PRIVACY
POLICY
Context
Summits LLC, along with its parent company, Context Capital Partners LP, and
subsidiaries (including Context Family Network LLC) (collectively,
"Context"/"us"/"we"), are committed to protecting
and respecting your privacy. This Policy (together with our Registration and Event Terms, Subscription and Services Agreement and Website Terms of Use, collectively referred to herein as the “Terms”) sets out
the basis on which any personal data or other information we collect from you,
or that you provide to us, will be processed by us in connection with our
businesses. This Policy applies to current and former users of our
products and services. This Policy also applies to Context Advisors (as defined
in the Terms) to the extent of the information covered herein. Capitalized or
defined terms not defined herein have the meanings set forth in the Terms.
By using www.contextsummits.com and
gocontextsummits.com (and any successor and related sites, collectively, the
"Website") and/or Context’s products and services including
participating in Summit Events, you are accepting and consenting to the
practices described in this Policy.
Information
you give us
This is information about you that
you give us by filling in forms on the Website or by corresponding with us in
person, by phone, email or otherwise. It includes information you provide, or
have in the past provided to us, when you: (1) register on our Website, including looking for
opportunities, sponsorships, media, association partnerships and suite
packages; (2) contact us; (3) register to receive emails from us; (4) subscribe
to our services (including registering for Summit Events); and (5) otherwise
communicate with us.
Information
we collect about you
With regard to each of your visits
to our Website, we will automatically collect technical information, including:
the IP address used to connect your computer to the Internet; hostname; network
name; and location information (city, latitude/longitude and postal
code). See also “Information about Location Tracking” in the Terms.
Information
we receive from other sources
This is information we receive about
you from sources such as industry contacts, other attendees/participants, the
service providers and vendors we use in connection with our products and
services, and databases. If you reside in the European Union, we will notify
you when we receive information about you from them and the purposes for which
we intend to use that information. We will only further use this information if
you consent to such use.
Cookies
Our Website uses cookies. A cookie is a small file of letters and
numbers that we put on your computer or device if you agree. Cookies help us to
provide you with a good experience when you browse our Website.
Our Website will place a cookie on
your computer or device when you access a password protected part of the
Website such as go.contextsummmits.com. This cookie is placed for security
purposes to store your login information and is strictly necessary to enable
you to navigate the Website.
Please
note that third parties (including, for example, advertising networks and
providers of external services like web traffic analysis services) may also use
cookies, over which we have no control. These cookies are likely to be
analytical/performance cookies or targeting cookies.
You can block cookies by activating
the setting on your browser that allows you to refuse the setting of all or
some cookies. However, if you use your browser settings to block all cookies,
you may not be able to access all or parts of our Website.
Uses made of the
Information
Information you give to us
We use information you give to
us in the following ways:
· to share with our employees, agents and representatives who
have a valid business reason to have access to such information;
· if you are a Summit Event attendee or participant, to share
with other Summit Event sponsors, attendees and participants in order for us to
give effect to the Context product and services you have chosen and to allow
our Summit Event sponsors to contact you about their products or services which
may be of interest to you;
· if
you are a user of Context 365 Services, to share with other users and
advertisers on the Context 365 platform and related services in order for us to
give effect to the Context product and services you have chosen and to allow those
advertisers to contact you about their products or services which may be of
interest to you;
· to keep you informed of relevant Context events or related
products and services, including the products and services of our Affiliates (as
defined below) such as Context
Advisors and our Summit Events sponsors and Context 365 advertisers;
· to carry out our obligations arising from any contracts
entered into between you and us and to provide you with the information,
products and services that you request from us;
· to notify you about changes to our products and services,
this Policy or our other terms of business; and
· to ensure that content from our Website is presented in the
most effective manner for you and for your computer or device.
Information we collect about you We will use this information:
· to administer our Website and for internal operations;
· to improve our Website to
ensure that content is presented in the most effective manner for you and for
your computer or device;
· as described in “Information about Location Tracking” in the
Terms;
· to allow you to participate in interactive features of our
service, when you choose to do so; and
· as part of our efforts to keep our Website safe and secure.
Information
we receive from other sources
We will combine this information with
information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending
on the types of information we receive and from what
source).
Disclosure of your information
You agree
that we have the right to share your personal data with:
·
any member of
Context's corporate group, our affiliated businesses, funds and investment
management and other affiliated and related entities (collectively,
“Affiliates”) which Affiliates may use such information for the purposes
permitted under this Privacy Policy; and
·
selected third
parties in the normal course of our business, including: (1) companies
(including accountants and attorneys) that provide products and services
necessary to enable us to provide products and services to you, to effect a
transaction that you request or to otherwise service you and/or your account;
(2) broker-dealers and similar entities assisting CCP Advisors in offering its
investment products and services, (3) sponsors of Summit Events and Context 365
advertisers, as described above; and (4) government agencies, courts, parties
to lawsuits, regulators or other competent bodies having jurisdiction over Context, in response to inquiries,
subpoenas or otherwise, including to meet any legal requirements applicable to
Context. In such cases, Context
will share only the information that it is required or
requested to share.
When we provide personal information
to a service provider/vendor we expect these providers to safeguard your
information, use the information only for the intended purposes and abide by
applicable law.
Information
you provide to third parties (including, but not limited to, BarclayHedge and
any Summit Event attendees) in connection with your registration for, or
participation in, any Summit Event or Context event shall be subject to any
applicable agreement or privacy policy that governs your relationship with such
party.
We may also disclose your
personal information to third parties:
·
in the event of a
merger, joint venture, business combination or similar transaction, purchase or
sale of any business or assets, in which case we may disclose your personal
data to the prospective participant, seller or buyer; or
·
if Context
Summits LLC or Context Capital Partners LP or all or substantially all of its
respective assets are acquired by a third party, in which case personal data
held by it about its customers, users or registrants may be one of the
transferred assets and we may disclose such data to the prospective acquirer.
·
Furthermore, you
agree that your name and/or participant Company registered for, sponsoring,
attending, or otherwise associated with a Summit Event may also be disseminated
to other attendees, participants, event sponsors, and third parties and posted
on the Website.
When
we are provided with updated information, we will endeavor to update our
records as soon as possible. We do not, however, have a duty to inquire as to
changes in the information you provide to us.
Anonymized
Data
Notwithstanding
anything in this Policy or the Terms to the contrary, we reserve the right to
include your personal data as part of an anonymized aggregation of data and
such aggregated data may be shared with third parties for any purpose.
Opting Out
You can ask us or third parties to
stop sending you marketing messages at any time by (i) logging into the Website
and checking or unchecking relevant boxes to adjust your marketing preferences;
(ii) by following the opt-out links on any marketing message sent to you; or
(iii) by contacting us at any time.
Where you opt out of receiving these
marketing messages, this will not apply to personal data provided to us as a
result of a product/service experience or other transactions.
Keeping your Personal Data secure
Context takes appropriate technical
and organizational security measures to prevent unauthorized or unlawful processing,
accidental loss of or destruction or damage to your personal data. Unfortunately, the transmission of information via the Internet is not completely secure. Although Context does its
best to protect your personal data, we cannot guarantee the security of your
data including information transmitted to our Website; any transmission is at
your own risk. For that reason, please do not use email to communicate
information to us that you consider to be highly confidential. If you
wish, you may contact us instead via telephone. Once we have received
your information, we will use strict procedures and security features to try to
prevent unauthorized access or
unlawful use.
Changes to
our Privacy Policy
Any changes we make to this Policy
in the future will be posted on this page and, in our discretion notified to you
by email. Please check back frequently to see any updates or changes to
our Policy.
Notice (1) to Persons located in the European Economic Area: Data
Controller
For the purposes of EU data protection
law, the data controller is Context Summits LLC of 597 5th Ave, 6th Floor, New
York, NY 10017, USA. Questions, comments and requests regarding this Privacy
Policy (the "Policy") should be addressed to [email protected].
Notice (2)
to Persons located in the European Economic Area: Personal Data Transfers
The personal data we collect from
you will be transferred to, and stored at, a destination outside the European
Economic Area ("EEA"). It will also be processed by staff operating
outside the EEA who work for us. This includes staff engaged in administering
your registration for, sponsorship of, or attendance at, our Summit Events and
other events or services, dealing with your enquiries when you contact us, and
supplying our services to you. By submitting your personal data, you agree to this transfer, storing
and processing.
Notice (3)
to Persons located in the European Economic Area: Rights and Data Retention
Lawful Basis of Processing
We collect and process your personal
information in conformance with applicable law. This includes but is not
limited to the following lawful bases for collection and processing:
(i)
With your consent as provided hereunder;
(ii)
In connection with the performance of contractual obligations;
(iii)
As necessary to comply with a legal obligation; and
(iv)
To fulfill our legitimate interest in conducting our business, where your
interests and fundamental rights do not override those interests including, but
not limited to:
a. providing the services for
which you have enrolled;
b. to keep our records
updated;
c. to study how customers use
our products/services, to develop them and grow our business and inform our
marketing strategy;
d. for running our business,
provision of administration and IT services, network security, to prevent fraud
and in the context of a business reorganization or group restructuring
exercises;
e. contacting you about our
products, or responding to your requests.
Under certain circumstances,
you have rights under data protection laws in relation to your personal data,
which may include rights to the following:
•
Request access to your personal data.
•
Request correction of your personal data.
•
Request erasure of your personal data.
•
Object to processing of your personal data.
•
Request restriction of processing your personal data.
•
Request transfer of your personal data.
•
Withdraw consent.
If you wish to exercise any of the rights set out above,
please contact us at [email protected].
You will not have to pay a fee to
access your personal data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we could refuse to comply with your request in these
circumstances.
We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights). This is a security measure to ensure that personal data
is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to
speed up our response.
We try to respond to all legitimate
requests within one month. Occasionally it could take us longer than a month if
your request is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.
Change of Purpose
We will only use your personal data
for the purposes for which we collected it, unless we reasonably consider that
we need to use it for another reason and that reason is compatible with the
original purpose. If you wish to get an explanation as to how the processing
for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data
for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.
Please note that we may process your
personal data without your knowledge or consent, in compliance with the above
rules, where this is required or permitted by law.
Revised January 2021