Equals 5, Inc. and its Affiliates ("Equals 5" or "We") know that you care about how the information we receive from you is used and shared, and we take your privacy seriously. This Privacy Policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

The treatment of your information can be different depending on your relationship with Equals 5:

"Equals 5 User" or "User"

refers to any individual who visits Equals 5 website or uses Equals 5 product. Our Privacy Policy for Equals 5 Users is outlined in Equals 5 User Policy and Common Policy sections of this document.

"Equals 5 Customers' Audience" or "Audience"

refers to any individual whose personal data were provided by Equals 5 customers to Equals 5 for advertising purposes. Our Privacy Policy for Equals 5 Customers' Audience is outlined in Equals 5 Customers' Audience Policy and Common Policy sections of this document.

This Privacy Policy does not apply to the practices of third parties that Equals 5 does not own or control, or to individuals that Equals 5 does not employ or manage. You can request a copy of this Privacy Policy by contacting us at contacts.

Note to EU Customers and Advertising Audience. We are committed to protect and respect your privacy in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016. Our Data Protection Officer can be contacted by email: [email protected]

Note to California Customers and Advertising Audience can be found below in Common Policy section of this document.

Equals 5 User Policy

By using Equals 5 product, you are accepting and agreeing to the practices outlined in this Privacy Policy. Equals 5 acts as the data controller for Equals 5 Users.

When do we collect personal data about you?

• When you are using Equals 5 product
  
  
• When you visit websites hosted at domain equals5.com and its subdomains
  
  
• When you interact with us in person, through correspondence, by phone, or by social media.
  
  
• When we collect personal information from other legitimate sources, such as third-party data aggregators, Equals 5 marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
  
  
• We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and Equals 5.
  
  

Why do we collect and use personal data?

We collect and use personal data mainly to perform direct sales, direct marketing and customer service. We also collect data about suppliers, partners and persons seeking a job or working in our company.

We may use your information for the following purposes:

• Send you marketing communications which you have requested. These may include information about our products and services, events, activities, and promotions of our associated partners' products and services. This communication is subscription based and requires your consent.
  
  
• Send you information about the products and services that you have purchased from us.
  
  
• Perform direct sales activities in cases where legitimate and mutual interest is established.
  
  
• Provide you content and venue details on a webinar or event you signed up for.
  
  
• Reply to a 'Contact me' or other web forms you have completed on one of our Equals 5 websites (e.g. to download a whitepaper).
  
  
• Follow up on incoming requests (customer support, emails, chats, or phone calls).
  
  
• Provide access to our customer support service.
  
  
• Perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar. The contract may be with Equals 5 directly or with a Equals 5 partner.
  
  
• Notify you about any disruptions to our services (system messages).
  
  
• Contact you to conduct surveys about your opinion on our products and services.
  
  
• Process a job application.
  
  

Our legal basis for collecting personal data

Collecting personal data based on consents

The collection of personal data based on consent from the data subject will be done by using "Consent Forms" that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.

Collecting personal data based on contracts

We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.

Collecting personal data based on legitimate interest

We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between Equals 5 and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.

What type of personal data is collected?

We collect name, phone number, title and email address, in addition to your company's name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address, cookie information, device information and actions taken on the site.

If you apply for a job at Equals 5, we collect the data you provide during the application process. Equals 5 does not collect or process any special categories of personal data, such as public unique identifiers or sensitive personal data.

How long do we keep your personal data?

We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.

This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.

The use of cookies and beacons

We use cookies and web beacons ('Website Navigational Information') to collect information as you navigate the company's websites. Website Navigational Information includes standard information from your web browser, such as browser type and browser language; your Internet Protocol ("IP") address; and the actions you take on the company's websites, such as the web pages viewed and the links clicked.

This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies and web beacons do not personally identify you.

Further information about cookies used on Equals 5 website and how to manage them can be found in our Cookies Policy.

Consent to transfer of personal data to third countries

In order to deliver Equals 5 product or services to you, we may send and store your personal data outside of the country where you reside or are located, including to the United States or other countries that may not or do not provide the same level of protection for your personal information as your country does. We are committed to protecting the privacy and confidentiality of personal information when it is transferred.

If you reside or are located within the European Economic Area (EEA) and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under the applicable law. By using and accessing Equals 5 product and services, users who reside or are located within the EEA agree and consent to the transfer and processing of their personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location. However, each time such transfer is necessary, we rely on your awareness of and consent to the transfer and to the Standard Contractual Clauses adopted by the European Commission and available at SCC.

Equals 5 Customers' Audience Policy

Equals 5 acts as the data processor for Equals 5 Customers' Audience. We receive personal data from our customers, who determine the purposes and means of the processing of personal data and act as data controllers in this case. It is our customers' responsibility to obtain necessary consents or observe other lawful grounds to use Equals 5 product with your personal data.

Why do we need personal data?

We use personal data to show you advertising of our customers via third-party advertising platforms (Ad Platforms). Equals 5 product analyzes information provided by Ad Platforms to estimate the probability of the fact that you saw advertising or clicked on it. We than share results of our estimates with the customer who advertised to you and who provided your personal data.

What type of personal data is received from customers?

We collect name, phone number, title and email address, in addition to your company's name and contact information. From our customers' websites we may collect IP-address, cookie information, device information and actions taken on the site.

How long do we keep your personal data?

We store personal data for as long as it is required by our customers. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.

The use of cookies and beacons

We use cookies and web beacons ('Website Navigational Information') to collect information as you navigate our customers' websites. Website Navigational Information includes standard information from your web browser, such as browser type and browser language; your Internet Protocol ("IP") address; and the actions you take on the customers' websites, such as the web pages viewed and the links clicked. We use this information to analyze the results of advertising campaigns of our customers.

Common Policy

Your rights to your personal data

You have the following rights with respect to your personal data:

• The right to request a copy of your personal data that Equals 5 holds about you.
  
  
• The right to request that Equals 5 corrects your personal data if inaccurate or out of date.
  
  
• If you are a customer and using Equals 5 product, you may update your user profile in Equals 5 by logging into Equals 5 and choose the account settings option to edit your details.
  
  
• The right to request that your personal data is deleted when it is no longer necessary for Equals 5 to retain such data.
  
  
• The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications. If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication. Please note that you may still receive system messages and administrative communications from Equals 5, such as order confirmations, system messages and notifications about your account activities.
  
  
• The right to request that Equals 5 provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
  
  
• The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
  
  
• The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
  
  

Any query about your privacy rights should be sent to [email protected]

Do we share your data with anyone?

We do not share, sell, rent, or trade your information with any third parties without your consent, except from what is described below:

If required by law:

We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company's rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.

Use of sub-contractors (processors and sub-processors):

We may use sub-contractors to process personal data on our behalf, we are responsible for making sure they commit themselves to adhere to this Privacy Policy and applicable data protection legislation.

If the sub-contractor processes Personal Data outside the EU/EEA area, such processing must be in accordance with the EU Privacy Shield Framework, EU Standard Contractual Clauses for transfer to third countries countries available at SCC, or another specifically stated lawful basis for the transfer of personal data to a third country.

Third-party websites

Equals 5 website and product may contain links to websites operated and maintained by third parties over which we have no control. Privacy policies of such linked websites may be different from our Privacy Policy. You access such linked websites at your own risk and we assume no liability for your interaction with third-party websites.

Children and COPPA

Equals 5 is a general audience service and does not knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children's Online Privacy Protection Act ("COPPA") without such parental consent. In fact, if you are under 18 years of age, you are not permitted to use Equals 5 website and product and should not send any information about yourself to us.

In the event that we become aware that we have collected personal information from any child, we will dispose that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us by email at [email protected].

Note to California residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our Users and Audience who are California residents to request and obtain from us once a year, free of charge, information about their personal data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal data that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to the details provided at the end of this section.

Please be aware that not all information sharing is covered by the "Shine the Light" requirements, and only information on covered sharing will be included in our response.

This section also provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act ("CCPA").

For more details about the personal information we have collected, including the categories of sources, please see the "What type of personal data is collected?" section above. We collect this information for the purposes described in the "Why do we collect and use personal data?" section above. Please see whether we share collected information with the third parties in the "Do we share your data with anyone?" section above. We do not sell (as such term is defined in the CCPA) the personal information we collect.

Subject to certain limitations, CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any "sales" that may be occurring, and to not be discriminated against for exercising these rights.

California consumers can make a request pursuant to their rights under CCPA by contacting us at the details provided below. We will verify your request using the information associated with your account, including the email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Equals 5 Inc.

5 Penn Plaza, 23 Floor

New York, NY 10001 USA

E-mail: [email protected]

Contact form: https://www.equals5.com/contacts

Changes to this Privacy Policy

Equals 5 reserves the right to amend this Privacy Policy at any time. The applicable version will always be found on our websites. We encourage you to check this Privacy Policy occasionally to ensure that you are happy with any changes.

If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.

Miscellaneous provisions

Given the fact that our technology evolves, Equals 5 cannot predict the future features of its product and services. Therefore, your consent to this Privacy Policy will also apply to the processing of your personal data and other information by new technologies and techniques, which fall within our original purposes disclosed in this Privacy Policy.

The completion of your registration at Equals 5 website and usage of its product contains an explicit acceptance of the processing of your personal data and other information as outlined in this Privacy Policy.

Your consent to this Privacy Policy means the same consent is given to all entities within Equals 5 group including parent companies, subsidiaries, joint ventures, or other companies under common control, in which case we will require such entities to honor this Privacy Policy.

Your right to complain with a supervisory authority

If you are unhappy with the way in which your personal data has been processed, you may, in the first instance, contact [email protected]. If you remain dissatisfied, then you have the right to apply directly to your national supervisory authority for a decision.