GLOBAL CIO MEDIA, LLC PRIVACY STATEMENT

GLOBAL CIO MEDIA, LLC (“GCM”) understands that your privacy is important to you and that you care about how your Personal Data is used and shared online. We respect and value the privacy of everyone who visits this website, CIOTalkNetwork.com (“CTN”) and GCM will only collect and use Personal Data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the applicable law(s).

This is to confirm and share that GCM collects personally data (PII/PI/PD) and other data about individuals, their company, and the company’s demographics (“personally identifying information and data”) including:

• when you provide information to GCM, such as when you register or sign up for any of Our products such as publications, subscriptions, e-mails, contests, newsletters, memberships, RSS Feeds, content delivery via SMS text or other technologies, webcasts, white papers, online seminars, conferences and other communications with GCM,
• when you register or sign up on CTN or when you register for any other GCM products individually or through “auto-register”, your information will be known to GCM and from time to time, We may append additional information that We collect from third party sources to enhance the information that you provided to GCM.

Please read this privacy statement carefully and ensure that you understand it. Your acceptance of this privacy statement is deemed to occur upon your first use of CTN Site or any GCM products. If you do “NOT” accept and agree with this privacy statement, you must stop using CTN and GCM products immediately.

1. Information About Us

• Our Site is owned and operated by Global CIO Media, LLC, with Federal Identification Number as 36-4214414, with registered address as 1797 Trevino Circle, Bolingbrook, IL 60490.
• Our Data Protection Officer is Raksha Sharma and can be contacted by email at dpo@ciotalknetwork.com or via board phone 630 596 8026.

2. Definitions and Interpretation

“We/Us/Our” represents GCM, a company registered in the United States of America, under Federal Identification Number 36-4214414, whose registered address is 1797 Trevino Circle, Bolingbrook, IL 60490.

• “Cookie” is a small text file placed on your computer or device by GCM when you visit certain parts of Our Site and when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Our Use of Cookies section below;
• “Cookie Law” refers to the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
• “Personal Data” represents all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means Personal Data that you give to us via CTN site and other electronic means associated with business operations. This definition shall, where applicable, incorporate the definitions provided in the local law, NIST Privacy Framework, and applicable US laws and standards.
• LAW – the applicable data privacy and protection law on the business activity, including however not limited to California’s Consumer Privacy Act (CCPA), EU General Data protection Regulation and UK DPA 2018.
• Data Subject – A natural living individual whose data is being collected, used, stored or shared (processed) by GCM).
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. What Does This Statement Cover?

This privacy statement applies only to your use of Our website and electronic communication via such domain. Our domain hosted services may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites, and We advise you to check the privacy policies of any such sites before providing any data to them.

4. What Does This Statement Cover?

As a data subject, We respect that you may have the following rights based on your residency and which may vary (in case of other countries – however We go with maximum privacy commitment), which this privacy statement and Our use of Personal Data have been designed to uphold:

• The right to be informed about Our collection and use of Personal Data;
• The right of access to the Personal Data We hold about you as referred to in section 12);
• The right to rectification if any Personal Data We hold about you is inaccurate or incomplete. For such cases, please contact Us using the details provided in section 15);
• The right to be forgotten which refers to the right to ask Us to delete any Personal Data We hold about you. We only hold your Personal Data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 15);
• The right to restrict which refers to the right to prevent Us from processing your Personal Data;
• The right to data portability which refers to obtaining a copy of your Personal Data to re-use with another service or organization;
• The right to object to Us using your Personal Data for specific purposes;
• The rights related to automated decision making and profiling

If you have any cause for complaint about Our use of your Personal Data, please contact Us using the details provided in section 15 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to file a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

For further information about your rights, please contact the designated data protection authority of your state or Information Commissioner’s Office or your local Citizens Advice Bureau.

5. Purpose to Collect the data?

The aggregated information We collect is used for purposes including the following:

• to improve the content and design of the Our site, products, and services
• to enable audit bureau to verify Our claims of traffic to the site
• to help advertisers, potential advertisers or marketers assess the suitability of Our site, products and services for their ad campaigns
• as clear GIFs, also known as pixel tags, provided by Our ad-serving company to help manage online advertising. These clear GIFS let Our ad-serving company recognize a browser’s cookie when a user visits Our site. The information We collect and share through this technology is not personally identifiable (It does not include your name, address, telephone number or e-mail address). For more information about Our ad-serving company or for your choices about not having this anonymous information used, please visit www.doubleclick.net/privacy_policy/
• GCM may contract with DoubleClick. to serve advertising on CTN, both on the Web site itself and through its e-mail newsletters. When DoubleClick is serving ads, it recognizes certain types of non-personally identifiable information, such as a user’s IP address, browser version or type, operating system, service provider and time zone. DoubleClick also uses cookies to note the general content of the sites that users visit over time in order to serve ads on this site and other sites. Any pages a user calls up on CTN aren’t connected with personally identifiable information collected either at www.CIOTalkNetwork.com or elsewhere. For more details about the non-personally identifiable information DoubleClick collects and the opportunity to opt out of such data collection, please visit www.doubleclick.net/privacy_policy/. We use web metric vendors to gather information to help Us understand how users utilize Our websites and other electronic products.
• We may create and use aggregate customer data to understand more about the interests of Our customers and may use the data to offer goods and services We believe may be of interest to Our customers, on behalf of GCM, its sister companies, or select organizations.

6. What do We collect?

• Postal addresses, and other personally identifying information and data will be used to promote GCM and other Global CIO Media companies’ products and services and may be rented and/or licensed to selected outside firms for promotional purposes. Offers for which the personally identifying information and data are rented and/or licensed for use and the users are required to target their offers carefully.
• Mobile telephone numbers that are provided to GCM will be used to provide the products and services you’ve specifically requested, such as, but not limited to content delivery via SMS or other technologies, and for customer service related to the products and services you’ve requested. With your express consent, your mobile telephone number may be used to promote other products and services of GCM, as well as the products and services of other GCM companies. Further, your mobile phone number may, with your express consent, be used to promote the products and services of carefully chosen third parties. At any time, you may “opt-out” of receiving communications via your mobile phone from GCM, other GCM companies, and third parties, by clicking the unsubscribe link of any individual message you may receive. Because many phone companies recycle phone numbers, it is possible for users who purchase a new phone to receive messages that the previous owner had subscribed to or otherwise consented to receive.
• E-mail addresses of GCM online subscribers are used for re-qualification purposes. These e-mail addresses may also be used to collect feedback by members of Our editorial or research team, to promote GCM and GCM products and services, and they may be rented to other firms and/or licensed for promotional purposes. When you provide your email address to us, you agree to receive email from GCM and its sister GCM companies. We allow users to “opt-out” of receiving e-mail from outside firms, however, when e-mail information is collected and with each e-mail use of the user’s address you can individually “opt-out” of receiving further e-mail from outside firms, GCM, its sister GCM companies. If a user does not choose to “opt-out” at the time the e-mail address is collected, or does not respond to the questions concerning how We may use their email address, the address may be rented and/or licensed for use to outside firms. Offers for which the e-mail address is rented and/or licensed for use require the users to target their offers carefully.

Depending on nature of our interaction and business engagement we may process one or more of the following categories of Personal Information about you:

• Personal details: your name; username or log in details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
• Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
• Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
• Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
• Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
• Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
• Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.

7. How Do We Use Your Data?

• All Personal Data is processed and stored securely, for no longer than is necessary considering the reason(s) for which it was first collected. We will always comply with Our obligations and safeguard your rights under the law.
• Our use of your Personal Data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your Personal Data, e.g., by subscribing to emails), or because it is in our legitimate interests.
• Specifically, We may use your data for the following purposes:
  • Providing and managing your access to Our Site;
  • Personalizing and tailoring your experience on Our Site;
  • Supplying Our products and services to you. Please note that We require your Personal Data in order to enter into a contract with you;
  • Personalizing and tailoring Our products and services for you;
  • Replying to emails from you;
  • Supplying you with emails that you have opted into, which you may unsubscribe or opt-out at any time;
  • Market research;
  • Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience

• With your permission and/or where permitted by Us or other contractual obligations via applicable law including however not limited to PECR, PIPEDA, EU LAW, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the palpable privacy law.
• You have the right to withdraw your consent to Us using your Personal Data at any time, and to request that We delete it. We do not keep your Personal Data for any longer than is necessary considering the reason(s) for which it was first collected

We do not seek to collect or otherwise Process your Sensitive Personal Information. Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable law. The Services are not intended for use by children.

We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
• Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
• Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defence of legal rights; or
• Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.

Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or podcast.

If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). And if it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.

8. How and Where Do We Store Your Data?

• We only keep your Personal Data for as long as We need to use it as described above in section 7, and for as long as We have your permission to keep it.
• Your data will only be stored in CLOUD BASED STORAGE .
• Data security is critical to Us, and to protect your data, We have taken suitable measures to safeguard and secure data collected through Our Site.

9. Do We Share Your Data?

• In certain circumstances, We may be required legally to share specific data held by Us, which may include your Personal Data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
• We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law,
• We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
• We may sometimes use third party data processors that are located outside the boundaries of US and for EU that outside of the European Economic Area (“EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. Where We transfer any Personal Data outside the United States (“US”) or EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the US or European Union (“EU”).
• In certain circumstances, We may be legally required to share certain data held by Us, which may include your Personal Data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority

10. What happens if Our Business Changes Hands?

• We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any Personal Data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use that data only for the same purposes for which it was originally collected by Us.
• If any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
• We may transfer your Personal Information to recipients in other countries. GCM will do so on the basis of standard contractual clauses or as per remedies available in the applicable jurisdiction including “explicit consent”.

11. How Can You Control Your Data?

• In addition to your rights under the , when you submit Personal Data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.
• You may also wish to sign up to one or more of the preference services operating in the US: such as do not contact/call (DNC). These may help you prevent receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
  12. Your Right to Withhold Information
• You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
• You may restrict Our use of Cookies. For more information, see section 14

13. How Can You Access Your Data?

You have the right to ask for a copy of any of your Personal Data held by Us (where such data is held). Under the LAW, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 15.

14. Our Use of Cookies

• Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and Personal Data is always protected and respected.
• All Cookies used by and on Our Site are used in accordance with current Cookie Law.
• Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
• Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
• Our Site uses analytics services. Website analytics refers to a set of tools used to collect and analyze anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however, whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
• The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
  In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
• You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalization settings.
• It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. Data Security

We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

Our data protection measures includes :

• Data Accuracy
  We take every reasonable step to ensure that your User Information is kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
• Data Minimization
  We take every reasonable step to limit the volume of your User Information that we Process to what is necessary.
• Data Retention
  We take every reasonable step to ensure that your User Information is only retained for as long as they are needed or necessary law permits GCM to withhold.

16. For our California Consumers/visitors

The California Consumer Privacy Act (“CCPA) provides certain rights for California consumers. If you are a consumer residing in California, the following additional terms apply to you.

• Right to Know About Information Collected, Disclosed or Sold
  You have the right to request that we disclose what personal information we collect, use, disclose, or sell. To submit a verifiable request, please email us at Privacy@CIOTalkNetwork.com.
  Please note that we will verify the request by sending an email to the email address used to make the request. We may ask for additional information reasonably related to the request to verify the request.
• Collection of Personal Information
  The categories of California consumers’ Personal Information we may collect are listed above in Section 6. In reference to Section 6, we may collect Personal Details, Demographic Information, Contact Details, Consent Records, Location Information, Purchase and Payment Details, Employer Details, Views and Opinions. We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy.
• We use this data for the purposes listed above in Section 5 (“Purposes”).
• Disclosure or Sale of Personal Information
  We may and may have disclosed or sold the categories of Personal Information listed in Section 6 for a business or regulatory purpose.

We may and may have disclosed Personal Information to the following categories of third parties for a business purpose:

• other entities within the Company group for a legitimate business purpose such as operating the Services and providing the Services to you;
• third party Processors for the purpose of providing the Services to you;
• third party providers where our Services use third party advertising, plugins or content;
• third party providers to assist with the collection, storage and segmentation of Online Data. These third party providers may collect User Information from our Services for their own purposes, including but not limited to, monitoring fraud around the web;
• third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier.
• Third party partners such as marketing and advertising companies and agencies, content publishers, retailers, third party providers of goods and services; or service providers whose services are embedded into and/or appear within the Services when you use a co-branded service (a service operated with a partner of GCM or register or otherwise provide information on such co-branded site. This information is only passed on if and when you grant us permission to pass the collected information back to that third party;

Our services are not intended for use by minors. We do not sell personal information of minors under 16 years of age without affirmative authorization. (for Californian resident the age bar is 16 and in general we have 13)

• Right to Request Deletion of Personal Information
  You have the right to request deletion of Personal Information collected or maintained by us. To do so, please submit a request via DSAR Portal or by emailing Privacy@CIOTalkNetwork.com.. If submitting a request by email, we may ask for additional information to verify your request.
• Right to Opt-Out of the Sale of Personal Information
  You have the right to opt-out of the sale of Personal Information by a business. To do so, please submit a request via DSAR Portal or by emailing Privacy@CIOTalkNetwork.com. If submitting a request by email, we may ask for additional information to verify your request.
• Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
  You have the right not to receive discriminatory treatment by the business for exercising your privacy rights conferred to you by the California Consumer Privacy Act.
• Authorized Agent
  To make a request under the California Consumer Privacy Act on a consumer’s behalf, we require a signed authorization letter from the consumer to Privacy@CIOTalkNetwork.com..

17. Contact for More Information

• If you have any questions or concerns about our privacy policies and practices, you may contact us on the details provided below or email us at Privacy@CIOTalkNetwork.com.
• If you are a Californian data subject, you have the right to opt out of the sale of your information. To opt-out, you can also call us at our US toll-free number (888) 330-4332.

18. Date Privacy Policy Last Updated

Our Privacy Policy was lasted updated as of the date indicated at the beginning of the policy.

19. Contacting Us

If you have any questions about Our Site or this Privacy Statement, please contact Us by email at Privacy@CIOTalkNetwork.com. Please ensure that your query is clear, specifically if it is a request for information about the data that We hold about you.

20. Changes to Our Privacy Statement

We may change this Privacy Statement from time to time due to reasons including changes in applicable laws. We will immediately post changes on Our Site, and you will be deemed to have accepted the terms of the Privacy Statement on your first use of Our Site following the alterations. We recommend that you check this page regularly to stay up to date.

Version: 4.0
Last updated: April 29, 2021