterns of navigation, on
   potential security matters, on performance issues, as well as for product
   development and internal analytics purposes, and otherwise to improve the
   safety, security and performance of our services. We only rely on our (or a
   third party’s) legitimate interests to process your personal information when
   these interests are not overridden by your rights and interests. In specific
   cases, the applicable Legitimate Interest Assessments have been conducted.

 

Please be advised that we may process your personal data for more than one legal
basis, depending on the specific purpose for which we are using your data.
Please contact us at compliance@dialecticanet.com*protected email* if you need
details about the specific legal basis we are relying on to process your
personal data.

7. Who has Access to your Data?

We may disclose your personal data to any of our employees, officers, insurers,
professional advisers, agents, suppliers, or subcontractors as reasonably
necessary for the purposes set out in this policy. Specifically:

 * Dialectica’s Employees. We may share your personal information with any
   member of our organization who reasonably needs access to personal data to
   achieve the purposes set out in this Privacy Policy.
 * Affiliates. We may share your personal information with our affiliates for
   any of the purposes described in this Privacy Policy.
 * Vendors and Service Providers. We may share any personal information we
   receive by our service providers and share within Dialectica for any of the
   purposes described in this Privacy Policy. Such third-parties may, for
   instance, provide support services such as: 
   * customer support;
   * market research;
   * fraud detection and prevention services, including anti-fraud screening
     service.;
   * internet services, internet service providers, cloud storage providers and
     e-commerce providers, technical support 
   * marketing services. – For more information on personalized advertisements
     and your choices, also review our Cookie policy.
 * Clients. Dialectica may share your information with our Clients, typically in
   connection with consulting opportunities. 
 * Analytics Partners. We use analytics services such as Google Analytics to
   collect and process certain analytics data. You can learn about Google’s
   practices by going to https://www.google.com/policies/privacy/partners/ and
   opt-out of them by downloading the Google Analytics opt-out browser add-on,
   available at https://tools.google.com/dlpage/gaoptout. 
 * Compliance with law. Dialectica may disclose the fact that you are a
   Specialist and information collected about you in response to a valid order
   or request by a court or other governmental body, to enforce an agreement
   between you and Dialectica or one of Dialectica’s Clients, to protect
   Dialectica’s rights, or as otherwise required or permitted by law, legal
   process or for the prevention or detection of a crime.
 * Merger, Sale, or Other Asset Transfers. Dialectica may disclose personal
   information to service providers, advisors, audit companies, potential
   transactional partners, or other third parties in connection with the
   consideration, negotiation, or completion of a corporate transaction in which
   we are acquired by or merged with another company or we sell, liquidate, or
   transfer all or a portion of our business or assets.

 

Please note that any third party with whom Dialectica collaborates, complies
with the terms of personal data processing under GDPR (see below under 11). In
addition, Dialectica and the data processors acting on behalf of Dialectica, are
committed to keeping the confidentiality of the processed personal data and not
to disclose or allow access to any third party without the prior notification of
the data subject except for in cases explicitly provided by law.  The data
processors acting on behalf of Dialectica are contractually bound to comply with
the legal obligations on the personal data processing, apply the appropriate
technical and organizational measures for the best possible protection of the
personal data against any incidental or illegal destruction, damage or loss,
alteration, or unauthorized access and in general unlawful processing of data.
These measures aim to ensure and to demonstrate that processing is performed in
accordance with the applicable data protection regime [including GDPR, Data
Protection Act (2018), the UK-GDPR, the Personal Information Protection and
Electronic Documents Act (PIPEDA) (2004)] taking into account the nature, scope,
context and purposes of processing as well as the risks of varying likelihood
and severity for the rights and freedoms of natural persons.

8. Data Transfers

Dialectica operates and processes personal data globally. Personal data provided
to Dialectica will be held by us inside the EEA or the UK and will be accessed
by our staff and third parties working for us for the purposes set forth in this
policy or for other purposes subject to your approval. Your personal information
may also be held, processed and accessed outside the EEA or the UK to countries
that have not been determined by the European Commission or the UK government to
provide an adequate level of data protection. In any such transfer, Dialectica
will ensure that appropriate data protection safeguards (e.g. European
Commission’s Standard Contractual Clauses or UK addendum to the Standard
Contractual Clauses) are in place and will perform the necessary Transfer Impact
Assessments (TIAs) where applicable. 

To obtain a copy of the relevant transfer mechanism or additional information on
the transfers, please contact us using the contact information below. Please
note that when personal information is transferred to certain countries, law
enforcement and regulatory agencies, including national security authorities, of
these countries may be able to access such information in accordance with the
laws of those countries.

9. Your Rights

Dialectica takes reasonable steps to ensure that your personal data is kept
accurate and up-to-date and that the personal data that is processed is limited
to the reasonably necessary in connection with the purposes set out in this
Privacy Policy. 

You have the following rights in connection with your data:

 1. To request access to your personal data that we hold. You may request a copy
    of your personal data and we shall provide it to you free of charge. Should
    you request any further copies, we may charge a reasonable fee based on
    administrative costs
 2. To request that we rectify any inaccurate personal data about you and,
    taking into account the purposes of the processing, to have any incomplete
    personal data about you completed. In any case, please note that when you
    provide to us your personal data guarantee that they are true and accurate
    and you undertake to notify us of any change or modification of your data. 
 3. To request that we erase your entire personal data to the extent that they
    are no longer necessary for the purpose for which we need to keep processing
    them, or when we are no longer legally permitted to process them. Please be
    advised that, in such cases, we will retain only non-personal data (e.g.
    anonymized, statistical data) and information for statistical and technical
    reasons. Also, in case you decide to delete your account, we will retain
    email information, in a secure manner, for new account-verification
    purposes. Also, we shall retain some “Payment Information”, if such apply in
    your case, for as long as we are obliged by the applied tax law or/and our
    contractual obligations with our service providers. In addition, Specialists
    must be aware that any data they request to be erased will be erased from
    Dialectica’s database effective as of the time of the request’s
    acceptance.  
 4. To request that we cancel or limit the processing of your personal data,
    which entails that in certain cases you can request us to temporarily
    suspend the processing of the data or that we keep them longer than
    necessary. 
 5. Where the processing of your data is based on our legitimate interest, you
    will also have the right to object to the processing of your data.
 6. To request that we transfer the information you gave us from one
    organization to another, or give it to you (Data Portability). The right
    only applies to information you have given us, if we are processing
    information based on your consent or under, or in talks about entering into
    a contract and the processing is automated. 
 7. To the extent that the legal basis for our processing of your personal
    information is consent, you have the right to withdraw that consent at any
    time. Withdrawal will not affect the lawfulness of processing before the
    withdrawal. You must be aware that consent withdrawal does not affect the
    lawfulness of processing prior to such withdrawal. 
 8. You may instruct us at any time not to process your personal information for
    marketing purposes.
 9. Right to File Complaint: You have the right to lodge a complaint with the
    competent Supervisory Authority of your country or EU Member State, such as
    the Information Commissioner’s Office (ICO) for the UK. 

 

Please note that in order to respond to any of the above we may require
information to confirm the individual’s identity. We may withhold personal
information that you request to the extent permitted by law.

Please contact us at compliance@dialecticanet.com*protected email* if you wish
to exercise any of these rights. In certain situations, and subject to
applicable law, we may not be able or obliged to grant part or all of your
individual requests.

Please note that any changes made in user databases will be reflected instantly
or within a reasonable period of time. We may retain some information for
backups, archiving, prevention of fraud and abuse, analytics, satisfaction of
legal obligations, or where we otherwise reasonably believe that we have a
legitimate reason to do so. We also have the right to refuse and/or charge a
monetary fee for requests which are manifestly unfounded or excessive, for
example because of their repetitive character. Dialectica tries to respond to
all legitimate requests as soon as possible (within 1 month upon its receipt).
If we require more time (for a maximum total of two additional months), we will
inform you of the reason and extension period in writing.

10. CalOPPA – Do Not Track Clause

Dialectica does not track its users over time and across third party websites to
provide targeted advertising and therefore does not respond to Do Not Track
(DNT) signals.

11. Information & Data Security

In order to prevent unauthorized access, disclosure or other unlawful
processing, we have put in place physical, electronic and managerial procedures
designed to safeguard and secure the information we collect online. Your data is
stored in secure networks and is only accessible by a limited number of persons
who have special access rights to such systems and are bound by a duty of
confidentiality. Only authorized personnel are permitted to access personal data
in the course of their work. 

We cannot, however, guarantee the security of our servers or transmissions
between our servers and your computer. Accordingly, all information which you
provide to us is supplied at your own risk. Please help us keep your information
secure by keeping your password and other account details confidential.

12. Retention Policy

We will retain your information for so long as necessary for the purposes for
which they were collected. We will also retain your information as required
under applicable retention policies or as permitted by applicable law. When
determining the specific retention period, we take into account various
criteria, such as the type of service provided to you, the nature and length of
our relationship with you, and mandatory retention periods. In general, we
retain Personal Data:

 1. for as long as you have an active account with us or as otherwise necessary
    to provide you with the Service. When you choose to discontinue/delete your
    account, we delete all personal data with the exception of personal data
    required to be retained by law (for instance in order to comply with tax
    legislation), to comply with any ongoing or prospective legal proceedings;
    and required to establish, exercise, or defend our legal rights, property or
    personal safety of Dialectica, its users and the public.
 2. until you withdraw your consent where processing is based on consent.
 3. to the extent that is necessary to comply with our legal obligations,
    resolve disputes or collect fees owed, or is otherwise permitted or required
    by applicable law, rule or regulation.

 

After the expiry of the retention period, we retain some information in an
anonymized or aggregated form but not in a way that would identify you
personally.

Nevertheless, some personal data relating to the data subjects’ transactions
with Dialectica as well as the information on notification, consent and
withdrawal of consent, where it is applicable, may be retained as necessary
information in order to enable us to establish lawfulness of the data subject’s
data processing by Dialectica and for ensuring the legal claims of the parties.

If you have a question about a specific retention period for certain types of
personal data we process about you, please contact us using the contact
information provided below.

13. Third Party Links

Our services may contain links to other websites, products, or services that we
do not own or operate. We are not responsible for the privacy practices of these
third parties. Please be aware that this Privacy Policy does not apply to your
activities on these third-party services or any personal information you
disclose to these third parties. We encourage you to read their privacy policies
before providing any personal information to them.

14. Children’s Privacy

We do not knowingly collect, maintain or use personal information from persons
under 18 years old (“minors”), and no part of our services is directed to
children. If you learn that a minor has provided us with personal information in
violation of this Privacy Policy, please contact us immediately.

15. Updates To Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you
to reflect changes in our personal information practices. We will post a
prominent notice on our website to notify you of any significant changes to our
Privacy Policy and indicate when it was most recently updated. You should also
check this page from time to time to ensure that you are happy with any changes.

16. How To Contact Us

We welcome all requests, suggestions and questions concerning our use of your
information. All such communication should be directed
to compliance@dialecticanet.com*protected email*, or call us at +44 203 637
2934, or write to us at: 28 Margaret St, London, W1W 8RZ, United Kingdom.

Dialectica is an information services company that brings unique, real-time
insights to the world’s top business professionals with the vision to shape
better decision making worldwide.
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