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Monday, August 12, 2024

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SDXCENTRAL PRIVACY POLICY

Last updated: November 28, 2021

SDxCentral, LLC (“SDxCentral”) provides this Privacy Policy, as well as our
Cookie Policy, to make you aware of our privacy practices and the choices you
can make about how your information is collected and used throughout our digital
properties and content (collectively, “Services”).

We recognize that building a long-term business relationship with you depends a
great deal on trust. This trust begins with disclosing our privacy practices as
well as our commitment to respecting your Privacy Policy. To make this policy
easy to access, it is available on the bottom of every SDxCentral.com web page.

Throughout this Privacy Policy and our Cookie Policy, Personal Information or
Personal Data refers to any information that is unique to an individual, such as
name, address, e-mail address, phone number, IP address and other information
that can reasonably identify an individual.

SDxCentral is a B2B tech media and martech company. As such, we provide our own
content, but also feature content from our corporate customers (“Customers”) as
well as links to our Customers’ websites. This Privacy Policy covers how we
collect, handle and disclose Personal Data on our Services through native or
sponsored content. It does not cover how our Customers may collect, handle and
disclose Personal Data when you click on one of their sponsored links and leave
our website.

IF YOU ARE AN INDIVIDUAL LOCATED IN THE EEA OR THE U.K.: If you are located in
the European Economic Area (“EEA”) or the United Kingdom (“U.K.”), this entire
Privacy Policy applies to you. However, please see the Section titled Additional
Information for Users in the EEA and U.K. below, which will provide more detail
information about which rights you have regarding the processing of your
Personal Data.

Questions about our privacy practices can be submitted by contacting us at:
legal@sdxcentral.com


TABLE OF CONTENTS

WHO WE ARE & HOW TO CONTACT US

CHANGES TO THIS PRIVACY POLICY

WHAT WE COLLECT

HOW WE USE YOUR INFORMATION

TAILORING E-MAIL COMMUNICATIONS AND WEB EXPERIENCES

SPONSORED LINKS

ADVERTISING

DO NOT TRACK SIGNALS

DISCLOSURE TO THIRD PARTIES

CHILDREN’S ONLINE PRIVACY PROTECTION

PAYMENT PROCESSING

CHOICES

ACCESS AND ACCURACY

SECURITY AND RETENTION

ONWARD TRANSFERS

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA AND U.K.

SdxCentral as Data Controller or Data Processor


WHO WE ARE & HOW TO CONTACT US

SDxCentral, LLC is a California corporation with the following contact
information:

3511 Ringsby Court, Unit 101
Denver, CO 80216

(408)-740-3131

legal@sdxcentral.com

For users in the EEA and the U.K., we may collect your Personal Data as a ‘data
controller’ when we determine the means and purpose of processing, or as a ‘data
processor’ when we collect and process Personal Data on behalf of our Customers
who provide us with sponsored content. In some cases, such as when you click on
sponsored links from our Customers, we and our Customers are each independent
data controllers. Please see the section “Additional Information for Users in
the EEA and U.K.” for more information.


CHANGES TO THIS PRIVACY POLICY

SDxCentral may update this Privacy Policy from time to time. When we change the
Privacy Policy in a material way, a notice will be posted on our website along
with a link to the updated Privacy Policy and/or through another reasonable
means of communication. Visitors and users are bound by any changes to the
Privacy Policy when they visit or use the website after such notice has been
provided.


WHAT WE COLLECT


INFORMATION WE COLLECT DIRECTLY FROM YOU:

Information may be submitted by users of our Services or our Customers’
employees. Generally, we collect Personal Information when you submit it to us,
such as when you:

 * Register for or subscribe to certain products or services
 * Consume sponsored content as a requirement for a sponsored program
 * Contact customer service
 * Register your organization as a customer of SDxCentral.

The Personal Data you submit includes your:

 * Name (first and last)
 * Job title and role
 * Company
 * Address (zip code, city/state, country)
 * Telephone number
 * Email address (personal or professional)
 * Salutation
 * Username
 * Password

If you are signed up as a user, in order to tailor our subsequent communications
to you and improve our products and services, we may also ask you to provide
information regarding your personal or professional interests, industry,
organization sector, demographics, and/or experience with our products and
contact preferences.

Personal Information may be required to determine access eligibility for certain
restricted parts of our website. Data collected online may be combined with
information provided offline.


INFORMATION WE COLLECT INDIRECTLY

We, or authorized third parties, may also collect information automatically when
you browse our Services, read an article or click on a link. For example, we may
collect IP addresses and browser type via automated technologies such as cookies
or similar technologies. Please visit our for more information.

We also collect information on which articles, webinars, slides, videos,
podcasts, whitepapers, eBriefs, guides and other content have been viewed. We
may analyze this data for trends and statistics in the aggregate, and we may use
such aggregate information to administer the website and gather broad
demographic information for aggregate use. Note that we associate this aggregate
data with a numerical identifier and not your name, so that it is pseudonymized.

We may also receive Personal Information from third parties. For instance, our
email marketing providers, such as Sendgrid, may also provide your IP, country,
city and state to us when you open an email.


HOW WE USE YOUR INFORMATION

We may use your Personal Information for a number of different reasons, as
further explained below. In addition, for users located in the EEA and the U.K.,
we must have a valid legal basis in order to process your Personal Information.
The chief legal bases under the European Union’s General Data Protection
Regulation (GDPR) that justify our collection and use of your Personal
Information are:

 * Performance of a contract: when your Personal Information is necessary to
   enter into or perform our contract with you.
 * Consent: when you have consented to our use of your Personal Information via
   a consent form (online or offline).
 * Legitimate interests: when we use your Personal Information to achieve a
   legitimate interest and our reasons for using it outweigh any prejudice to
   your data protection rights.
 * Legal obligation: when we need to use your Personal Information to comply
   with our legal obligations.
 * Legal claims: when your Personal Information is necessary for us to defend,
   prosecute or make a claim.

Below are the general purposes (and corresponding legal bases in brackets for
users in the EEA and U.K.) for which we may use your Personal Information.

 * To provide and register you on the Services, such as to complete transactions
   [performance of a contract or legitimate interests]
 * To manage our relationship with you, including to notify you about changes to
   our terms or Privacy Policy, provide you with customer support, and/or remind
   you of scheduled webinars [performance of a contract, legitimate interests,
   and in some cases, legal claims]
 * To send you the newsletter(s) to which you have subscribed [performance of a
   contract]
 * To respond to your inquiries, including to investigate and address your
   concerns and monitor and improve our responses [performance of a contract or
   legitimate interests]
 * To help maintain the safety, security, and integrity of our Services,
   databases and other technology assets, and business [legitimate interests,
   and in some cases, legal claims]
 * To provide our Services to our Customers [legitimate interests and
   performance of a contract]
 * For testing, research and analysis, including to develop and improve our
   Services [legitimate interests and consent for analytics]
 * To advertise our Services [consent for tracking]
 * For internal analytics and in order to inform our Customers of trends and
   statistics [legitimate interests and consent for analytics]
 * To personalize your experience and to deliver content and offerings relevant
   to your interests, including to provide you with marketing information we
   think would be of particular interest [legitimate interests or consent where
   required]
 * To evaluate or conduct a merger, divestiture, restructuring, reorganization,
   dissolution, or other sale or transfer of some or all of our assets, whether
   as a going concern or as part of bankruptcy, liquidation, or similar
   proceeding, in which Personal Information held by SDxCentral is among the
   assets transferred [legitimate interests]
 * To respond to law enforcement requests and as required by applicable law,
   court order, or governmental regulations [legal obligation]
 * To prevent and detect fraud and unlawful acts [legitimate interests, and in
   some cases, legal obligation].


TAILORING E-MAIL COMMUNICATIONS AND WEB EXPERIENCES

On occasion SDxCentral may employ technologies that enable us to review which
recipients have opened our e-mail communications and which links they have
accessed in the message. This helps us to tailor our communications in our
attempts to send you the most relevant information, as local laws and your
preferences and permissions allow. As a registered user, we may also monitor
your web browsing session while you are logged-in to SDxCentral.com. In this
way, we will try to improve our website through personalization to better meet
your needs. We do this in order to improve our Services and provide more
tailored services to our Customers.


SPONSORED LINKS

Most of the content on our website (“Site”) is native content created and
provided by our journalists. However, we also provide sponsored links to
websites hosted by our Customers.

If you click on these links, you will leave our Services. SDxCentral does not
control and is not responsible for any of these Customer websites, their content
or their data collection practices. We do not endorse or make any
representations about them, or any information, software or other products or
materials found there, or any results that may be obtained from using them. In
addition, Customers, as independent controllers, are solely responsible for
informing you of their data collection practices once you click on a link that
takes you to their websites.

In addition, Customers may receive information when you click on links to their
websites via our Advertising Partners (described below). Our Cookie Policy
contains more details about our practices.


ADVERTISING

SDxCentral, as a data controller, partners with third-party advertisers, ad
server companies, and ad networks (“Advertising Partners”) to promote Services.

What does this mean? When you visit our Site, Advertising Partners may drop
cookies (or similar tracking technologies) and capture and collect the
information described above so that they can track your activity on the Site –
unless you are in the EEA or the U.K. and have not opted in, or have blocked
cookies as described below and in our Cookie Policy. This information may be
combined with other information from other sources, and used to deliver targeted
advertising on other websites.

Please visit our for more information on the types of cookies that are used by
us and our Advertising Partners on our Site, as well as your choices.

Your choices: For more information about online advertising and your choices,
please visit https://youradchoices.com/. In addition, we and our Advertising
Partners endeavor in good faith to adhere to self-regulatory advertising
principles, such as the Digital Advertising Alliance’s Principles (“DAA”) or the
Network Advertising Initiative (“NAI”). If you are interested in learning more
about and/or opting out of online behavioral advertising, sometimes called
interest-based advertising, we encourage you to visit one of the advertising
industry-developed opt-out pages:

 * Network Advertising Initiative
 * DAA
 * EDAA

Please note that while we provide these links for your convenience, we do not
have access to, or control over, these third parties’ use of cookies or other
tracking technologies.

If you do not wish to receive personalized ads, please visit the opt-out pages
at the above links to learn about how you may opt-out of receiving personalized
ads from member companies.

You can also change your privacy settings in your device settings and implement
limited ad tracking.

NOTE: In order to disable advertising-related tracking at your request,
companies may need to set an opt-out cookie on your browser. Sometimes a
browser’s configuration may prevent companies from setting such cookies, for
example, if your browser is set to block all third-party cookies by default.
Therefore, you may need to change your browser settings to accept cookies, in
order to fully disable advertising-related tracking.


DO NOT TRACK SIGNALS

We currently do not follow do not track signals from your browser.


DISCLOSURE TO THIRD PARTIES

We disclose your Personal Information as explained below.


THIRD-PARTIES

SDxCentral may share users’ information with our third-party agents,
contractors, or service providers who are hired to perform services on
SDxCentral’s behalf. These companies do things to help us provide the Services.
In some cases, these companies collect Personal Information directly from you.
Below is an illustrative list of third parties who help us get things done:

 * Hosting and content delivery network services
 * Customer support services
 * Analytics services
 * Advertising services
 * Billing services and payment gateway providers
 * With your consent, we share Personal Information with the sponsors and
   contributors to the SDxCentral webinars, slides, videos, podcasts, and PDFs
   such as our advertising and promotion clients, for their own marketing
   purposes
 * Professional service providers, such as auditors, lawyers, consultants,
   accountants and insurers


SDXCENTRAL CUSTOMERS

When we act on behalf of our Customers as a data processor, with your consent,
we may provide your Personal Information to such Customers. In some cases, we
will only provide aggregated information that does not identify you, in order to
provide information about trends, demographics (such as location) and
organizations that may be interested in their content.


BUSINESS TRANSFERS

As we continue to grow, we may purchase websites, applications, subsidiaries,
other businesses or business units. Alternatively, we may sell businesses or
business units, merge with other entities and/or sell assets or stock, in some
cases as part of a reorganization or liquidation in bankruptcy. As part of these
transactions, we may transfer your Personal Information to a successor entity
upon a merger, consolidation or other corporate reorganization in which
SDxCentral participates, or to a purchaser or acquirer of all or a portion of
SDxCentral’s assets, bankruptcy included.


LEGAL OBLIGATIONS AND SECURITY

SDxCentral may preserve or disclose your Personal Information in limited
circumstances (other than as set forth in this Privacy Notice), including: (i)
with your consent; (ii) when we have a good faith belief it is required by law,
such as pursuant to a subpoena, warrant or other judicial or administrative
order (as further explained below); (iii) to protect the safety of any person;
to protect the safety or security of our Services or to prevent spam, abuse, or
other malicious activity of actors with respect to the Services; or (iv) to
protect our rights or property or the rights or property of those who use the
Services.

If we are required to disclose Personal Information by law, such as pursuant to
a subpoena, warrant or other judicial or administrative order, our policy is to
respond to requests that are properly issued by law enforcement within the
United States or via mutual legal assistance mechanism (such as a treaty).


CHILDREN’S ONLINE PRIVACY PROTECTION

SDxCentral does not target its website to minors. SDxCentral’s website is not
directed to children under the age of 16. SDxCentral does not knowingly collect
Personal Information from children under the age of 16. If we learn that a child
under the age of 16, provided us with Personal Information, we will delete that
information.


PAYMENT PROCESSING

SDxCentral does not directly collect payment information. We use third-party
payment processors to process all payments in accordance with Payment Card
Industry (PCI) data security standards.


CHOICES

SDxCentral will not use or share your Personal Information in ways unrelated to
the ones described above without first notifying you and offering a choice. We
will also provide you the opportunity to let us know if you wish to opt-out at
any time of certain or all contact from SDxCentral, and we will use reasonable
efforts to honor such requests. You can access, review, correct, update, delete
or modify your registration or subscription profile information and modify your
communication preferences by visiting the relevant account management sections
of our Services.


ACCESS AND ACCURACY

SDxCentral uses reasonable efforts to keep your Personal Information accurate.
We will provide you with online access to your Personal Information so that you
may review, update or correct Personal Information that we hold.

Note that in order to protect your privacy and security, we will also take
reasonable steps to verify your identity before granting you access or enabling
you to make corrections. To access your Personal Information, please visit the
relevant account management sections of our Services. If you cannot access your
Personal Information on the Services, please submit a request for support here.


SECURITY AND RETENTION


SECURITY

No method of transmission over the Internet or method of electronic storage is
100% secure, however we take steps that are reasonably necessary to securely
provide our Services. We have put in place reasonably appropriate security
measures designed to prevent your Personal Information from being accidentally
lost, used or accessed in an unauthorized way, altered or disclosed. We limit
access to Personal Information only to those employees, agents, contractors and
the third parties who have a business need-to-know.

We also have procedures in place to deal with any suspected data security
breach. If required, we will notify you and any applicable regulator of a
suspected data security breach. We also require those parties to whom we
transfer your Personal Information to provide acceptable standards of security.


DATA RETENTION

General Retention Periods

We use the following criteria to determine our retention periods: the amount,
nature and sensitivity of your information, the reasons for which we collect and
process your Personal Information, the length of time we have an ongoing
relationship with you and provide you with access to our Services, and
applicable legal requirements. We will retain Personal Information we collect
from you where we have an ongoing legitimate business need to do so (for
example, to comply with applicable legal, tax or accounting requirements), when
we are unable to reasonably verify your identity, or as may otherwise be
required under applicable laws.

Additionally, we cannot delete information when it is needed for the
establishment, exercise or defense of legal claims (also known as a “litigation
hold”). In this case, the information must be retained as long as needed for
exercising respective potential legal claims.

When we have no ongoing business need to process your Personal Information, we
will either delete or anonymize it or, if this is not possible (for example,
because your Personal Information has been stored in backup archives), we will
securely store your Personal Information and isolate it from any further
processing until deletion is possible.

Time Frame of Deletion

If Personal Data can no longer be retained or is no longer necessary, it will be
erased without undue delay.

Anonymization

In some instances, we may choose to anonymize your Personal Information instead
of deleting it, for statistical use, for instance. When we choose to anonymize,
we make sure that there is no way that the Personal Information can be linked
back to you or any specific user.


ONWARD TRANSFERS

We are located in the United States, and the Personal Information that we
collect is stored on servers located in the United States. This means that your
Personal Information will be collected, processed and stored in the United
States.

We have implemented safeguards designed to ensure that the Personal Information
we process remains protected in accordance with this Privacy Policy, including
when processed internationally or by our third-party service providers and
partners.

 


ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA AND U.K.

If the GDPR applies to you because you are in the EEA or the U.K., please read
this section for more information.


SDXCENTRAL AS DATA CONTROLLER OR DATA PROCESSOR

In some instances, SDxCentral acts as a ‘data controller’ of the Personal Data
it collects from you, namely when it determines the means and purposes of the
processing. This includes information that you submit when signing up for the
Services, or the Personal Data that we collect via cookies, or when you opt-in.
Our processing of such Personal Data is subject to this Privacy Policy (and
Cookie Policy).

In other instances, SDxCentral acts as the ‘data processor’, namely when it acts
on behalf of its Customers, who are the data controllers with respect to content
such as white papers that you can access via the Services.

Finally, when SdxCentral enables sponsored links to Customers’ websites, each
party acts as an independent data controller, in which case your Personal Data
is governed by each party’s respective privacy and cookie policies.


STAYING IN CONTROL OF YOUR INFORMATION: YOUR RIGHTS

Your Rights

Individuals in the EEA and U.K. have certain rights in relation to their
Personal Data:

 * The right to be informed – our obligation to inform you that we process your
   Personal Data (and that’s what we’re doing in this Privacy Policy);
 * The right of access – your right to request a copy of the Personal Data we
   hold about you (also known as a ‘data subject access request’);
 * The right to rectification – your right to request that we correct Personal
   Data about you if it is incomplete or inaccurate (though we generally
   recommend first making any changes in your Account Settings);
 * The right to erasure (also known as the ‘right to be forgotten’) – under
   certain circumstances, you may ask us to delete the Personal Data we have
   about you (unless there’s an overriding legal reason we need to keep it);
 * The right to restrict processing – your right, under certain circumstances,
   to ask us to suspend our processing of your Personal Data;
 * The right to data portability – your right to ask us for a copy of your
   Personal Data in a common format (for example, a .csv file);
 * The right to object – your right to object to us processing your Personal
   Data (for example, if you object to us processing your data for direct
   marketing); and
 * Rights in relation to automated decision-making and profiling – our
   obligation to be transparent about any profiling we do, or any automated
   decision-making.

These rights are subject to certain rules around when you can exercise them. If
are located in the EEA or the U.K. and wish to exercise any of the rights set
out above, please contact us (see Who We Are & How to Contact Us).

Exercising Your Rights

You will not have to pay a fee to access your Personal Data (or to exercise any
of the other rights) unless your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request under those
circumstances.

We may need to request specific information from you to help us confirm your
identity. This is a security measure to ensure that Personal Data is not
disclosed to any person who has no right to receive it. Note that if we are
unable to reasonably confirm your identity, we will not be able to honor certain
requests.

We will respond to all legitimate requests within one month. Occasionally it may
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
as required by law.

In addition, if you no longer wish to receive our marketing/promotional
information, we remind you that you may withdraw your consent to direct
marketing at any time directly from the unsubscribe link included in each
electronic marketing message we send to you. If you do so, we will promptly
update our databases, and will take all reasonable steps to meet your request at
the earliest possible opportunity, but we may continue to contact you to the
extent necessary for the purposes of providing our Services.

You have the right to make a complaint at any time to the supervisory authority
for data protection issues in your country of residence.

Finally, if you send us a data subject request that relates to our processing
activities when we act as a data processor on behalf of our Customers, or when
Customers directly collect your Personal Data after you’ve clicked on their
sponsored links, we will endeavor to inform the Customer of your requests and
assist as may be required, but SDxCentral is not responsible for responding to
such requests directly. As such, to the extent that your data subject request is
intended for one of our Customers, please submit your request directly to that
Customer.


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