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Privacy Policy Statement of IMIT Advisory Limited (the Company)

Introduction

We pride ourselves on our reputation for providing objective and unparalleled insight and advice to the marketplace.

When our clients, prospects, registered users and vendors entrust us with their personally identifiable information (“Personal Information”), they expect that we will protect that information with the same level of care we do our own. Doing so is fundamental to our business success.

We developed this Privacy Policy Statement (the “Policy”) to define and document for our clients, prospects, registered users and vendors the various ways that we safeguard and balance their privacy rights with our legitimate business needs to collect, maintain, and communicate information.

Scope

This Policy applies to IMIT and any entities doing business under the IMIT Advisory name worldwide, which collect, process and/or store Client Personal Information.

IMIT aims to comply with the applicable laws and regulations protecting the privacy of Personal Information in the jurisdictions in which IMIT operates. Where appropriate, laws within specific jurisdictions may require supplemental terms to comply with local laws.

General Definitions

(These definitions may vary slightly according to local data privacy laws.)

“Agent” means a Third Party that processes Personal Information solely on behalf of and under the instructions of the Company.

“Associate(s)” refers to any employee of the Company or its direct or indirect subsidiaries worldwide.

“EEA” refers to the European Economic Area, which covers the countries of the European Union (“EU”) as well as additional non EU-countries (currently Iceland, Liechtenstein and Norway).

“IMIT”, “IMIT Advisory” or the “Company” means IMIT Advisory Limited and its direct and indirect subsidiaries.

“Company User” is any identified or identifiable natural person with whom IMIT conducts its business, including without limitation: clients, prospects, event attendees, registered users, vendors and other individuals.

“Personal Information” is any information relating to an identified or identifiable natural person recorded in any medium (e.g., PDA, computer, paper). It includes information such as name, address, job title, IMIT topics of interest and requested manner of communication (e.g., mail, fax, email, phone, etc.). It also includes certain highly sensitive information about an individual, such as race, religion, gender, sexual orientation, medical/health records, credit card information, dietary requirements, and political beliefs. Additional legal safeguards apply in the case of Sensitive Personal Information (see definition below).

Examples of Personal Information relevant to IMIT business may include:

  • Client or Prospect Information: Name, email address, business address, employer/ company-related information, website registration, subject matter preference information. This information may be found on marketing/mailing/contact lists (e.g., in contacts function of MS Outlook or on a PDA), in corporate data bases, on spreadsheets.
  • Event Attendee and/or Sponsor Information: Name, email address, business address, employer/ company-related information, credit card information (in rare instances). This information may be found on registration forms/profiles, attendee lists, business cards, photos, video clips, online streaming.
  • Sales Order Fulfillment Information: Name, email address, business address, employer/ company-related information. This information may be found on Sales Order Forms, Inquiry records (e.g., webGAMEC).
  • Third Party Service Provider Information: Name, email address, business address, employer/company-related information. This information may be found in corporate databases.

“Processing” means any operation that is performed on Personal Information, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

“Sensitive Personal Information” is a subset of Personal Information, which due to its sensitive nature has been classified by law or policy as deserving heightened privacy protections. Sensitive Personal Information includes, without limitation: race, ethnicity, medical records. As a rule, IMIT refuses to accept Sensitive Personal Information from third parties, including our clients, since it is rarely necessary for our business.

“Third Party” or “Third Party Service Provider” is any natural or legal person, public authority, agency or other body apart from the Company User that processes Personal Information solely on behalf of and under the instructions of IMIT. All such Third Parties agree to collect, safeguard and use the Personal Information in accordance with the terms of the IMIT Privacy Policy and applicable data privacy laws.

The IMIT Privacy Principles

IMIT is committed to respecting your privacy rights and protecting the Personal Information you share with us. We protect your Personal Information in accordance with the following Privacy Principles:

1. Notice: We notify you when we collect your Personal Information that it will be used to administer our relationship with you and to deliver our superior service- including informing you about IMIT offerings that may be relevant to you.

2. Choice: We do not share Personal Information about you outside IMIT unless you give us permission to do so, or when the law requires it. We give you choices related to how we use and share your Personal Information, and we make it easy for you to remove your name from marketing and distribution lists via email or by contacting: [email protected]

3. Onward Transfer: We insist that the vendors we hire to provide support services to IMIT adhere to our Privacy Policy and Principles as well as applicable data privacy laws.

4. Security & Enforcement: We safeguard and protect your Personal Information. We educate our employees and service providers on our Privacy Policy and Principles- as well as their roles and responsibilities in complying with them; and we enforce remedial penalties for non-compliance.

5. Global Compliance: We endeavor to comply with the applicable data privacy laws in all regions where we conduct business.

6. Access: We aim to keep your Personal Information accurate and current; and we update or disclose it to you whenever you request us to do so. We post our Privacy Policy and Principles on our Web sites and we notify you on those Websites about any significant amendments thereto.

Below, we take a closer look at each of the IMIT Privacy Principles enumerated above.

1. Notice:

We notify you when we collect your Personal Information that it will be used to administer our relationship with you and to deliver superior service; including informing you about IMIT offerings that may be relevant to you.

a. IMIT processes your Personal Information in a reasonable and lawful manner for relevant and appropriate business purposes and retains such Personal Information for no longer than is necessary for the purpose(s) for which it was collected.

b. In keeping with the nature of IMIT’s business, IMIT services and benefits are not marketed to minors. IMIT does not knowingly attempt to solicit or receive any Personal Information from children.

c. IMIT collects Personal Information at several different points, including but not limited to the following (in alphabetical order):

  • Cookies. IMIT may employ a cookie, or small piece of information stored on a file in the Company User’s browser or hard drive, which enables Web servers to “identify” that Company User each time he/she initiates a session on an IMIT Web site. Unless the Company User has adjusted his/her browser settings to refuse cookies, the IMIT system will issue a cookie when the Company User visits an IMIT Web site.Here is what Company Users need to know about cookies:
    • First Party cookies are set by the IMIT Web site you are visiting.
    • Third Party cookies are set by a domain outside of the IMIT Web sites.
    • Persistent cookies remain on your computing device for the period specified in the cookie and are activated each time you revisit the website that set such cookie.
    • Session cookies remain on your computing device until you close your browser window, at which point they are automatically deleted.

    While Company Users may block cookies at any time by changing their browser settings, it is important to note that First Party cookies may be necessary in order to identify Company Users and ensure they fully access and use the content and features on the IMIT Web sites.

    IMIT uses cookie technology to enable registered Company Users (i) to move quickly and securely through access-controlled areas of the IMIT Web sites; and (ii) to take advantage of certain useful features on the sites, such as “remember my password.”

    First and Third party cookies do not store any Company User Personal Information on the IMIT Web sites; they are simply identifiers. By continuing to use the IMIT Web sites, Company Users consent to the placement of these cookies on their computing device in accordance with the terms above.

  • Email alerts. Company Users are asked to provide their email address when signing up for email alerts on IMIT Web sites. Additional information may also be collected depending on the type of alert requested. Alerts may be managed or deleted by Company Users on the “Alerts” link available at the top of the www.imitadvisory.com homepage.
  • Event Registration. Where IMIT collects Personal Information for Event Registration, IMIT will not disclose such information to any Third Party (other than in connection with administration of the IMIT Event) without the registrant’s consent. IMIT does not rent, sell or otherwise disclose this collected Personal Information for non-Event-related mailings.
  • IMIT Web Sites. The IMIT Web sites are owned and operated by IMIT to deploy the IMIT products and services. Each IMIT Web site requires the Company User to create an account and choose a password. Passwords are for the Company User’s individual use and may not be shared with others. For additional guidance about how to use the IMIT services, please consult the Usage Guidelines for IMIT Services on the policy page of imitadvisory.com. IMIT does not sell, rent or share (outside the IMIT family) Personal Information collected on the IMIT Web sites. IMIT obtains the Company User’s consent prior to disclosing Personal Information to Third Parties for consumer marketing purposes. IMIT Web sites may contain links to other Web sites. IMIT is not responsible for the privacy practices of such other sites. Company Users should be aware when leaving an IMIT Web site and should read the privacy statements of the new Web site they enter.
  • Mobile Computing Devices. Some IMIT Web sites and online resources are specifically designed to be compatible with and used on mobile computing devices. Mobile versions of IMIT Web sites may require Company Users to log in with an account for that Web site. Information about use of each mobile version of the Web site will be associated with the Company User accounts. Some of the IMIT Web sites and online resources enable Company Users to download an application, widget or other tool that can be used on mobile or other computing devices. These tools may store information on mobile or other devices and enable Company Users to email reports and other information from the tool. These tools may also transmit Personal Information to IMIT to enable (i) Company Users to access user accounts and (ii) IMIT to enhance and track use of these tools as well as develop new tools for quality improvement.
  • Purchases & Fulfillment. When Company Users place an order or register for an IMIT Event, additional Personal Information, such as credit card number and expiration date, may in some instances be requested. IMIT may also collect additional information about hotel, meal and other travel preferences. This Sensitive Personal Information, which is used solely for confirmation and billing purposes and to service the order, is used only for the purpose identified hereunder and is deleted in a secure and timely manner once that purpose has been served.
  • Recruiting. Candidates for employment must provide Personal Information as required by the recruiting and interview process, such as full name and mailing address, personal email address, job resume, photo, references and other employment-related information. This information is retained by IMIT only until such time as the successful candidate is appointed, or the unsuccessful candidate requests that IMIT continue to retain his/her Personal Information for future opportunities.
  • Registration for IMIT Web sites. When Company Users register on IMIT Web sites, or for IMIT events, or to purchase products, IMIT may request certain Personal Information. IMIT uses this Personal Information to provide advice and service, as well as to share offers deemed relevant by IMIT. In circumstances where data processing is not permitted under local law, IMIT requests express consent from the Company User. IMIT may also contact Company Users regarding Web site problems or other customer service-related issues.
  • RFID. Radio Frequency Identification is a generic term that is used to describe a scanning system that transmits the identity (in the form of a unique serial number) of an object or person wirelessly, using radio waves. IMIT may use RFID scanning technology at IMIT Events (via the Attendee Badge) to collect information pertaining to Attendee participation in Event sessions and activities and/or visits to Exhibitor booths. This collected information is used internally to help IMIT better understand client business needs. IMIT also makes RFID scanning tools available to its Exhibitors but requires them to inform Event attendees (i) of the purpose of their scanning, and (ii) that their Exhibitor RFID scanning is in no way affiliated with IMIT.
  • Social Media. Online social media resources are interactive tools that enable Company Users to collaborate and share information with others. Social media resources include but are not limited to social networks, discussion boards, bulletin boards, Blogs, Wikis and referral functions to share Web site content and tools with a friend or colleague. Where a Company User makes specific reference to IMIT on a social media resource, IMIT may collect the Company User’s Personal Information. When using social media resources, Company Users are advised to take care with what Personal Information they share with others. IMIT provides additional notice and choices on its Web sites about how Personal Information is collected, used and disclosed with regard to social media resources.
  • Usage Tracking. IMIT may monitor how Company Users use its Web sites, including search terms entered, pages visited and documents viewed. For registered Company Users, this information is stored with their registration information. It is uniquely numbered, and is used solely for purposes of enabling IMIT to provide the registered Company User with a personalized Web site experience. This data may also be used, in an aggregated (i.e., not personally identifiable) format to (i) help IMIT understand areas for future research; and (ii) identify appropriate product offerings and subscription plans. This same data may also be used by IMIT clients, in a form that is personally identifiable to the specific client, to better understand how their employees are using their IMIT subscriptions.

2. Choice:

We do not share personal information about you outside IMIT unless you give us permission to do so or when the law requires it. We give you choices related to how we use and share your Personal Information, and we make it easy for you to remove your name from marketing and distribution lists via email or by contacting: [email protected]

a. IMIT gives each Company User the opportunity to opt-out (i) from allowing IMIT to disclose his/her Personal Information to a Third Party unless the disclosure is required by law or is for the fulfillment of a contractual obligation (e.g., employment contract) and (ii) from allowing IMIT to process Personal Information for a purpose other the original purpose for which it was collected or the purpose authorized subsequently by the Company User.

b. An “Unsubscribe” button, and other identifying information as required by applicable law, is provided on each email communication sent by IMIT (other than those required by law or to administer a current contract) so that the Company User may opt-out or otherwise direct the proposed use of their Personal Information.

3. Onward Transfer:

We insist that the vendors we hire to provide support services to IMIT adhere to our Privacy Policy, the most current version of which is posted on our Web sites for easy access.

a. IMIT takes very seriously its obligation to protect and safeguard the Personal Information of Company Users and seeks the cooperation of its business partners in furthering this goal.

b. IMIT uses Third-Party service providers (such as mailing & shipping houses and event coordinators, together with other service providers as necessary) to fulfill its contractual obligations to its clients.

c. Where IMIT is required to share Personal Information with Third Parties, such as vendors, IMIT will contractually ensure that such vendor safeguards the Personal Information they are processing to the same degree as IMIT safeguards the Personal Information in its care.

d. When Company Users register for an IMIT event, IMIT provides to hotels and facilities hosting the event, and to vendors providing event-related services, only that Company User Information necessary to administer the Attendee event experience.

e. Where IMIT has knowledge that a Third Party service provider – or its Agent – is using or sharing Personal Information in a way that is contrary to this Policy, IMIT will take reasonable and timely steps to prevent or stop such processing.

f. Where local law or government authority requires, IMIT will comply with requests to disclose Personal Information of a Company User, issuing timely notice where possible and permissible. Many entities receiving Personal Information under these conditions are required to adhere to privacy requirements that govern their handling of the collected Personal Information.

4. Security & Enforcement:

We safeguard and protect your Personal Information. We educate our employees and service providers on our Privacy Policy and Principles as well as their roles and responsibilities in complying with them; and we enforce remedial penalties for non-compliance.

a. IMIT maintains and implements a data security program that includes industry standard administrative, technical, physical, and operational safeguards designed to:

  • maintain the security and confidentiality of Personal Information;
  • safeguard against any anticipated threats or hazards to the security, confidentiality and integrity of Personal Information; and
  • protect against unauthorized access, disclosure, alteration or destruction of Personal Information that could result in harm to IMIT or Company Users.

b. The nature and extent of protection will correspond to applicable local laws and regulations.

c. In addition, IMIT provides users of its Web sites with a secure online experience by deploying a variety of security measures to maintain the safety and confidentiality of the Personal Information it collects. For further guidance about data security at IMIT, email: [email protected]

d. All IMIT Associates, Third Party service providers, and other individuals whose responsibilities include the processing (e.g., collection or storage) of Personal Information are trained to safeguard and protect that Personal Information in accordance with this Policy.

e. IMIT has implemented protocols to verify ongoing compliance with this Policy and to enforce penalties against those who violate it. Company Users wishing to report a privacy violation, may do so through their designated IMIT Account Representative or by contacting: [email protected]

5. Global Compliance:

We endeavor to comply with the data privacy laws in all regions where we conduct business.

a. Globally: IMIT aims to comply with the applicable laws and regulations protecting the privacy of Personal Information in the jurisdictions in which IMIT operates. Where appropriate, specific jurisdictions may require supplemental terms to this Policy in order to comply with local laws.

b. In Hong Kong: This Privacy Policy Statement sets out the policies and practices of the Company’s commitment to protecting personal data privacy in accordance with the provisions of the Personal Data (Privacy) Ordinance.

6. Access:

We endeavor to keep your Personal Information accurate and current; and we update or disclose it to you whenever you request us to do so. We post our Privacy Policy Statement on our Web sites and we notify you on those Web sites about any significant amendments.

a. IMIT takes reasonable steps to ensure the Personal Information it has collected is accurate, complete, and current.

b. If a Company User desires to access and review the Personal Information IMIT has collected about him/her or if such Personal Information is incorrect, incomplete or has changed, IMIT provides the Company User with reasonable opportunity (via their user profiles on the IMIT Web sites) to view/correct/update it at any time.

c. IMIT may amend this Policy from time to time, should it become necessary or advisable to do so. We will notify you about significant changes to our Privacy Policy by placing a prominent notice on our Web site(s) and where we deem it reasonably necessary, via notice to the primary email address specified in your user profile.

You have the right to access and update your information and contact us. If you have any question about our Privacy Policy Statement, please write to us at:

Data Protection Officer, Shared Services
IMIT Advisory Limited
Unit 1104, Crawford House
70 Queen’s Road Central
Central, Hong Kong

We thank you for entrusting us with your Personal Information and with your business!

For any and all questions regarding our Privacy Policy and Principles, contact [email protected]

Last Updated: July 2015