Terms & Conditions

We understand how important it is to keep your information safe and secure and we take this very seriously. We have taken steps to make sure your information is looked after in the best possible way and we review this regularly. Please read this Privacy Notice (‘Privacy Notice’) carefully, as it contains important information about how we use the information about you we collect, store and use.

Definitions

In this Privacy Notice the following words are used as set out below:

• Inconf is referred to as ‘we’, ‘us’, ‘our’, or Inconf.
• ‘Our Clients’ means event organisers and/or their event production companies or agencies.
• ‘Your information’ means personal data that may be used to identify you as an individual.
• ‘CRM’ means the system used to manage sales leads that come in via our website/ email, and to store contact data for prospects, targets and marketing.

We are required to provide you with this Privacy Notice by Law. It explains how we use the information we collect, store, and hold about you. If you are unclear about how we process or use your information, or you have any questions about this Privacy Notice or any other issue regarding your information, then please contact our Data Protection Lead (see paragraph 3 below). The Law says:

• We must let you know why we collect information about you
• We must let you know how we use any information we hold on you
• We need to inform you in respect of what we do with it
• We need to tell you about who we share it with or pass it on to and why
• We need to let you know how long we keep it for

We are Inconf a company registered in England and Wales with company number 12399032 and our registered address is 28 Alexandra Terrace, Exmouth, Devon, EX8 1BD. We deliver virtual event platforms and live streaming services for brands, corporations, associations, rights-holders, event management agencies and production companies. (‘the Service’). We receive data from Our Clients or their event production companies or agencies. Other data collected includes but is not limited to questions submitted, polling responses, surveys, profiles and instant messages directly from the data subject during their interaction with the Inconf Platform. When delivering virtual events on behalf of Our Clients, we are the Data Processor and our Client (and/or their event management company / agency) is the Data Controller. We also collect data about our sales prospects and targets . This data is typically collected via LinkedIn, websites and our personal networks of contacts and is stored in our CRM (Customer Relationship Management) system. We are the Data Controller of our sales and marketing information unless we are a Data Processor as referred to above. The purposes for which we collect and use your information are set out in this Privacy Notice.

Our Data Protection Lead is Daniel Cave, Chief Experience Officer If you have a query or need any further information about this Privacy Notice or wish to make a complaint, please email the Data Protection Lead at: [email protected]

All information collected will only be used for the purpose of providing the Service as described in this Privacy Notice. We will collect and use the information you have provided for the purposes of:

• Populating the website and virtual event platform so that users can read about the agenda and speakers at an event
• User data, including first name, last name, company name, job title and email address, is entered into the back-end database to facilitate users logging into the system
• Data collected during users’ interaction with the Inconf platform, for example questions submitted, polling responses, surveys, profiles, instant messages etc. is used to facilitate the user’s engagement with event content and with other delegates.
• Event feedback data will inform the planning of future events.
• CRM data is used in our sales and marketing activities for example doing email campaigns, telemarketing, or inviting targets to join webinars we are hosting.

We may collect the following information either from Our Clients or on behalf of Our Clients

• First name and last name
• Job Title
• Company Name
• Email address
• A short biography or profile
• Questions that users have posed (in writing) to speakers or presenters
• Answers to polling questions that users have submitted via the platform either multiple choice or free-text responses
• Responses to surveys / questionnaires / feedback forms completed by users via the platform
• Instant messages sent between delegates / exhibitors / sponsors / presenters via the platform’s networking tools
• Notes captured when a user types into the platform during an event
• Analytics information to enable reporting on event attendees, sessions attended, duration of attendance, expo stands visited, which documents they downloaded and how they answered polling questions

In addition, we may collect the following:

• Information regarding Our Clients and prospects on our CRM as part of our sales process
• The contract/project plan and the billing details for Our Clients.

The law states that we must collect and use your information in accordance with a legal basis. We will only use any information that you provide in accordance with the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (‘UK GDPR’), the Data Protection Act 2018 and any other relevant legislation, regulation, code of practice or guidance. The legal basis for collecting and using your information will depend on the information concerned and the specific context in which it is collected. We will normally use your information where:

• We have your consent to do so (you have a right to withdraw this consent at any time).
• We require the information to perform a contract with you. For example a user will be engaged by Our Clients by virtue of a contract to attend an event.
• The processing is in our legitimate interests (where we have a business or commercial reason to use your information) and this is not overridden by your data protection interests or fundamental rights or freedoms
• We have a legal obligation to process the information

We will keep your information for as long as necessary but in any event in accordance with our data retention and disposal policy, with current law and national guidance. All event data is deleted within 6 months days following the end of an event or project.

8. WHO WE SHARE YOUR INFORMATION WITH

We typically pass to Our Clients any data collected during their event, together with an analytics ‘insight report’ which gives them a summary of the key insights drawn from the data collected. We may pass on your information if we have a legal obligation to do so.

Your information may be used to report trends or reports to Our Clients. The data is used for analytics as a key part of the service to Our Clients and includes which delegates watched which sessions / downloaded which documents / visited which expo stands and submitted which questions. This information will not be anonymized which means it can identify you as an individual. Clients are offered the option for their delegates or visitors to be excluded from tracking if they wish.

We will not share your information for marketing purposes unless we have your consent.

• Be informed if your information is being used;
• Request access to the information that we have collected about you. We are obliged to provide this to you free of charge within one month of receipt of your request (unless your request is complex, or you have made numerous requests in which case it may take us longer). If your request is unfounded, excessive, or repetitive we may charge a reasonable administrative fee;
• Request the correction of any information held about you that is inaccurate or incomplete. We encourage you to inform us of any changes to your information so that we can ensure that the data we hold on you is accurate and up to date;
• Request the deletion or removal of your information where your information is no longer necessary for the purpose for which it was collected/processed, where there is no appropriate reason for us to continue processing it or where we have processed your information unlawfully. However, your request for deletion/removal may not always be met for legal reasons. You will be informed of these reasons when you make your request;
• Object to the processing of your information for a particular purpose or purposes.
• Restrict the processing of your information for example when you challenge the accuracy of the data, we hold on to you and we are verifying that data;
• Request portability of your information. This means you have a right to receive the information you provided to us in a way that is accessible and machine-readable. You also have the right to ask us to transfer your information to another organization if this is technically feasible;
• Not to be subject to automated individual decision-making and profiling (known as automated processing) if the decision affects your legal rights or has an important effect on you in some other way;
• Withdraw your consent at any time where we process your information on the basis of your consent. Please note that if you withdraw your consent, we may not be able to continue to provide you with our services. We will inform you of this at the time you withdraw your consent;

For further information on your rights please go to:https://ico.org.uk/your-data-matters/

12. RIGHT TO OBJECT AND COMPLAIN

You have the right to object to your information being used in some or all of the ways as described in this Privacy Notice. Please contact the Data Protection Lead should you have any questions or issues with the use of your information as described here.

You have the right to complain about the management of your information. In the first instance, please refer your complaint to the Data Protection Lead as detailed above. If you remain dissatisfied with our response you have a right to raise any concern or complaint with the Information Commissioner’s Office:https://ico.org.uk/

If English is not your first language, you can request a translation of this Privacy Notice. Please contact our Data Protection Lead for further information.

Our website uses cookies to enable certain core functionality such as allowing you to log in to the virtual event platform and to network with other participants. These cookies do not contain any sensitive or personal information and only act as a mechanism for our server to identify your user account as you move around the website.

When you visit our website, you are also prompted to allow us to collect additional information about how you use the website. This data is anonymized and is used to allow us to identify trends on our website and make improvements. For example, this anonymized data allows us to see how many people have visited a certain page on our website in a given month. Unless you click the “Allow cookies” option, we do not collect this data or store the Google Analytics tracking cookie that enables this functionality on your device.

For more information on ‘Cookies and similar technologies’ go to;https://ico.org.uk/your-data-matters/online/cookies/

Our website contains hyperlinks to other third-party websites. If you go to another website from our website, it is important that you read their Privacy Notice on that website to find out what it does with your information and their policies may differ from ours. We take no responsibility legal or otherwise for the content or use of information, personal or otherwise, on other websites.

Where we use third parties to process or use your information on our behalf, we ensure that we have a robust agreement in place which makes it clear that they must be compliant with the UK GDPR and any other relevant data protection legislation. We also make it clear that the information they may receive about you from us is only used in a manner consistent with the aims of Inconf and this Privacy Notice.

• Inconf’s platform is built on a WordPress Engine and uses Google Drive and Google’s Gmail for Business4
• It may be necessary during the course of any activities in relation to the use of the platform that WordPress will require access to your information but please rest assured that this is secure and done in compliance with data protection legislation.
• We store a mix of PII and non-PII data with 3rd parties such as Mixpanel, Google Analytics, WP engine and Slido depending on the features requested for each event.

We take the security of your information very seriously and we do everything we can to ensure that your information is always protected and secured. We regularly update our processes and systems and we also ensure that our staffs are properly trained. We also carry out assessments and audits of the information that we hold about you and make sure that, if we provide any other services, we carry out proper assessments and security reviews. The website is maintained by WordPress who are the website hosts and providers however they do not process any data on behalf of Inconf Ltd. Your information is held electronically. It is password protected and held securely on either our internal computer systems or on a third-party secure server. The data we collect can only be accessed by the key Inconf project team members including the Project Manager, Data Analyst, Developers and Senior Leadership Team.

We are obliged to protect any confidential information that we hold about you and we take this very seriously. It is imperative that you let us know immediately if you change any of the contact details you have given us or given to others to give us so as to ensure that the information, we hold about you is up to date and correct.

Please note that this Privacy Notice will be regularly reviewed and updated in line with current data protection legislation, regulation, and guidance. You should check this Notice occasionally to ensure you are aware of the most recent version that will apply each time you access this website.

This Privacy Notice was last updated on 1 July 2021

Cookies Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies.  These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies.These are used to recognise you when you return to our website. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title / Name	Purpose	More information
wpe-auth wordpress_logged_in_ wordpress_sec_	Cookies that support the basic functionality of the site,such as logging in.	–
gs_u_GSN gs_v_GSN-2194840-F gs_u_GSN gs_v_GSN >mp_<variable>_m	Cookies used by a service called Gosquared, which we use to track how many visitors are online at once.	Gosquared.com
_gat_UA-<variable>_ _dc_gtm_<variable>_ _gid _ga	Google analytics tracking software to measure how many visits we get and what users do.	Analytics.google.com
mp_<variable>_mixpanel	Mixpanel tracking software to measure how many visits we get and what users do.	Mixpanel.com
ONID sb presence pin xs _BEAMER_LAST_UPDATE_HLZbZZJA4756 usida c_user dpr datr __EX_d68e20632b79795d146f00d9ad8cfe95297749b6__ AWSALBCORS _BEAMER_USER_ID_HLZbZZJA4756 __exponea_time2__ AWSALBTGCORS fr _hjid currentAccountUuid __exponea_etc__ _ga	Cookie set by Vimeo player, to enable embedded videos to play, and to track the number of views and similar metrics.
Slido.EventAuthTokens _gaexp Slido.Privacy _persistenceTest	Cookies used by sli.do q&a tool to deliver functionality.	Sli.do

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. Except for essential cookies, all cookies will expire after various time periods. This Cookies Policy was last updated on 1 July 2021

Inconf Platform Terms of Use

Who we are and how to contact us

We are Inconf Ltd (“We”). We are registered in England and Wales under company number 12399032 and have our registered office at 28 Alexandra Terrace, Exmouth, England, EX8 1BD Our main trading address is 15 Victoria Road, Exmouth, England, EX8 1DL.

What’s in these terms?

This acceptable use policy sets out the standards that apply when you log in to this Platform or interact with our Platform in any other way.

By using our Platform you accept these terms:

By using our Platform, you confirm that you accept the terms of this policy and that you agree to comply with them. If you do not agree to these terms, you must not use the Platform.

We may make changes to the terms of this policy

We amend these terms from time to time. Every time you wish to use the Platform, please check these terms to ensure you understand the terms that apply at that time.

Prohibited uses

You may use the Platform only for lawful purposes. You may not use the Platform:

• In any way that breaches any applicable local, national or international law or regulation.
• In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.
• For the purpose of harming or attempting to harm minors in any way.
• To bully, insult, intimidate or humiliate any person.
• To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
• To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:

• Not to reproduce, duplicate, copy or re-sell any part of the Platform
• Not to access without authourity, interfere with, damage or disrupt:

• Any part of the Platform;
• Any equipment or network on which the Platform is stored;
• Any software used in the provision of the Platform; or
• Any equipment or network or software owned or used by any third party.

Interactive services We may from time to time provide interactive services on the Platform, including, without limitation:

• Chat rooms.
• Bulletin boards.
• Q&A tools.
• Networking features.
• Polling, voting and quiz features.

Any moderation of Interactive Services will be undertaken by our client and you should refer to them for details.

Content standards

These content standards apply to any and all material which you contribute to the Platform (Contribution), and to any interactive services associated with it. The Content Standards must be complied with in spirit as well as to the letter. The standards apply to each part of any Contribution as well as to its whole. If applicable our client will determine, in its discretion, whether a Contribution breaches the Content Standards.

A Contribution must:

• Be accurate (where it states facts).
• Be genuinely held (where it states opinions).
• Comply with the law applicable in England and Wales and in any country from which it is posted.
• A Contribution must not:
• Be defamatory of any person.
• Be obscene, offensive, hateful or inflammatory.
• Bully, insult, intimidate or humiliate.
• Promote sexually explicit material.
• Include child sexual abuse material.
• Promote violence.
• Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
• Infringe any copyright, database right or trademark of any other person.
• Be likely to deceive any person.
• Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
• Promote any illegal content or activity.
• Be in contempt of court.
• Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.
• Be likely to harass, upset, embarrass, alarm or annoy any other person.
• Impersonate any person or misrepresent your identity or affiliation with any person.
• Give the impression that the Contribution emanates from Inconf Ltd, if this is not the case.>
• Advocate, promote, incite any party to commit, or assist any unlawful or criminal act such as (by way of example only) copyright infringement or computer misuse.
• Contain a statement which you know or believe, or have reasonable grounds for believing, that members of the public to whom the statement is, or is to be, published are likely to understand as a direct or indirect encouragement or other inducement to the commission, preparation or instigation of acts of terrorism.
• Contain any advertising or promote any services or web links to other sites.

Breach of this policy

When we consider that a breach of this acceptable use policy has occurred, we and/or our client may take such action as we deem appropriate.

Failure to comply with this acceptable use policy may result in our taking all or any of the following actions:

• Immediate, temporary or permanent withdrawal of your right to use the Platform.
• Immediate, temporary or permanent removal of any Contribution uploaded by you to the Platform.
• Issue of a warning to you.
• Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
• Further legal action against you.
• Disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

We exclude our liability for all actions we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.

How this contract can be transferred

We can transfer our rights and obligations under these terms to any third party, provided this does not adversely affect your rights under these terms.

Which country’s laws apply to any disputes?

If you are a consumer, please note that the terms of this policy, its subject matter and its formation are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are a resident of Scotland, you may also bring proceedings in Scotland. If you are a business, the terms of this policy, its subject matter, and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Terms & Conditions

Privacy Policy

OUR COMMITMENT TO PRIVACY

Your privacy is important to Declaration Partners LP and its affiliates (together, “Declaration,” “our,” “us” or “we”). To better protect your privacy, we are providing information explaining our online information practices.

This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use certain information about you through your use of our websites and investor portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). Visitors that are: (a) residents of California should also refer to our California Website Privacy Policy below, or (b) in the United Kingdom or European Union should refer to our GDPR Privacy Notice below, each of which supplements this Website Privacy Policy.

Please read this Privacy Policy carefully. If you do not provide your information for us to use in accordance with this Privacy Policy, then we may not be able to provide our services or products to you and/or you may no longer be able to use the Website fully or at all. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

THE INFORMATION WE COLLECT AND HOW WE USE IT

We may collect various types of information in connection with use of the Website. For example, knowing how users use our website – tracking their movement through this website via “cookies”– helps us improve website design and usefulness. As a result, Declaration’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (“IP”) addresses. Declaration generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page.

To the extent that you provide us with any personally identifiable information through or in connection with the Website, we may use such information for Declaration’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to Declaration, save where the GDPR Privacy Notice applies (in which case it sets out the basis on which we use such personally identifiable information), you consent to Declaration’s use of such personally identifiable information for the purposes described in this Privacy Policy. We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through the Website; any transmission of information or data by you to or through the Website is at your sole risk.

You may request to access any personally identifiable information we have about you by contacting us at 1.833.968.8686.

CAPACITY

You represent to Declaration that you have the authority to use the Website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit users of the Website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18. If we learn we have collected or received personal information about an individual under the age of 18, we may be required or otherwise take steps to delete that information or obtain the consent of a guardian.

COOKIES

Information regarding how you access the Website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected using cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where we use cookies that are not necessary for the functioning of the website (for example, for use in relation to marketing and advertising), we will ask you to consent to their use. You may opt-in or opt-out of accepting cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

You may access any personally identifiable information we have about you by contacting us at 1.833.463.0211.

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review this Privacy Policy regularly. If we decide to change this Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of this Privacy Policy under which the information was collected.

MISCELLANEOUS

Please also see our Terms of Use, which apply to your use of the website.

CALIFORNIA WEBSITE PRIVACY POLICY

This California Website Privacy Policy supplements the Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA.

Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

WHAT DOES THIS WEBSITE PRIVACY POLICY APPLY TO?

This Privacy Policy applies solely to your interactions with us through the Website. If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice, and that notice will govern that personal information.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We collect limited types of personal information through the Website. The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we collect from individuals on the Website may include the following:

• Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);

• Other customer records, such as telephone number and personal information provided in connection with obtaining access to any registered user features of the Website;

• Any other information that you provide to us via the Website, such as commercial information (including financial data); and

• Internet or other electronic network activity information, such as information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

HOW DO WE OBTAIN YOUR PERSONAL INFORMATION?

In connection with forming and operating the Website, we may collect and maintain your nonpublic personal information from the following sources:

• Information provided directly through your communications with us in connection with the Website; and

• Information captured automatically by us in connection with your use of the Website, information captured via cookies.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We will use your personal information for one or more of the following business purposes:

• To perform services for you.

• To improve the Website and the products and services that we offer.

• To communicate with you, including responding to requests for information submitted by you through the Website.

• To keep a record of your relationship with us.

• To audit and verify the quality and effectiveness of our services and compliance.

• To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.

• To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We do not sell any of the personal information we collect about you to third parties.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “WHAT INFORMATION DO WE COLLECT ABOUT YOU?”

We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

YOUR RIGHTS UNDER THE CCPA AND CPRA

Deletion and Correction Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, retention and use of personal information specific to you. Such information includes:

• the categories of personal information we collected about you;

• the categories of sources from which the personal information is collected;

• our business or commercial purpose for collecting such personal information;

• the categories of third parties with whom we share the personal information;

• the specific pieces of personal information we have collected about you; and
• whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

Right to Opt-Out: You have the right to opt out under the CPRA, which allows consumers to prevent businesses from selling their personal information. If a consumer opts out, the business must not sell the consumer’s personal information. Declaration does not sell data to any third- party.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Please contact Ashleigh Brogan, Chief Compliance Officer at (646) 969-5721.

Email us at the following email address: [email protected]

We will contact you to confirm receipt of your request under the CCPA and CPRA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request to verify your request. You may designate an authorized agent to make a request under the CCPA and CPRA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline.
But in certain cases, additional time might be required. Please contact us at the email address above with any questions about this California Website Privacy Policy.

GDPR PRIVACY NOTICE

OUR COMMITMENT TO PRIVACY

Your privacy is important to Declaration LP and its affiliates (together, “Declaration,” “our” or “us,” “we”). To better protect your privacy, we are providing information explaining our online information practices.

In this GDPR Privacy Notice, “European Data Protection Legislation” means all applicable laws relating to the protection of personal data in force from time to time in the EU or the UK, including (without limitation): Regulation (EU) 2016/679 (the “EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland, the Privacy and Electronic Communications (EC Directive) Regulations 2003, and any other legislation which implements any other current or future legal act of the European Union or the United Kingdom concerning the protection and processing of personal data (including any national implementing or successor legislation), and including any amendment or re-enactment of the foregoing.  The terms “controller”, “processor”, “data subject”, “personal data” and “processing” in this GDPR Privacy Notice shall be interpreted in accordance with the European Data Protection Legislation.

This GDPR Privacy Notice applies if and to the extent that the European Data Protection Legislation applies to our processing of personal data collected by or provided to us through your use of our Website and supplements the Privacy Policy above (in the event of a conflict, this GDPR Privacy Notice shall take precedence). If you provide personal data to use through another means (e.g., as an employee or seeking employment or pursuant to a services agreement) you will receive a separate privacy notice or agreement, and that notice, or agreement will govern our processing of that personal data.

For the purposes of European Data Protection Legislation and this GDPR Privacy Notice, Declaration will be a controller of any personal data collected by us. If this GDPR Privacy Notice applies, such visitors (as data subjects) have certain rights with respect to such personal data, as outlined below.   If you have any questions regarding our use of your personal data, or this GDPR Privacy Notice, please contact us at 1.833.463.0211.

THE PERSONAL DATA DO WE COLLECT ABOUT YOU

We will collect and process the types of personal data described in the Website Privacy Policy and California Website Privacy Policy above. We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.). Nor do we collect any information about criminal convictions and offences.

HOW WE OBTAIN YOUR PERSONAL INFORMATION

We will collect your personal data either through you directly providing such data to us in your electronic communications with us via the Website, or through our

use of various technologies, including cookies, to monitor your use of the Website.

WHY WE USE YOUR PERSONAL INFORMATION

We will process your personal data for the following purposes in reliance on the following legal bases under the European Data Protection Legislation:

Purpose	Legal Basis
To provide you with the services or products you have requested.	Contractual necessity
To keep a record of your relationship with us.	Legitimate interest
To verify your identity.	Legal requirement
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.	Legitimate interest
Fraud and abuse prevention.	Legitimate interest
Litigation management and conducting internal audits and investigations.	Legitimate interest
To administer and protect our business and Website.	Legitimate interest
To make suggestions and recommendations to you about goods or services that may be of interest to you.	Legitimate interest

No automated decision-making, including profiling, is used when processing your personal information.

Failure to provide certain personal data may mean that we cannot provide our services or products to you and/or that you may no longer be able to use the Website fully or at all. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

MARKETING

We may send you direct marketing communications to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in or opt-out of receiving any such direct marketing communications by contacting us at (646) 969-5721.

SHARING AND TRANSFER OF PERSONAL DATA

Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this GDPR Privacy Notice, including professional advisors, CEOs and CEOs-in-Training, recruitment firms, consultants, placement agents and data hosting providers. We seek to ensure that anyone who provides a service to, or for us, involving the processing of your personal data enters into an agreement with us and meets our standards for data security. To the extent that we transfer your personal data to countries outside of the UK or EEA, such transfers will only be made in accordance with the European Data Protection Legislation. For further information about the safeguards/derogations used, please contact us at (646) 969-5721.

We reserve the right to disclose your personal data as required by applicable law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.

SECURITY AND RETENTION OF PERSONAL DATA

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the personal data we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through the Website; any transmission of information or data by you to or through the Website is at your sole risk.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this GDPR Privacy Notice unless a longer retention period is required by applicable law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact us at (646) 969-5721.

YOUR RIGHTS

You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what personal data we store and process about you. To exercise these rights and controls, please contact us at (646) 969-5721. Your rights in respect of the personal data processed by us under this GDPR Privacy Notice are:

• Access: You have the right to ask for a copy of the personal data that we hold about you free of charge; however, we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.

• Correction: You may notify us of changes to your personal data if it is inaccurate or it needs to be updated.

• Deletion: If you think that we should not be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.

• Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against applicable law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.

• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.

• Portability: If you wish to transfer your personal data to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.

• Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

NOTIFICATION OF CHANGES

We reserve the right to amend this GDPR Privacy Notice from time to time by updating this GDPR Privacy Notice. If we decide to change our GDPR Privacy Notice, we will post those changes, so our users are always aware of what personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use personal data collected as described in this GDPR Privacy Notice only in accordance with this GDPR Privacy Notice.

CONTACT US

If you have any questions or concerns about this GDPR Privacy Notice, please contact us at (646) 969-5721.

COMPLAINTS

Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.