1. OUR APPROACH TO PRIVACY

1.1 RoWards LLC and its affiliates are committed to respecting your privacy. We are committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”), individuals who register to use the Services as defined below (“Customers”). This Privacy Statement describes Company’s’ privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by Company (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal information.

1.2 We collect data about users of our websites, blogs, mobile sites, or applications; about individuals that attend events organized, hosted, or managed by us; and about our clients (where these are natural persons) or their employees, agents, and representatives (and these individuals about whom we collect data are referred to as “you” in this Privacy Policy).

1.3 We may collect data that identifies or is associated with you (“personal information “) when you access our websites, blogs, mobile sites, applications, widgets and other interactive features, when you register or attend an event organized or hosted by us, or when you otherwise contact us (“Public Services “).

1.4 We may also collect personal information about you when we provide services or market our services (“Client Services “) to you, your employer, or any other person that has authorized you to communicate with us regarding the provision of Client Services to them in accordance with our client agreement.

1.5 This Privacy Policy sets out how we collect, store, process, transfer, share and use your personal information.

1.6 Before accessing, using or receiving our Public Services or Client Services, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this privacy policy.

2. DATA CONTROLLER

2.1 The identity of the data controller of the personal information we hold about you will depend on if you are engaging with RoWards LLC or any of our affiliates, or if you access, use, or receive our Public Services or Client Services.

3. INFORMATION YOU PROVIDE TO US

3.1 We collect personal information about you when you voluntarily submit information directly to us when you access, use, or receive the Public Services or the Client Services. This can include information you provide to us when you submit an inquiry through our website, register for and/or attend an event, correspond with us by phone, email or otherwise, subscribe to our mailing lists, client alerts, newsletters, or other forms of marketing communications, provide information requested by us to comply with our professional and Client obligations, or in connection with our provision of the Client Services.

3.2 If you choose not to provide personal information, we may not be able to provide some or all of the Public Services or Client Services to you or respond to your other requests.

3.3 When you use the Public Services, the categories of information we collect may include:

• contact information
• business information
• employment information
• location information
• information provided by third parties
• your comments and opinions that you express when you comment on a blog post, contact us by email, mail, or phone.

We use this information to operate, maintain and provide to you the features and functionality of the Public Services, to address your questions and concerns, to personalize your content so that it is relevant to the city or country you are using your device in, to contact you, including sending you news, alerts and marketing communications, and to help us develop new products and services.

3.4 The table at Appendix 2 further sets out the categories of personal information we collect about you when you use the Public Services and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the personal information.

3.5 When you use Client Services, the categories of information we collect may also include:
identification information
instructions and information about payment and transaction information
We use this information to provide you with the Client Services in accordance with our agreements; to communicate with you; to comply with our professional or Client obligations and to facilitate our internal business operations.

3.6 We also automatically collect personal information about you indirectly about how you access and use our websites, blogs, mobile sites, applications, widgets, and other interactive features (the “Online Services “) and information about the device you use to access the Online Services. For example, we may collect:

• information about how you view the Online Services (e.g., the pages you view, the links you click);
• information about your browser and usage patterns (e.g., your IP address, browser type and language); and
• information about the device you use to access the Online Services (e.g., device identifier, device type, model, and manufacturer)

We use this information to: present our Online Service to you on your device; determine news, alerts and other products and services that may be of interest to you for marketing purposes; and monitor and improve our Online Services and business, and to help us develop new products and services.

3.8 The table at Appendix 4 further sets out the categories of personal information we collect about you automatically and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the personal information.

4.PERSONAL INFORMATION WE SHARE WITH OTHERS

4.1 As required in accordance with how we use it, we will share your personal information with the following:

(a) Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.
(b) Affiliates. Other affiliates of RoWards LLC so that they can provide you with client updates, information and marketing messages about products or services that may interest you.
(c) The public. When you use our Public Services, content, and information that you post on message boards, blogs, or other services on our website, or that you allow us to make public, may be available to other visitors to our websites and to the general public. When you use our Client Services, to the extent you have given us consent to do so, we may also share your name and the company you work for together with comments and feedback on our Client Services.
(d) Client directories. When you use our Client Services, we may share your contact details and limited information about the Client Services provided to you or the client with client directories or other promotional publications or communications, to promote our Client Services. We will only share your personal information in this way to the extent that you have given us your consent to do so.
(e) Social Media Networks. When you use our Public Services, content that you share through social media may be shared with your social media account provider and your friends, followers, or contacts on the connected social network.
(f) Purchasers and third parties. In connection with a business transaction. We may, where permitted by our professional confidentiality obligations, disclose generic information about our current clients, such as limited client lists and/or brief descriptions of the Client Services being provided, to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
(g) Law enforcement, regulators, and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to
(a) comply with the law and the reasonable requests of law enforcement;
(b) comply with legal process;
(c) respond to requests from public or government authorities, including public or government authorities outside your country of residence;
(d) enforce the terms of our agreement (being, as applicable, our Terms of Use Agreement for Public Services or the terms of our client engagement letter for Client Services) and pursue available remedies or limit the damages that we might sustain;
(e) protect the security or integrity of the Public Services or Client Services (as applicable); and/or
(f) exercise or protect our rights, privacy, safety or that of our affiliates, clients, you or others.

5. MARKETING AND ADVERTISING

5.1 From time to time we may send you Client updates, alerts, news, and mailings relating to seminars or events that we think may be of interest to you.
5.2 Most messages we send will be by email. For some messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
5.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of Client Services.
5.5 Your personal information may also be shared with any affiliates of RoWards LLC, who may also use this information for the same purposes outlined in this Privacy Policy.

6. NOTICE TO YOU

If we need to provide you with information about something, whether for Client, marketing, or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Online Services. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

7. CONTACTING US

15.1 Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to Robert.Ward@rowards.com or to the partner with whom you entered into an engagement for the provision of Client Services.