Clear Path Analysis Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Notice (“Notice”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us when you use our website at europe.privatemarketsinvestor.com (“Website”) or any of our services, or where we enter into any other business relationship with you. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Clear Path Analysis Limited.

YOUR PERSONAL INFORMATION

Information we collect from you

We collect and process some or all of the following types of information from you in the course of your use of the Website, our provision of our services, or otherwise conducting any business relationship with you:

• Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the Website, subscribing to our services, or requesting further information or services. We may also ask you for information when you complete a survey or report a problem with the website.
• Specifically, personal details such as name, email address, phone number, place of work, position, details of your job industry, your location or any information input by you when using the Website, completing our survey forms or using our services.
• In respect of the personnel engaged by our sponsors or suppliers (or prospective sponsors or suppliers), and with whom we come into contact in connection with the relationship between Us and our sponsor or supplier, we will process your contact details and any other information that you provide to us.
• If you contact Us, We may keep a record of that correspondence.
• We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
• Details of transactions you carry out through our Website and of the fulfilment of your orders.
• Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.

The provision of name, email address, place of work, position, telephone number and enquiry details are required from you to submit and enable Us to respond to your enquiry. Your name and email address, phone number, place of work, position, industry details, location and details regarding how you heard about Us are required from you to subscribe to our services. The provision of your name, email address, place of work, position, telephone number, industry details, location and details regarding how you heard about Us is required from you when downloading material, participating in surveys or registering for events or requesting to be notified when such material and events registration is available. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.

Information We Collect From Other Sources

We may also obtain personal data such as your name, organisation, job title and other information that you make public on social media, such as LinkedIn.

USES MADE OF YOUR INFORMATION

Provision of data to our content sponsor

Clear Path Analysis hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Clear Path Analysis has a “free to view” business model. Our services are paid for by content sponsor (“Sponsors”) in exchange for Clear Path Analysis providing them with access to information about who reads their content. Once personal data is transferred to our Sponsor they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Clear Path Analysis users with information about their products and services.

Details of each Sponsor to which your personal data will be transferred is clearly stated within the summary of the content that you are able to view before you access the applicable Content. Sponsor may be located within or outside the EEA – their location will also be clearly indicated. For full details of how this Sponsor will use your personal data, you should review the Sponsor’s own Privacy Notice.

We have always been completely transparent about the provision of users’ personal data to our Sponsor, and until 25th May 2018 have relied on legitimate interest to collect and process our users’ information in this way.

From 25th May 2018, although we believe that we continue to have a legitimate interest in providing your information to the Sponsor whose content you access, and that the Sponsor continue to have a legitimate interest in receiving this personal data, we have decided to give you more control by asking for your express consent to this processing when you register. Users who register after 25th May 2018 will therefore be required to opt in or out of this use. Users who registered prior to 25th May 2018 will not be asked to expressly consent to the use but may opt out at any time by amending the settings in their profile or by contacting Us at the contact details set out below.

Clear Path Analysis’s own use of your personal data

We use information held about you in accordance with the following “legal bases” and for the following purposes:

• To provide you with our Website and to carry out any other obligations arising from any contracts entered into between you and Us. We rely on “performance of a contract with you” as the legal basis for this processing.
• To notify you about changes to our service. We rely on “performance of a contract with you” as the legal basis for this processing.
• To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website. We rely on “legitimate interest” as the legal basis for this processing, and the legitimate interest is the maintenance and improvement of our Website for the benefit of all our users.
• To respond to your enquiries. Where you have contacted us via our online “Contact” form, e-mail and telephone or participated in any surveys, we rely on “legitimate interest” and the legitimate interest is “responding and contacting you regarding the enquiries you have made in relation to the services we offer and reviewing your responses to our survey”
• To allow you to participate in interactive features of our service, when you choose to do so.
• We may use information held about you to promote our products and services that may be of interest to you. We rely on a number of legal bases for this type of processing, as follows:
• if you are an existing or prospective user of and/or contributor to Clear Path Analysis, we will only do this where we reasonably believe that our services may be of interest to you and we rely on “legitimate interest” to promote our products and services to you.
• if you are registered as a Clear Path Analysis, we rely on “legitimate interest” to promote our products and services to you that are similar to those in which you have previously shown an interest.
• In any case, if you would prefer that we do not use your data to market or promote our products and services to you, please either (i) tick the relevant box on the form through which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) contact Us at the contact details set out below.

DISCLOSURE OF YOUR INFORMATION

We routinely disclose your personal data to third parties as follows:

• To our Sponsor, as described above.
• To our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).
• We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
• We may also disclose your personal data to third parties:
• in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our users will be one of the transferred assets; or
• if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions or the Terms and Conditions that we have in place with our content providers; or
• to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website.

Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

Keeping your personal data up to date

If your personal details change you may update them by accessing the ‘My Subscription’ page, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by accessing the ‘My Subscription’ page, or by contacting Us using the contact details below.

We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How long we keep your personal data

If you contact us using our website contact form, requesting general information about our services, we will hold personal data you choose to provide or that we may collect from you for 3 years from our last point of contact, unless you register as a user, sponsor or supplier.

If you subscribe to our services, we will hold personal data you choose to provide or that we may collect from you for 3 years from our last point of contact.

If you are engaged by one of our sponsors or suppliers we will hold you contact information for we will hold your contact details for the period that sponsor or supplier is registered with us and for 3 years after.

Data such as IP addresses, traffic data, location data, weblogs and other communication data will be retained for 3 years from the date of collection.

Where we store your personal data

All information We hold about you is stored on our secure servers.

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.

Such countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).

We will not otherwise transfer your personal data outside the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information, please contact Us (see ‘Contact’ below)

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Notice is already designed to address
• require Us to correct any mistakes in your information which We hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to Us,
• let Us have enough information to identify you (full name, e-mail address, job title, organisation name), and
• let Us know the information to which your request relates.

HOW TO COMPLAIN

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Notice at any time. Any changes We may make to our Notice in the future will be notified and made available to you using the Website. Your continued use of the services and the Website shall be deemed your acceptance of the varied Privacy Notice.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

For the same reason, We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable Us:

• To estimate our audience size and usage pattern.
• To store information about your preferences, and so allow Us to customise our site according to your individual interests.
• To speed up your searches.
• To recognise you when you return to our site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

Please note that our advertisers or sponsors may also use cookies, over which we have no control.

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to noelhillmann@clearpathanalysis.com.