Effective Date: 19 July 2024
This Privacy Policy describes the data protection practices of Capital Market Communications Limited and its affiliates and subsidiaries worldwide (collectively, “Camarco,” “we,” “us,” or “our”). This Privacy Policy applies to information that we collect and use about you including when you access or use an Camarco website, marketing e-mails, interact with us at a conference or event, engage with us through social media or our digital properties, use Camarco’s professional services, engage or communicate with us, or participate in any other Camarco online or offline services that we offer. We refer to these products and services collectively as the “Services.” The operator or organizer of the relevant Services is the data controller determining the purposes and means for the processing of your personal data.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
This Privacy Policy contains the following sections:
- The Information We Collect
- How We Use Your Information
- Legal Bases for Use of Your Information
- Cookies and Similar Technologies
- Online Analytics and Advertising
- How We Disclose Your Information
- Retention of Your Information
- Your Rights and Choices
- Third Party Links and Features
- Children’s Privacy
- International Users
- Notice to California Residents
- How We Protect Your Information
- Changes to Our Privacy Policy
- CAMARCO Contact Information
THE INFORMATION WE COLLECT
We obtain information about you through the means discussed below through our provision of Services.
- INFORMATION YOU PROVIDE TO US
We collect a variety of information that you provide directly to us. For example, we collect information from you through:
- The Services you use, including if you are a user of our professional services
- Requests or questions you submit to us via online forms, email, portals, or otherwise
- Your participation in sweepstakes, contests, Camarco events, or surveys
- Uploads or posts to the Services
- Requests for support and technical assistance
- Signing-up for a mailing list;
- Providing account information or giving us your contact information; and
- Corresponding with us directly.
Information collected from you. The types of data we may collect from you includes:
- Personal identifiers, such as your name, email addresses, physical address, telephone numbers, username, your date of birth, your image, and other contact information
- Professional and employment-related information
- Educational or employment information or history;
- Information about your interests or affiliations and information on your positions on political or policy matters, corporate matters, or other matters or issues;
- Information about articles (or similar) that you may have published;
- Billing information, such as credit or debit card number, verification number, and expiration date, and banking or routing information
- Business contact details, including your title, role, and business contact information
- Information about purchases or other transactions with us
- Information about your customer service interactions with us
- Information provided in your responses to surveys and research we conduct
- Quotes, photographs, video, and other information if you choose to serve as a “Case Study” listed on our website
- Any other information you choose to provide to us in connection with your use of or interactions with the Services.
- Information associated with or derived from other information about you that we process, such as, inferences.
Information collected about you. In providing our Services to our clients, we may engage in research, studies, or analyses that result in the collection of information about individuals. Such information may include names, contact information, career information, business contact information, demographic information, and information about individuals’ participation in groups or organizations. This information is collected in accordance with applicable law, and is processed and used by CAMARCO in connection with providing Services to our clients and pursuant to our agreements with such clients.
- INFORMATION WE COLLECT THROUGH AUTOMATED MEANS
When you use our websites and other digital properties or interact with us in any digital or virtual environments, we collect certain information automatically as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
Specifically, when you use our website and other digital properties or interact with us in any digital or virtual environments, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services and upload or post content, error logs, and other similar information.
Location Information. When you use our digital properties, we and our service providers may also automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer, mobile device, or other device.
Social Media Information. If you visit the website, our other digital properties, or interact with us in any digital or virtual environments on a device on which you also use social networks or if you interact with us through a social media service or other platform, we may have access to some information you provide to that social network or platform such as your name, email address, friend list, photo, age, gender, location, birthday, social networking ID, current city, and the people/sites you follow, or your posts or “likes.” For a description on how social media services and other third-party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.
- INFORMATION WE COLLECT FROM OTHERS
We may receive information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you and use for our research and professional services. If applicable, we may also use this information to supplement the information that we collect from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, advertising, and products.
- sensitive personal INFORMATION
We have highlighted the types of personal information that constitutes sensitive personal information, the processing of which requires your separate consent under the data protection laws of the People’s Republic of China (for the purpose of this Notice only, excluding Hong Kong SAR, Macau SAR and Taiwan) (the “PRC”). We only process your sensitive personal information if the processing is necessary for performing the Services or achieving related purposes.
Providing us with your sensitive personal information increases the risk that you may suffer harm to your personal safety or dignity or your reputation, or loss or damage to your property if your sensitive personal information is accessed, used, or divulged without authorization while it is in our custody. While we take the security of your sensitive personal information seriously and take reasonable security measures to secure the sensitive personal information that we collect about you or that you provide to us, please understand that no security measures can be entirely flawless, and we cannot guarantee that your sensitive personal information will never be accessed or used without authorization.
HOW WE USE YOUR INFORMATION
We, along with our service providers acting on our behalf, use your information for various purposes depending on the types of information we have collected from and about you, in order to:
- Complete a purchase or provide the Services
- Provide our professional services to our clients
- Provide support for the provision of the Service and our professional services to our clients
- Respond to your request for information and provide you with more effective and efficient customer service
- Contact you by email, postal mail, phone, or other means regarding Camarco and its subsidiaries and affiliates worldwide and its current and prospective clients and third-party products, services, surveys, research studies, newsletters, promotions, events, promotional material, marketing communications, and other subjects that we think may be of interest to you
- Customize the content you see on the Services
- Help us better understand your interests and needs, help us improve an Camarco website, and improve the Services, including through research and reports, and test, develop, create, and market new products, features, and services
- Perform due diligence or know your customer activities in connection with any engagement with Camarco and its subsidiaries and affiliates worldwide to perform its professional services
- Carry out requests made by you to us;
- Secure our Services and resolve technical issues being reported
- Conduct business operations, business administration, and legal compliance activities such as activities to comply with our legal obligations, protect the rights, property, or safety of us or of third parties, enforce our agreements with you, or activities in connection with a business transaction such as a merger, reorganization, acquisition by another company, or sale of all or a portion of our assets
- Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
- Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
- Use as otherwise required or permitted by law
Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.
Aggregate/De-Identified Data. We may aggregate and/or de-identify or anonymize any information collected through the Services so that such information can no longer be reasonably linked to you or your device. We may use such information for any purpose, including, without limitation, for research and marketing purposes and for Camarco’s professional services, and may also disclose such data to any third parties, including advertisers, promotional partners, sponsors, and current and prospective clients.
LEGAL BASES FOR USE OF YOUR INFORMATION
The legal bases for using your information as set out in this Privacy Policy are as follows:
- Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the terms of service of our websites or the terms of our agreement to provide professional services to a client)
- Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website and applications; operate our business and our Services; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the client to whom we are providing Services)
- Where we have a reason to process the data in accordance with the laws of an EU Member State (e.g., for tax and accounting purposes)
- Where we have your consent to engage in a particular processing activity.
COOKIES AND SIMILAR TECHNOLOGIES
To collect the information in the “Information We Automatically Collect” section above, we and our service providers use Internet server logs, cookies, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
As we adopt additional technologies, we may also gather information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
ONLINE ANALYTICS AND ADVERTISING
- ANALYTICS
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
- ONLINE ADVERTISING
In using the Services, third parties may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. These third parties (e.g., ad networks and ad servers such as Google, Act-On Software, Sugar Market/SalesFusion, Facebook, and Twitter and others) may use this information to serve relevant content and advertising to you as you use the Internet, and access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services to assist in this activity.
We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Please note that if you exercise the choices above, you may still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.
HOW WE DISCLOSE YOUR INFORMATION
CAMARCO will disclose your information in the following ways:
- Affiliates and Subsidiaries. We may disclose information we collect with Camarco’s subsidiaries and affiliates worldwide to deliver products and services to you, ensure a consistent level of service, enhance our products, services, and your customer experience, to notify you of information that may be relevant or of interest to you, and in connection with any business relationship Camarco and its subsidiaries and affiliates worldwide have with you.
- Service Providers. We provide access to or disclose your information to select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.
- CAMARCO Clients. Unless we expressly notify you otherwise at the time of collection, we may disclose information that we receive from and about you to Camarco clients and to the clients of Camarco’s subsidiaries and affiliates including in connection with the professional services offered or provided to such clients.
- Protection of CAMARCO and Others. By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or a lawful request by public authorities, including to meet national security or law enforcement requirements; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Camarco, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
- Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, your information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
- Aggregate/De-Identified Information. From time to time, we may disclose Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. The disclosure of such data is unrestricted.
RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
YOUR DATA RIGHTS AND CHOICES
A. Marketing Communications
You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.
B. Rights Regarding Your Information
Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
- Provide you access to and/or a copy of certain personal information we hold about you.
- Correct or update personal information we hold about you.
- Delete certain personal information we have about you.
- Provide you with information about the financial incentives that we offer to you, if any.
- Restrict or object to certain uses of your information.
- Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising” as described below. If you are a California resident, please see the “Notice to California Residents” section below for more information about our privacy practices and your rights.
As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. Your local law may also allow you to designate an authorized agent to make access and/or deletion requests on their behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
To exercise any of these rights, please use the contact information at the bottom of this Privacy Policy.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.
C. Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes
Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”
As explained in the “How We Disclose Your Information” section above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. We also provide information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.
If you would like to opt out of the disclosure of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” or processing for purposes of targeted advertising, please see the “Online Analytics and Advertising” section above.
Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.
THIRD PARTY LINKS AND FEATURES
The Services contain links to third-party websites such as social media sites, and also contain third-party plug-ins (such as the Facebook “like” button and Twitter “follow” button). If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.
CHILDREN’S PRIVACY
The Services are intended for general audiences and not for children under the age of 16. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 16 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
INTERNATIONAL USERS
We operate globally and may transfer, store, and/or process your information to or with other entities within Camarco or other third parties such as trusted service providers and partners in locations around the world (including the United States) for the purposes described in this Privacy Policy. Wherever your information is transferred, stored or processed by us, we take reasonable steps to protect your information in accordance with this Privacy Policy and applicable laws. These measures may include implementing Standard Contractual Clauses to govern the transfer of your information, or other means recognized by applicable laws. By providing us with your information, you acknowledge any such transfer, storage, or processing.
If you have any concerns or complaints about our data processing activities, we urge you to first try to resolve such issues directly with us. However, if applicable, you may make a complaint to the data protection supervisory authority in the country where you are based, or seek a remedy through local courts if you believe your rights have been breached.
NOTICE TO CALIFORNIA RESIDENTS
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act and its California Privacy Rights Act amendments (collectively, “CCPA”).
We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities with which we disclose such information in the “Information We Collect”, “How We Use Your Information,” and “How We Disclose Your Information” sections of this Privacy Policy. We provide additional information required by the CCPA below.
A. Categories of Personal Information we collect, use and disclose
Throughout this Privacy Policy, we discuss in detail the types of Information we collect from and about users and discuss how we use and disclose such information. The following are the “categories” of personal information under the CCPA that we collect from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes:
Identifiers (such as name, address, phone number, email address, data of birth, image, and other contact information); commercial information (such as transaction data); financial data (such as credit card information processed by our payment processor); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history); general geolocation data derived from IP addresses; any user-generated content or feedback that you provide (including through customer service interactions or in response to surveys/research); and professional, educational, interests, or employment related data (e.g., information about your interests, affiliations, and articles you have published); and inference data that we derived from other information we process.
B. How we use these categories of personal information
We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law).
- Our or our service providers’ operational purposes;
- Auditing consumer interactions on our site (e.g., measuring ad impressions);
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
- Bug detection and error reporting;
- Customizing content that we or our service providers display on the Services (e.g., contextual ads);
- Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
- Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
- Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third party partners;
- Other uses about which we notify you.
Further details and examples of these types of uses are discussed in our main privacy policy in the “How We Use Your Information” section. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device. We may also disclose this information to third parties for legal, compliance or security purposes, or in connection with a business transfer, as described further in “When We Disclose Your Information” above.
C. Sale/Sharing of Personal Information
The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising purposes. We “sell” or “share” the following categories of information to third-party advertising partners and vendors that support our advertising efforts (such as advertising analytics services):
Identifiers (such as name, address, email address); commercial information (such as transaction data); internet or other network or device activity (such as browsing history and usage information).
If you would like to opt out of our use of your information for such purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes under California law, please see the “Online Analytics and Advertising” section above. Please note that we do not knowingly sell the personal information of minors under 16 years of age.
Please note we do not use or disclose sensitive personal information other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.
D. Additional Privacy Rights
In addition to the rights section before in section C above, California residents may make certain requests about their personal information under the CCPA as set forth in the “Your Rights and Choices” section above.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you.
E. Shine the Light
California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.
F. Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Except as otherwise described herein with respect to legally required browser based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. To learn more about Do Not Track, you can do so here.
HOW WE PROTECT YOUR INFORMATION
Camarco takes technical and organizational security measures to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to Camarco via the Internet.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services (or otherwise notify you of changes where legally required), so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.
CONTACT INFORMATION
Please feel free to contact us if you have any questions about Camarco’s Privacy Policy or the information practices of the Services. You can reach us via email, privacy@apcoworldwide.com or by mail at APCO Worldwide LLC, Attn: Legal Department, 1299 Pennsylvania Avenue, NW, Suite 300, Washington, DC 20004.
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