Privacy Policy

Updated and Effective as of December 2022

This privacy policy describes how Winsight, LLC and its subsidiaries, including Technomic, Inc. (collectively, “Winsight,” “we,” “us,” or “our”) collects, uses and shares your personal information in connection with your use of our websites, applications and online services, including websites, online services, and applications (including mobile applications) related to or used in connection with events that are operated by, controlled by or affiliated with us (collectively, “Services”).

This Privacy Policy only applies to personal information collected through our Services and does not apply to information collected at any other website, application or otherwise by us (unless specifically stated), including when you call us, write to us, or communicate with us in any manner other than through our Services. By using our Services, you consent to our use of your personal information and agree to the terms of this Privacy Policy.

TABLE OF CONTENTS

1. INFORMATION YOU CHOOSE TO SUBMIT
2. INFORMATION WE AUTOMATICALLY COLLECT
3. COOKIES/TRACKING TECHNOLOGIES
4. INFORMATION WE RECEIVE FROM OTHER SOURCES
5. INFORMATION USE
6. SOCIAL NETWORK AND PLATFORM INTEGRATION
7. OUR INFORMATION SHARING PRACTICES
8. TECHNOMIC PAID RESEARCH AND SUBSCRIPTION
9. TECHNOMIC CONTACTS DATABASE
10. ANONYMOUS DATA
11. PUBLIC INFORMATION
12. USERS OUTSIDE OF THE UNITED STATES AND CONSENT TO TRANSFER
13. IMPORTANT INFORMATION ON EUROPEAN UNION AND UNITED KINGDOM USER RIGHTS
14. ADVERTISING
15. CHOICE/OPT-OUT OF COMMUNICATIONS
16. MODIFYING AND DELETING YOUR PERSONAL DATA
17. SECURITY
18. LINKS
19. CHILDREN'S POLICY
20. SENSITIVE PERSONAL DATA
21. CHANGES
22. CONTACT US
23. CALIFORNIA RIGHTS NOTICE
24. SUBSCRIBERS TO WINSIGHT MEMBERSHIP

Information You Choose To Submit

You may choose to provide your personal information to us. For example, if you attend one of our events or participate in one of our surveys, you may provide us with information such as your name, email address and information about your employer. If you wish to register for any of our Services, you must provide certain personal information (for example, your name and email address), and you must also provide a username and password. You are responsible for keeping your username and password secure and not sharing your account with others.

You may also choose to submit, or we may collect additional information about you, such as demographic information (for example your gender, birth date, or zip code) and information about your preferences and interests. You also may choose to submit your alias, bio, email, photos, or any other information that you would like to share with other users of our Services.

We may ask event attendees to upload a photo for their event badge for security purposes. This is used solely to identify if the photo contains an image of a human face. We store the photo that the attendee has uploaded, and the facial recognition only adds a Yes/No answer as to whether the photo contains an image of a human face.

Our mobile application includes functionality that allows our attendees to identify their location at the event, in certain cases. Application users choose to use the application anonymously or to login as an identified user, in which case the personal data provided upon registration may be used. Information such as IP address, device ID and location is gathered.

We use your personal information to fulfill your requests for products and services, to improve our Services, to contact you from time to time, with your consent, about us and our products and services, and as otherwise described in this Privacy Policy.

Information We Automatically Collect

We and our third-party service providers (including any third-party content, advertising, and analytics providers) may automatically collect certain information from your device or web browser when you interact with our Services to help us understand how users use our Services and to target advertising to you (collectively referred to, as “Usage Data”). For example, each time you visit our Services we and our third-party service providers may automatically collect your IP address, mobile device identifier or other unique identifier, browser and computer type, access time, the Web page you came from, the URL you go to next, the Web page(s) that you access during your visit and your interaction with content or advertising on our Services.

As a general matter, we do not collect or process sensitive personal information. When you use credit card or bank account details to pay for our products or services or in connection with our events, we rely on third party payment processors and only they will have access to your financial information for purposes of completing your transactions with us.

We and our third-party service providers may use Usage Data for a variety of purposes including to diagnose problems with our servers and software, administer our Services, gather demographic information, and target advertising to you on our Services and elsewhere online. Our third-party advertising networks and ad servers will also provide us with information, including reports that tell us how many ads were presented and clicked on our Services in a manner that does not personally identify any specific individual. The Usage Data we collect is generally non-identifying, but if we specifically identify or associate it with you, we will treat it as personal information.

Cookies/Tracking Technologies

We may use tracking technologies, such as cookies, local storage, and pixel tags as well as other similar technologies, such as web beacons, tags, and scripts, including local storage objects such as HTML5 (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your device.

Cookies and Local Storage

Cookies and local storage may be set and accessed on your computer. Upon your first visit to our Services, a cookie or local storage may be sent to your computer that uniquely identifies your browser. “Cookies” and local storage are small files containing a string of characters that is sent to your computer’s browser and stored on your device when you visit a website. Many major Web services use cookies to provide useful features for their users. Each website can send its own Cookie to your browser. Most browsers are initially set up to accept Cookies. You can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. If you reject Cookies, you may not be able to use our Services or take full advantage of our Services. Additionally, if you clear all Cookies on your browser at any point after setting your browser to refuse all Cookies or indicate when a Cookie is being sent, you will have to again reset your browser to refuse all Cookies or indicate when a Cookie is being sent.

You can find more information about Cookies and how they work, what Cookies have been set on your computer or mobile device and how to manage and delete them at http://www.allaboutcookies.org/ and www.youronlinechoices.com/uk.

Pixel Tags

We may also use “pixel tags”, which are small graphic files that allow us and third parties to monitor the use of our Services and collect Usage Data. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your computer.

We may use pixel tags, either provided by us or by our third-party advertisers, service providers and ad networks, to collect information about your visit, including the pages you view, the links you click, and other actions taken in connection with our websites and Services and use them in combination with our Cookies to provide offers and information of interest to you. Pixel tags may also enable ad networks to serve targeted advertisements to you when you visit our Services or other web sites.

Web Beacons.

Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in the Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. In addition, we may use various technologies that collect similar information for security and fraud detection purposes.

Tracking Technologies Usage.

We may use Tracking Technologies for a variety of purposes, including:

• Strictly Necessary. We may use Cookies or other Tracking Technologies that we consider strictly necessary to allow you to use and access our Services, including Cookies required to prevent fraudulent activity and improve security.
• Performance Related. We may use Cookies or other Tracking Technologies that are useful to assess the performance of our Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through our Services.
• Functionality Related. We may use Cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing our Services, including identifying you when you visit our Services or keeping track of your specified preferences, including in terms of the presentation of content on our Services.
• Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our Services and third-party sites based on how you interact with our Services. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.

Tracking Technologies Choices and Consent

We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable Cookies as set forth above. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.

We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.

Text Notifications

You may agree to receive “text” notifications by SMS message, which will be sent by mobile phone number provided by you. There are no premium charges for our text notifications, but standard message and data rates may apply. If you choose to receive text notifications, you will receive messages based on the programs you select. If you sign up to receive text messages from any of our programs, we do not share that data and only use that data to send text messages that you opt-in to receive. To opt-out of receiving text notifications, you can modify your preferences to stop receiving text notifications. You can also opt-out from your mobile phone by texting STOP at any time. An unsubscribe message will be sent to your mobile phone confirming the cancellation, but you will not receive any further text notifications.

Information We Receive from Other Sources

We may supplement the information we collect with outside records to learn more about our users, to better tailor the content and offers we show you, and for other purposes. We may receive this information about you from third parties, including consumer data resellers and advertisers.

We may receive personal information about you from your organization and others with whom you have a relationship that provide or publish personal information related to you, such as from our customers when they arrange access to our Services for you or from others when they create, post, or submit user content on our Services that may include your personal information.

We may combine the information we receive from those other sources with information we collect through our Services. In those cases, we will apply this Privacy Policy to the combined information, including treating certain information as personal information.

Information Use

We may use the information we collect, including personal information and Usage Data to:

• enable you to use our Services, to create an account or profile, to process information you provide via our Services (including verifying that your email address is active and valid) and to process your transactions;
• process your personal information for event registration and participation;
• assist you with hotel arrangements in connection with our events;
• inform you of our events, meetings, content, initiatives, and other benefits and opportunities;
• to provide related customer service and care, including responding to your questions, complaints, or comments and sending surveys (with your consent) and processing survey responses;
• to fulfill paid subscription services and report back usage information to the subscribing entity;
• to provide you with information, products, or services that you have requested;
• with your consent, to provide you with information, products, or services that we otherwise believe will interest you, including special opportunities from us and our third- party partners;
• to tailor content, recommendations, and advertisements we and third parties display to you, both on our Services and elsewhere online;
• for internal business purposes for new content, products, and services, and to improve, test, and enhance the features and functions of our current Services;
• to administer and process contests, sweepstakes, and promotions, provided that such contests, sweepstakes and promotions may carry their own separate terms of use and privacy policy, in which case those policies would further govern your participation;
• to contact you with administrative communications and, in our discretion, changes to our Privacy Policy, Terms of Use, or any of our other policies;
• to comply with regulatory and legal obligations; and
• for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

Social Network and Platform Integration

Our Services may contain integration with social networks and other platforms in which information is shared between us and such platforms (e.g., Facebook, Instagram, Twitter). For example, if you create or log into your account through a third-party social media site, we will have access to certain information from that site, such as your name, email address, account information, photo and friends lists, and other information in accordance with the authorization procedures determined by the social media site. If you visit our Services on a device through which you also interact with social networks or if you interact with us through a social media function such as a plug-in (for example, a Facebook “like” button) then you permit us to have on-going access to, to use and to store some information from your social network profile (such as your name, email address, your friend list, photo, age, gender, location, birthday, social networking ID, current city, and the people/sites you follow) according to this Privacy Policy. If you don’t want a social network to collect the information about you, or you don’t want a social network to share it with us, please review the privacy policy, privacy settings and instructions of the applicable social network before you visit and use our Services. We are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by social networks. We encourage you to read the privacy policies of websites that you visit so that you understand how they collect and use your information before using these websites.

Our Information Sharing Practice

Generally: We may share non-personalized data, including Usage Data, deidentified data and aggregated user statistics, with third parties in our discretion. We may share user’s information, including personal information, as otherwise described in this Privacy Policy, and under the following circumstances:

Service Providers: We may enter into relationships with third parties who provide services to us (for example, analytics companies, advertisers and ad agencies, data management and storage services or credit card processing services, sweepstakes or contest prize fulfilment). In those circumstances, we disclose user information so that the service providers may perform those services. These service providers are only permitted to use your personal information to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal information. In particular, our sites use certain Google analytics and other services, and certain pages use the Google AMP Client ID API, each of which may enable collection and sharing of your information (including personal information) with Google for further use. For specific information on Google usage and how to control it, please see How Google uses data when you use our partners’ sites or apps and Google’s Privacy Policy.

Your Organization and Contacts. We may share your personal information with your organization and others with whom you have a relationship in order to fulfill or perform a contract or other legal obligation, including with our customer that arranges access to our Services for you and pays us in connection with your access. We may also share your personal information with your contacts if you are in the same organization or to facilitate the exchange of information between you and the contact(s).

Third Party Marketing: We may share your information (including personal information) with third parties for their own direct marketing purposes. Messages delivered from a third party will subject you to the third party’s privacy policy. We may also match your email address with third parties with whom you have also consented to share your email address and use such match to deliver custom offers or emails to you.

Business Transition. If we go through a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of our assets, including during the course of any due diligence process), your personal information will likely be among the assets transferred. By providing your personal information, you agree that we may transfer such information in those circumstances without your further consent.

Other Disclosure Scenarios. We reserve the right, and you hereby expressly authorize us, to share your information: (1) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims; (2) if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent, or take action regarding significant abuse of our Services infrastructure or the internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information); (4) to protect and defend our legal rights or property, our Services or other users, or any other party, and to protect the health and safety of our users or the general public; (5) to our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); and (6) when required by law.

We will, to the extent required by law and the applicable customer contract, obtain assurances before disclosing personal information to a subcontractor or third party agent that the recipient will (a) use the personal information only to assist us in providing, maintaining or improving our Services, (b) provide at least the same level of protection for personal information as is required of us, and (c) notify us if the recipient is no longer able to provide the required protections.

Technomic Paid Research and Subscription Services

Users of Technomic’s paid research products and services agree to this Privacy Policy and understand that access to these products and services is authorized through a paid agreement between their organization and Technomic. Any changes to the paid agreement may affect the products and services users may access.

To access online paid research products and services, users must validate their identities, create log in credentials, and provide certain information to create a profile in the system.

Users understand that Technomic may disclose all digital behaviors collected when using these paid services to a user’s organization, and for its own purposes related to analyzing usage and improving the quality of our Services.

Technomic Contact Databases

Technomic maintains databases of key personnel at industry related companies. Technomic subscribers pay a fee to access these databases. In some cases, the contacts listed are a matter of public record and in other cases, contact information is discovered through research. European Union and United Kingdom residents listed as a contact in one of these databases have certain rights described below relating to their personal information.

Anonymous Data

When we use the term “Anonymous Data”, we are referring to de-identified information and Usage Data, either alone or when combined with any other information available to a third party. We may create Anonymous Data from personal information we receive about you and other individuals whose personal information we collect. Anonymous Data might include analytics information and information collected by us using Cookies. We make personal information into Anonymous Data by excluding information (such as your name, address, email address) that makes the data personally identifiable to you. We use this Anonymous Data to analyze usage patterns to make improvements to our Services.

Public Information

If you identify any information as public, you authorize us to share such information publicly. For example, you may elect to make certain of information (such as your alias, bio, email, or photos) publicly available. Also, there may be areas of our Services (for example, message boards, discussion rooms, and other online forums) where you are able to post information that is available to all other users of our Services. By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any information that you post to those areas.

Users Outside of the United States and Consent to Transfer

Our Services are operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored, and processed in the United States. By using our Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

Important Information for European Union and United Kingdom Users

If you are a user from the European Union or United Kingdom, you should be aware that Winsight is the controller of your personal data (Data Controller) under the EU General Data Protection Regulation (“GDPR”) and the UK General Data Protection Regulation (“UK GDPR”)

You may have certain additional rights regarding your Personal Data (as defined in GDPR), including the right to:

• access your information;
• rectify your information if it is incorrect or incomplete;
• have your information erased (“right to be forgotten”) if certain grounds are met;
• withdraw your consent to our processing of your information at any time, if our processing is based on consent;
• object to our processing of your information, if our processing is based on legitimate interests;
• object to our processing of your information for direct marketing purpose; and
• receive your information from us in a structured, commonly used, and machine-readable format, and the right to transmit your information to another controller without hindrance from us (data portability).

There is no charge for any of these requests. To make a request, please contact us at Winsight, LLC, 300 S. Riverside Plaza, Suite 1600, Chicago, IL, 60606, by phone at (312) 876-0004 or send us an email at privacyrequests@winsightmedia.com. We try to respond to such requests in a timely manner, but in no event longer than one month.

When we collect your Personal Data, we maintain and store it for as long as we determine reasonably necessary to provide our Services to you, unless you exercise your right to erasure described above, or to comply with applicable legal requirements.

Legal Basis for Processing

If you are a citizen of the European Union or United Kingdom, when we process your Personal Data, we will only do so in the following situations:

• We have a contractual obligation.
• You have provided your consent. You are able to remove your consent at any time, and you may do this by contacting us at privacyrequests@winsightmedia.com.
• We have a legal obligation.
• We have a legitimate interest in processing your Personal Data. For example, we may process your Personal Data to send you marketing communications, relevant content, products, or events invitations, or to communicate with you about changes to our Services, and to provide, secure, and improve our Services.

Transfers of Personal Data

You should be aware that Personal Data that you provide to us may be transferred out of the country in which you reside to servers in a country that may not guarantee the same level of protection as the one in which you reside. Nevertheless, we will take all steps reasonably necessary to ensure that your Personal Data is treated securely in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to a third party unless there are adequate controls in place, such as the EU’s Standard Contractual Clauses, to protect your Personal Data.

Questions or Complaints

If you are user in the European Union or United Kingdom and have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article- 29/structure/data-protection-authorities/index_en.htm.

Advertising

General: We may use other companies under agreements with us to serve third-party advertisements when you visit and use our Services. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to our Services and other web sites to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies, not this one.

Targeted Advertising: To deliver offers and advertisements that may be of interest to our users, we may display targeted advertisements on our Services, or other digital properties or applications in conjunction with our content, based on information provided by our users and information provided by third parties that they have independently collected. User information is sometimes provided to sponsors and advertisers as a result of interacting with their advertising, branded content, or other products.

Your Ad Choices: Some of the third-party services providers and/or advertisers may be members of the Network Advertising Initiative (“NAI” or the Digital Advertising Alliance (“DAA”) Self- Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information about targeted advertising and the “opt-out” procedures of NAI members. You can opt-out of our use of your website viewing behavior data to serve you interest-based advertising on third-party sites and email newsletters here http://www.aboutads.info/choices/.

Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online or on your device.

Mobile: We may from time to time offer certain location or pinpoint based services, such as location assisted navigation instruction. If you elect to use such location-based services, we must periodically receive your location to provide such location-based services to you. By using the location-based services, you authorize us to: (i) locate your hardware; (ii) record, compile and display your location; and (iii) publish your location to third parties designated by you by means of location publication controls available within the applications (for example, settings, user preferences). As part of the location-based services, we may collect and store certain information about the users who elect to use such location-based services, such as a device id. This information will be used to provide you the location-based services. We may use third-party providers to help provide location-based services through mobile systems (unless you opt out of such location-based services with such providers) and we may provide the information to such providers to enable them to provide their location-based services, provided that such providers may use the information in accordance with this Privacy Policy.

Choice/Opt-Out from Communications

We offer you the opportunity to manage your communications from us. Even after subscribing to one or more newsletters and/or opting in to one or more offers to receive marketing and/or promotional communications from us or our third-party partners, users may elect to modify their preferences by going to the Communications Preferences page anytime or by following the “Communications Preferences” and/or “Unsubscribe” link provided in an email or communication received.

You may also be able to change your preferences by updating your profile or account, depending on which of our Services you are using. Please be aware that if you wish to remove yourself from a newsletter and/or other marketing emails from third parties that you consented to through our Services, you must do so by contacting the relevant third-party. Even if you do opt-out of marketing emails, we reserve the right to send you transactional and administrative emails including those related to our Services, service announcements, notices of changes to this Privacy Policy or other Services policies, and to contact you about any goods or services you have ordered.

In some cases, we will offer special content, products, or services in exchange for an email address that might be used to share our various editorial or marketing products. Our sponsors and clients may make similar offers to our audiences via our digital products, in which case the email address will be shared with that client. We will make reasonable efforts to be transparent about that sharing when you offer your email address.

Modifying and Deleting Your Personal Information

You may access the information we hold about you. If you wish to exercise this right, please contact us using the details in the Contact Us section below. If you would like to update, correct, modify, or delete from our database any personal information you previously submitted to us, please let us know by accessing and updating your profile. If you delete certain information, you may not be able to order services in the future without re-submitting such information. We will comply with your request as soon as reasonably practicable. Also, we will maintain personal information in our database whenever we are required to do so by law.

If you are using our Services through one of our customers, such as your employer, you may not be able to opt out of our Services if we are directed by our customer to supply the Services to you and you should contact your organization if you have questions or concerns about privacy or our use of your information.

We may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (for example, when you enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such promotion). We will retain your personal information for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Security

We have implemented commercially reasonable and appropriate security measures to help protect your personal information from loss, misuse, or unauthorized access or disclosure; we use standard, industry-wide practices such as firewalls, encryption of personal information at rest and in transit to protect your information.

Unfortunately, however, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your user information, including personal information, we cannot guarantee its security. You use our Services and provide us with information at your own initiative and risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Us section below.

Links

Our Services may contain links to other websites that we do not control, and our Services may contain videos, advertising and other content hosted and served by third parties. We are not responsible for the privacy practices of any third-party.

Children's Privacy

We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and do not use our Services to knowingly collect personal information from children under the age of majority in your jurisdiction, including any information that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent.

If you are a child under the age of majority in your jurisdiction, you are not permitted to use our Services and should not send any information about yourself to us through our Services. If we become aware that we have collected personal information from any child under the age of 13, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at (312) 876-0004 or send us an email at privacyrequests@winsightmedia.com. You may also contact us by postal mail or by fax, using the following: Winsight, LLC, 300 S. Riverside Plaza, Suite 1600, Chicago, IL 60606 Fax: (312) 876-1158.

Sensitive Personal Information

We ask that you not send us, and you not disclose, any sensitive personal information (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through our Services or otherwise to us.

If you send or disclose any sensitive personal information to us, we will treat it as personal information and you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such data to our Services.

Changes

We may update this Privacy Policy from time to time in our discretion and will notify you of any material changes to the way we treat personal information, by posting a notice on relevant areas of our Services. We may also provide notice to you in other ways in our discretion, such as through contact information you provided. Any updated version of this Privacy Policy will be effective upon the posting of the revised Privacy Policy, unless otherwise specified. Your continued use of our Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. We will not, however, without your consent, use your personal information in a manner materially different than what was stated at the time your personal information was collected.

Contact Us

Should you have any questions or concerns about this Privacy Policy, please call us at (312) 876- 0004 or send us an email at privacyrequests@winsightmedia.com. You may also contact us by postal mail or by fax, using the following: Winsight, LLC, 300 S. Riverside Plaza, Suite 1600, Chicago, IL 60606. The fax number is (312) 876-1158.

California Rights Notice

Additional Notice for California Residents

At Winsight, we are mindful of our responsibilities under the California Consumer Protection Act (“CCPA”). If you are a California consumer within the meaning of the CCPA, these California-specific provisions apply to you.

Most visitors to our website are representatives of businesses seeking to interact with us as part of their jobs, and such business-to-business interactions do not fall within the scope of the CCPA.

How We Collect, Use, and Share Personal Information

1. Personal Information Collected in the Last Twelve Months

We collect information from users as described in our Privacy Policy. The “Personal Information”, as defined in California Civil Code § 1798.140(o), we have obtained on California residents within the last twelve months includes:

1. Identifiers such as name, postal and email addresses, IP address, unique personal identifier, online identifier, token identifier, or account name when you register to use our Services, purchase our products and services, interact with us on social media, or sign up to learn more about our products and services.
2. The following categories of protected classification characteristics under California or federal law:
   i. Gender when you create an account and choose to submit this optional information.
   ii. Commercial information such as records of products or services purchased, or obtained, or considered from us.
   iii. Internet or other similar network activity information, including, but not limited to, browsing history on our websites, search history, information on a consumer’s interaction with our websites or applications.
   iv. Geolocation data such as physical location or movements.
   v. Sensory data such as audio information, including recordings of when you called into our support line; video information in the form of CCTV at our local storefronts; and electronic information in the form of Internet or other electronic network activity information as described above.
   vi. Current or past professional or employment-related information, including past job history or performance evaluations.
   vii. Inferences drawn from other Personal Information, such as profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

For each of these categories, we obtain Personal Information from a variety of sources. For more information about our collection practices, please see “Information We Automatically Collect,” “Information You Choose to Submit,” and “Information We Receive From Other Sources” above.

Personal Information does not include publicly available information from government records, deidentified or aggregate consumer information, and Personal Information protected by certain other sector-specific federal or California statutes.

2. Our Use of Personal Information for Business Purposes in the Last Twelve Months

We use the Personal Information we collect, identified in each of the above categories, for the business purposes disclosed within this Privacy Policy. These business purposes include:

1. Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
2. Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
3. Debugging to identify and repair errors in our systems;
4. Short-term, transient use including contextual customization of ads;
5. Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
6. Conducting internal research to develop and demonstrate technology;
7. Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide;
8. Preparing statistics and performing analysis to support our operations;
9. Conducting marketing and surveys regarding our products and industry; and
10. Receiving and responding to inquiries.

We may also use the Personal Information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the Personal Information was collected.

3. Sharing of Personal Information in the Last Twelve Months

1. Disclosures of Personal Information on California Consumers for Business Purposes.

   Within the last twelve months, we have disclosed Personal Information identified in the above categories only (i) for exempt activities, as part of a business-to-business transaction, (ii) at your express request, or (iii) for our business purposes. For more information on the service providers with whom we share information, please see Our Information Sharing Practices

   When we disclose Personal Information for a business purpose, we execute a contract that describes the purpose and requires the recipient to keep Personal Information confidential and not use it for any purpose except performing the contract.

2. Sales of Personal Information

   Within the last twelve months, within the meaning of the CCPA, we have transferred information to digital ad networks to assist with marketing on our behalf (or on behalf of the associations and companies we work with). We provide an opt-out mechanism for these transfers below, but the best way to opt-out of digital marketing is by using the advertising opt-out mechanism in the Self-Regulatory Program for Online Behavioral Advertising at Your Ad Choices. To learn more about targeted advertising and “out-out” procedures of NAI and DAA members, please visit http://www.networkadvertising.org/managing/opt_out.asp. You may also opt-out of our use of your website viewing behavior data in order to provide you with interest-based advertising on third-party sites and email newsletters here http://www.aboutads.info/choices/.

   We do not disclose Personal Information of individuals we know to be under the age of 16 to businesses or third parties for monetary or other valuable consideration as a “sale” under the CCPA without affirmative authorization.

California Rights and Choices

If you are a California resident, you have certain rights related to your Personal Information. You may exercise these rights free of charge except as otherwise provided by applicable law. We endeavor to respond to your request promptly upon verification and as required by applicable law.

1. Right to Know / Portability

   You have the right to request that we disclose to you:

   • Specific pieces of Personal Information we have collected about you;
   • Categories of Personal Information we have collected about you;
   • Categories of sources from which the Personal Information was collected; o Categories of Personal Information that we sold or disclosed for a business purpose about you;
   • Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
   • The business or commercial purpose for collecting or selling Personal Information.

2. Right to Deletion

   You have the right to request that we delete (and direct our service providers to delete) Personal Information we collected about you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

   • complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
   • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
   • debug products to identify and repair errors that impair existing intended functionality;
   • exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
   • comply with the California Electronic Communications Privacy Act;
   • engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
   • enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
   • comply with a legal obligation; or
   • make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3. Right to Opt-Out

   You have the right to direct us to not sell your Personal Information. As described above, our only sale involves digital marketing activity and the best way to opt-out is using the Self- Regulatory Program for Online Behavioral Advertising at http://www.aboutads.info/choices/. To submit an opt-out request through Winsight, click here or call our toll free number listed in “How to Submit a Request” below.

4. Right to Non-Discrimination for Exercise of a California Privacy Right

   We will not discriminate against you because of your exercise of any of the above rights, or any other rights under the CCPA. This means that we may not deny you goods or services, charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under the CCPA.

   We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.

5. How to Submit a Request

   You may submit a request to exercise these rights by:

   • Submitting an online request at Rights Request
   • Emailing us at privacyrequests@winsightmedia.com
   • Calling us toll-free at 800-607-5425
   • Writing us at Winsight, LLC, Inc., c/o General Counsel, 300 S. Riverside Plaza, Suite 1600, Chicago, IL 60606

   You must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine whether this applies to you. We will not accept inquiries via email or by facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.

6. Verifiable Request

   As required under applicable law, we take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information sufficient to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and to describe your request with sufficient detail that allows us to understand, evaluate, and respond to it. For example, we may request you provide contact details to be verified with the email address recorded in our files (and subsequently verified by you). We may limit our response to your exercise of the above rights as permitted under applicable law.

7. Agent Authorization and Disability Access

   You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require additional information to prove your agent’s relationship to you. We may refuse a request if the agent does not provide adequate proof of their authorization. You may also make a verifiable consumer request on behalf of your minor child, but you must also provide proof that you are that child’s parent or legal guardian.

   Consumers with disabilities may access this notice in an alternative format by emailing us at privacyrequests@winsightmedia.com or calling us toll-free at 800-607-5425

Other California Privacy Rights

1. California “Shine the Light” Law (Civil Code Section § 1798.83)

   Under the Shine the Light Law, a California resident may ask us to refrain from sharing your Personal Information with third parties for their direct marketing purposes. To make such a request, please contact us using the contact information below.

2. California Do Not Track Disclosure

   California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Winsight responds to “Do Not Track” browser settings. There currently is no consensus among industry participants as to what “Do Not Track” means in this context. Therefore, like many websites and online services, our Services do not alter their practices when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track”, please visit http://www.allaboutdnt.com.

Contact Information about this California Notice

You may contact us with questions or concerns about our privacy policies or practices and your choices and rights under California law by:

1. Calling us toll-free at 800-607-5425
2. Emailing us at privacyrequests@winsightmedia.com

You must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine whether this applies to you. We will not accept inquiries via email or by facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.

Other States Privacy Rights

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal information processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, considering the information’s nature and processing purpose.
• Opt-out of profiling to further decisions that produce legal or similarly significant effects.
• To exercise any of these rights please call us toll-free at 800-607-5425 or email us at privacyrequests@winsightmedia.com.

Subscribers to Winsight Membership

We may use and/or disclose your Personal Data or Usage Data to provide the products and services you request or that are offered as part of your subscription, process transactions, and send you related information, including confirmations, receipts, and subscription renewal information. All financial data will be independently processed by Stripe and is subject to Stripe’s Privacy Policy and Services Agreement. Financial data is not handled by Winsight internally. All subscriber data becomes integrated with our overall database and digital platforms and is subject to the same processing and use outlined in the overall Privacy Policy. Subscribers also agree to the Terms and Conditions set forth by Winsight.