Privacy policy.

This privacy policy sets out how we collect, process and use the personal data of our users, customers, event attendees and website visitors in connection with our products and services. Treating personal data with respect, keeping it secure and processing it in accordance with the law is of the utmost importance to With Intelligence.

With Intelligence privacy policy.

With Intelligence is made up of different legal entities. This privacy policy is issued on behalf of the With Intelligence so when we mention With Intelligence, With, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the With Intelligence group responsible for processing your data. With Intelligence Ltd is the controller (or equivalent in the relevant jurisdictions) and responsible for this website.

We might need to change this privacy policy from time to time. We will publish any updated privacy policy on our website and if possible, we will update you directly if we think the changes are likely to affect you.

If you are a resident of Nevada or California, please see our sections at the end of our privacy policy on how local data protection laws affect you.

About us.

With Intelligence produces a range of business information products relating to alternative and traditional asset management, as well as hosting events on areas of interest to those sectors.

Our personal data usage guidelines.

We will only use your personal data for the purposes for which we collected it, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for a purpose which is unrelated to the purpose for which we originally collected your personal data, then we will notify you and we will explain the lawful basis which allows us to do so. If you are located in Hong Kong, we will ask for your consent before processing your data for any unrelated purposes.

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

Other than where necessary to comply with our legal obligations as part of our recruitment process (see section “job applications”), we do not collect any special categories of personal data. This means we will not collect data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic data or biometric data for the purpose of uniquely identifying a natural person. Similarly, we do not collect any information about criminal convictions and offences.

Children’s privacy.

Our websites, products and services are not intended for children, and we do not knowingly collect data relating to children.

Types of personal data held by us.

From time to time we collect, use, store, process and transfer the following kinds of personal data:

Identity data, including first names, last names, job titles, usernames or similar identifier, dates of birth, gender and dietary requirements;
Contact data including billing addresses, delivery addresses, email addresses and telephone numbers;
Personal data contained within photographs;
Business data, including job roles, company name, business contacts, networking activities;
Information for our databases, including publicly available information about companies, their regulatory filings, their directors, shareholders, stakeholders and professional advisers, and other information from profiles, reports, articles and blogs;
Financial data including bank account details and payment card details; Transaction data including details about payments made to and from users and other details of products and services our customers have purchased from us;
Technical data including internet protocol (IP) addresses, 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 used to access this website or our services or products;
Profile data including usernames and passwords, purchases or orders made, social media account details, preferences, feedback and survey responses;
Job applicant data, such as contact information, experience, education information, CV, background information, other information applicants provide to us and special categories of personal data where necessary in order to comply with our legal obligations;
Usage data including information about how our websites, products and services are used;
Security footage data, including audio and video recordings; and
Marketing and Communications data including personal preferences in receiving marketing from us and our third parties and any communication preferences.

How we collect personal data and what we use it for.

Providing products and services.

When a client or customer purchases a subscription service or a product from us, we collect certain personal data. We also collect personal data when an individual submits a website form or contacts us to request information about our products and services. We use this personal data in the following ways:

To fulfil our contract: this includes setting up clients and users, processing payments, providing updates relating to our products, processing user IDs, passwords and contact details and delivering content. Any such use will be on the basis that it is necessary to pursue our legitimate interest of carrying on our business.

After the contract has ended: we will keep full records about the contract for a limited period in case you want to reactive your account. Such processing would be carried out on the basis that it is necessary for the purposes of our legitimate interest in conducting our business to pursue our legitimate interest of protecting our business.

Record keeping: we retain details of transactions for a period of up to 6 years for our internal records and for the purpose of tax and regulatory compliance. Any further use of the retained information will only be to comply with regulatory requirements or in the event of a dispute between the recipient and us. Such processing would be carried out on the basis that it is necessary to pursue our legitimate interest of protecting our business and to comply with the law.

Monitoring use: we use software services and tools to monitor the use of our websites, products and services access using your account details, to identify and manage potential security issues and to keep your account safe. Any usage data will be processed to the extent necessary for our legitimate interest of ensuring our products, websites and services are secure. We will retain usage data for a period of up to 6 years. Any further use of the retained information will only be to comply with regulatory requirements or in the event of a dispute between you and us – in which case such processing would be carried out on the basis that it is necessary to pursue our legitimate interest of protecting our business.

Printing and logistics: in fulfilling our contract with you, we may need to have certain materials printed and despatched to you. In these circumstances your personal data may be sent to a third-party provider in accordance with the terms of this privacy policy. Any such use will be on the basis that it is necessary to pursue our legitimate interest of carrying on our business.

Troubleshooting and technical support: in certain circumstances when performing our contract with you (or otherwise providing requested services to you where no contract exists), a need may arise for us to transfer your data to a third-party technical support or technology development agency. Any such use and transfer will be on the basis that the processing is necessary to perform the agreement that we may have with you and in order to pursue our legitimate interest in developing and improving the stability and security of our systems.

Where we rely on you to provide personal data in order for us to meet statutory or contractual obligations and you do not provide this, we may not be able to provide some or all of our services to you, or the provision of these services may be reduced or delayed.

Events and webinar.

We process personal data in order to effectively manage, organise and run our events and webinars. Where you sign up to attend one of our events or webinars:

We will collect such personal details as are required to deliver our contractual obligations (or otherwise providing requested services to you where no contract exists), such as your name, email address, payment details and any other relevant attendee details. We will only process such details as are necessary to enable us to perform the contract between you and us or to pursue our legitimate interest of promoting our business and developing new customers.

We may publish or circulate an attendance list (including your name and company name) which will be made available to other attendees and to the event/webinar sponsors. We will not share your details with the venue (where relevant) or other third parties for marketing purposes unless you provide your consent. We consider this processing to be necessary to pursue our legitimate interest of running our events and webinars effectively.

We may also request and collect information about your relevant interests and preferences. We will use this information to help us make decisions about the kind of events, webinars and any services or products you might be interested in hearing about from us and will use this information for marketing purposes. If you are located in Hong Kong, we will ask for your consent before collecting and processing your personal data in this way. Outside of Hong Kong, such processing is carried out to pursue our legitimate interest of promoting our business, developing new customers and to inform our marketing strategy.

In order to properly deliver the event or webinar we may need to have certain materials printed and despatched to you. In these circumstances your personal data may be sent to a third-party printer or logistics provider. Any such transfer will be made in accordance with the terms of this privacy policy. Any such use will be on the basis that the processing is necessary to perform the agreement that we may have with you.

Your photograph may be taken at one of our events and may be used for marketing purposes. If we intend to do this, we will ask you to enter into an image waiver and consent form. If you are located in the US or Hong Kong, we will ask for your consent before taking your photograph and using it for marketing purposes.

Any individuals who sign up to act as speakers at our events or webinars may have their personal data collected and used in the following way:

We will use your contact details to contact you in connection with the event or webinar and process any payment or facilitate any obligations or rights set out in any agreement which may exist between you and us. Any such processing will be carried out on the basis that it is necessary to fulfil the contract between you and us. We will retain details of transactions between you and us for up to six years. We will only use the retained information to comply with regulatory requirements or in the event of a dispute between you and us – such processing may be carried out on the basis that it is necessary to pursue our legitimate interest of protecting our business.

We may use any profile or personal data that you provide us with or that are publicly available to help market or advertise the event that you are speaking at on the basis that such processing is necessary to achieve our legitimate aim of running an effective event or webinar. We may retain your profile and details for our internal records and to allow us to contact you in the future about similar events or webinars. Such processing is carried out to pursue our legitimate interest of promoting our business.

In order to properly deliver the event or webinar we may need to have certain materials printed and despatched to you. In these circumstances your personal data may be sent to a third-party printer or logistics provider. Any such transfer will be made in accordance with the terms of this privacy policy. Any such use will be on the basis that the processing is necessary to perform the agreement that we may have with you.

Visits to our websites.

Our websites use cookies to help us (1) make sure our website performs as intended; (2) to analyse how visitors use our websites in order to help us make our websites more effective; and (3) to help us make marketing decisions about how we promote our services online.

Cookies are small data files that websites store on your electronic device so that the website can store data and will enable us to collect information, which is likely to include data from which you can be identified. For further details, including the duration that we retain data for, please see our Cookie Notice https://www.withintelligence.com/cookies.

You can control the use of cookies at the browser level by setting your web browser controls to accept or refuse cookies. If you choose to block all cookies, you may not be able to access all or parts of our website. In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information on this, please visit the websites: http://www.aboutads.info/choices/ or http://www.youronlinechoices.com or http://globalprivacycontrol.org.

In some instances we also use server logs to collect data. Our lawful basis for using cookies and server logs to collect and process usage data is that it is necessary to pursue our legitimate interests of promoting our business and for the correct functioning and operation of our websites.

Marketing.

We use third party agencies, data research companies and our own internal team to actively identify people who we believe are likely to find our events, services products useful. Our team and our third party researchers look for and source business contact details and information about an individual’s job role both online (using publicly available resources and websites), through networking activities and from details collected from previous event attendees, newsletter subscribers and users of our products.

We use those business contact details to send event invites and emails about relevant industry news. We always include an unsubscribe link at the bottom of any such email which we send, so that you can let us know if you do not wish to receive any further marketing emails. In Hong Kong, we will only do this with the consent of the relevant individual.

Our lawful basis for using personal data in this way is that it is necessary to pursue our legitimate interest of promoting our business, developing new customers and to inform our marketing strategy.

Customer engagement.

In parallel with the services and products that we provide we offer access to certain platforms through which we engage with our customers and clients. This includes, for instance, our own community social media platform and a customer polling platform. In operating these platforms, we may process your personal data to allow you to access and use the services on these platforms.

Information databases.

We collect, use and store personal data relating to third parties such as details about the directors, shareholders, stakeholders and professional advisors of certain companies in order to provide certain services. Data of this type is collected and processed both internally by our researchers and by third party agencies on our behalf. Our researchers and agencies may contact relevant individuals directly to obtain information as well as using publicly available websites, LinkedIn, regulatory filings, company registries and news articles. We use this information to write profiles, articles, blogs and reports which are then published for the benefit of our subscribers (who may be based outside the UK, EEA, US, Hong Kong or Singapore) via a searchable database or in a newsletter. We process data in this way in order to pursue our legitimate interests of developing our products/services and growing our business and to present financial service journalism.

Job applicants.

If you apply for a job at With Intelligence, we will use the information you provide us with to assess your suitability for the role and to progress or end your application. The personal data we will require, and use includes contact details, your curriculum vitae, your previous experience, education history and answers to questions relevant to the role you have applied for. Our HR team and the hiring manager for the role will have access to this data.

We may collect your special categories of personal data where it is necessary to do so to comply with our legal obligations as an employer. We may also ask about equal opportunities data. We use this data on an anonymised basis to produce and monitor equal opportunities statistics for legal reasons. There is no obligation to provide this data and it will not affect your application if it is not provided.

We will only share your data with contracted third parties if it is necessary for the recruitment process and we will notify you at the time that we do so. We will never sell your data or use it for marketing purposes.

If your application is not successful, we will store your details for six months to help with any questions, before securely deleting or anonymising the personal data. If you elect to hear about other opportunities in the future, we will retain your personal data for a further two years before securely deleting or anonymising the personal data.

If your application is successful, we will need to complete employment checks for legal reasons, in particular, to verify your right to work in the country and to verify your previous employment references.

We may carry out data processing of this nature to the extent necessary for the legitimate interest of recruiting and developing our workforce.

Administration.

We may process personal data in order to allow us to properly administer our systems and our business, including data storage, hosting, reporting, systems maintenance, improving our computer systems, troubleshooting, analysis, testing and the operation of our databases. Processing of this kind is incidental to the provision of our services and products and to the efficient operation of our business. We may carry out data processing of this nature for the legitimate interest of administering, improving and protecting our business, this website, our products and our services. We may also carry out this type of data processing to pursue our legitimate interest in ensuring our systems are secure and preventing fraud.

Debt management.

Where a client fails to make payment for an event, service or product at the time that it is due we may need to transfer your personal data in order to instruct a third-party debt collection agency. Processing of this type may be carried out in order to pursue our legitimate interest in recovering such a debt.

Analytics.

We use data analytics to monitor and improve our websites, products/services, marketing, customer relationship management and user experiences. Wherever possible when carrying out this type of analytical work, we anonymise all personal data. In certain circumstances, however, cases arise whereby we need to process personal data in order to achieve the objectives of our analytical processing. Where we do so we are pursuing our legitimate interests of defining the types of customers for our products and services, keeping our websites, services and products updated and relevant, developing our business and to inform our marketing strategy.

CCTV.

At some of our offices there is a CCTV system installed. Any individual who visits these offices will have their image recorded by the CCTV system. We operate CCTV systems at these premises in order to pursue our legitimate interests of protecting the personal safety of staff, visitors and other members of the public, to act as a deterrent against crime and to prevent crime and pursue our assets from damage, disruption, vandalism and other crime.

Data security.

We have put in place appropriate security measures at organisational, technical, physical and operational levels to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. 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. However, the transmission and storage of information is subject to vulnerabilities and unauthorised third-party activity. Although we will do our best to protect your personal data, we cannot and do not guarantee the security of your data.

When you register for an account with us, you may be required to choose or will be assigned a password which enables you to access our website. You are responsible for keeping this password confidential and for all activity that takes place through your account credentials. Do not share your password with anyone. If your password is compromised, change your password within your account. If you believe your account may have been compromised, please notify us immediately.

International transfers of personal data.

UK and the EU

We share your personal data within With Intelligence. As we have a number of offices outside of the UK and the European Union (EU) your personal data may be transferred outside of the UK and the EU (a ‘restricted transfer’). ‘UK Transfers’ refers to transfers of personal data that are subject to the UK data protection laws and ‘EU Transfers’ refers to transfers of personal data are subject to the EU data protection laws.

We also work with a number of third-party outsourcers based outside of the UK and/or the EU, including providers of research services, IT support, technology and website development agencies. From time to time, we may need to transfer certain personal data to these parties in accordance with the terms of this privacy policy.

Whenever we transfer your personal data out of the UK or the EU, we provide an equivalent degree of protection to the personal data by ensuring that at least one of the following safeguards is implemented:

Where the recipient is located in a country that has been deemed to provide an adequate level of protection for personal data by the UK Secretary of State (for UK transfers) or the European Commission (for EU transfers); or

Using standard contractual clauses approved by the ICO (for UK Transfers) or the European Commission (for EU Transfers) as providing appropriate safeguards for restricted transfers.

Disclosure of personal data to third parties.

We may disclose any personal data that we hold to certain third parties who are contracted to help us provide our products and services (some of whom may be based outside the UK, EU, US, Hong Kong or Singapore). Any such third parties will be acting as processors on our behalf and will be contractually bound to only use the data in accordance with our instructions and to implement adequate security measures. The data will only be transferred by us to a third party if appropriate contractually binding safeguards are implemented between us and the processor. We require all third parties to respect the security of your personal data and to treat it in accordance with all applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may share also personal data with third parties (who will also be acting as controllers in respect of that personal data) if we:

have a legal duty to do so or if it is required to enforce or apply our contracts or to protect legal rights, our property, the use and functionality of our websites or the safety of us or others; and

sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners will only be entitled to use personal data in accordance with the provisions set out in this privacy notice.

Links to third-party sites.

Our website may contain links to other websites and companies that may be of interest to you. If you click on any of those links, you will leave our website. We are not responsible for third-party websites. Please consult the terms of service and privacy policies of those sites when you visit them.

Data retention.

We will only retain your personal data for as long as is 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 believe there is a reasonable 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.

By law we must keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ‘Your rights’ below for further information.

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

Your rights.

If we hold data about you, you have certain rights under applicable data protection laws.

In the UK and the EU, this includes the:

Right to be informed: you have a right to ask us what personal data we collect and what we use it for;

Right of access: you have a right to request a copy of any personal data that we hold about you. We will respond to your request within one month;

Right of rectification: you have a right to require us to correct any personal data held about you which is inaccurate or incomplete. We will rectify any errors you highlight to us within one month;

Right to restrict processing: you have a right to request us to restrict the processing carried out in respect of personal data relating to you;

Right of data portability: you have a right in certain circumstances to request that the personal data held by us about you transferred to another organisation;

Right to object: you have a right to object where processing is carried out in certain circumstances. You may always object to us processing your personal data for direct marketing purposes; and

Right to object to automated decision making and profiling: you have a right not to be subject to a decision based solely on automated processing which produces legal or similar significant effects on you.

In Hong Kong or Singapore, points (d) to (g) above do not apply to you. However, if you are located in Hong Kong, you are able to opt-out of direct marketing. If you are located in Singapore, you have the right to be notified of a data breach in certain circumstances.

In certain situations, we may be able to rely on one of the exemptions under the applicable data protection laws. These exemptions may mean we have a right to refuse requests for disclosure of information, erasure requests and rectification requests, as well as exempt us from some notification obligations.

We will confirm to you in writing to acknowledge receipt of any request we receive relating to your rights as a data subject, and we will let you know if we have complied with your request within the applicable timeframe. If having, carried out an assessment, we believe that we are indeed able to rely on one of the exemptions, we will let you know why we have reached that conclusion.

Privacy signals.

Some internet browsers incorporate a “Do Not Track” feature or other similar features that signal to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Accessibility.

We are committed to ensuring this privacy policy is accessible to individuals with disabilities. If you wish to access this privacy policy in an alternate format or would like to report an issue you are experiencing on our website, please email us at data@withintelligence.com.

Questions, complaints and contact.

‘With Intelligence’ is the trading name of With Intelligence Ltd and its affiliates.

You can contact With Intelligence with any questions you might have about our use of data or this privacy policy. You also have the right to request access to and correction of the personal data held by us about you.

You can contact us via the following addresses:

UK: With Intelligence Limited: One London Wall, London EC2Y 5EA, United Kingdom

USA: With Intelligence LLC: 41 Madison Avenue, New York, NY 10010, USA

Hong Kong: With Intelligence HK Limited: Suite 1106-08, 11th Floor, Tai Yau Building, No.181 Johnston Road, Wan Chai, Hong Kong

Singapore: With Intelligence Pte, 24 Raffles Place, #27-04, Singapore 048621

Email: data@withintelligence.com

With Intelligence has implemented appropriate technical and organisational measures to ensure our compliance with all applicable data protection laws. With Intelligence has formed a data privacy compliance committee reporting to our board and Chief Executive.

Please let us know if you have any concerns about how we are handling your data. We will do our best to resolve the matter, but if we are unable to do so to your satisfaction you may make a complaint to our General Counsel (legal@withintelligence.com). All users in the UK also have the right to lodge a complaint with the appropriate supervisory authority. All complaints can be lodged with the ICO who can be contacted at https://ico.org.uk/make-a-complaint/

This privacy policy was last updated on 22/03/2023.

Notice to Residents of Nevada, USA.

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal data. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal data for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal data as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to data@withintelligence.com.

Notice to Residents of California, USA.

This privacy notice to Consumers in California, USA (“CA Notice”) is for California residents and supplements the other sections of our privacy policy. This CA Notice explains how we collect, use and disclose your “Personal Information” (as that term is defined by California law) and how you may exercise your rights under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). This Notice is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you.

NOTICE AT COLLECTION OF PERSONAL INFORMATION. To provide you with our Sites and Services, we collect and process information about you, including in some cases, Personal Information. To comply with the CCPA and to assist you in understanding our data collection and protection practices during the past 12 months:

a) Categories of Consumer Personal Information. We collect and, in the 12 months prior to the Date of Last Revision of this Privacy Policy, have collected the following categories of consumer Personal Information as described in the “Types of personal data held by us” section above.

b) Sources of Personal Information. We collect the above categories of consumer Personal Information from you, from your devices and from our service providers as described in the sections above on “types of personal data held by us” and “how we collect personal data and what we use it for”.

c) Purpose for Collection. In addition to the business purposes for which we collect consumer Personal Data described in the sections above on “types of personal data held by us” and “how we collect personal data and what we use it for”, we collect consumer Personal Information for the following business or commercial purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.

Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

d) Sale and Sharing of Personal Information. We do not “sell” Personal Information, as that term is commonly interpreted. The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the last update of this privacy policy and, for each category, the categories of recipients to whom we disclosed Personal Information. Please note that not all categories of personal information were necessarily shared with all categories of recipients listed.

Category of Personal Information	Categories of Recipients
Identifiers (name, postal address, online identifier, Internet Protocol address, email address, account name)	Distributors; business partners; data hosting and cloud storage providers; mailing providers; advertising service providers, accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)	Data hosting and cloud storage providers; cookie management service provider; advertising service providers.
Telephone number	Distributors; business partners; data hosting and cloud storage providers; mailing providers; advertising service providers, accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Bank account number	Financial institutions for processing.
Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)	Data hosting and cloud storage providers; cookie and privacy management provider.
Other financial information, including business credit history, payment behavior, and tax identification number	Business partners; data hosting and cloud storage providers; accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Geolocation data	Distributors; data storage providers; security, anti-fraud, and verification providers.
Commercial information (records of personal property and personal credit information)	Distributors; business partners; data hosting and cloud storage providers; mailing providers; accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Professional or employment-related information (including employment history)	Distributors; business partners; data hosting and cloud storage providers; mailing providers; providers, accounting service providers, call center service providers, client relationship management service providers, payment processing vendors.
Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, behavior, and abilities	Security, anti-fraud, and verification providers; client relationship management service providers.

e) Sensitive Personal Information. We do not use Sensitive Personal Information (as it is defined in the CCPA) for the purpose of inferring characteristics about individuals.

f) Retention of Personal Information. We retain Personal Information for as long as necessary to fulfil the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Please see our “data retention” section above for more information.

g) Your Rights. Under the CCPA, you have the following rights:

RIGHT TO KNOW	You have the right to request that we disclose to you the Personal Information we collected about you in the 12-month period preceding your request. This right includes the right to request: (1) specific pieces of Personal Information we have collected about you; (2) categories of Personal Information we have collected about you; (3) categories of sources from which the Personal Information was collected; (4) categories of Personal Information that we sold or disclosed for a business purpose about you (if applicable); (5) categories of third parties to whom your Personal Information was sold or disclosed for a business purpose (if applicable); and (6) the business or commercial purpose for collecting or, if applicable, selling your Personal Information.
RIGHT TO DELETE	You have the right to request that we delete your Personal Information that we have collected from you, with some exceptions. Note that if you request that we delete your information, we may be unable to provide you with certain offers, access or services.
RIGHT TO CORRECT	You have the right to correct inaccurate Personal Information we maintain about you.
RIGHT TO LIMIT PROCESSING OF SENSITIVE PERSONAL INFORMATION	If we use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use and disclosure. We do not use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.
RIGHT TO NON-DISCRIMINATON	You have the right to non-discrimination for exercising your CCPA rights. This means we cannot deny you goods or services, charge you different prices, or provide a different level of quality of goods or services just because you exercise your rights under the CCPA. We will not and do not discriminate against you or other customers for exercising any of your CCPA rights.

h) How to Exercise Your Rights.

Right to Submit a Request to Know, Delete and/or Correct: You may submit a request to know, delete and/or correct by emailing us at data@withintelligence.com. If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct. We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

i) Shine the Light Law. California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). With Intelligence does not sell or disclose information to third parties for their direct marketing purposes.