CDS GLOBAL PRIVACY NOTICE

CDS GLOBAL PRIVACY NOTICE
Last updated:  November 16, 2023

This Privacy Notice (the “Notice”) describes how CDS Global, Inc. and its affiliates (collectively, “CDS Global”, “we”, “our” or “us”) handle personal information in connection with the operation of the CDS Global website (www.cds-global.com and the country-specific webpages, including www.cdsglobal.co.uk) linking to this Notice (collectively, the “Site”). 

This Notice applies only to information that CDS Global obtains in connection with the operation of the Site and describes how we can use the information we obtain and with whom we may share it.  This Notice does not describe the privacy practices of the publishers and other clients for whom CDS Global may act as a service provider (collectively, “CDS Global Clients”).  We encourage you to review their privacy policies and other similar statements. With respect to privacy rights you may have with regards to personal information CDS Global Clients may collect and provide to CDS Global for processing, please contact the applicable CDS Global Client directly to submit your request.

The Site is made available for informational and research purposes and is intended for users acting in a professional capacity.   

PERSONAL INFORMATION WE OBTAIN (Categories of Personal Information We Collect)
CDS Global obtains different types of information, including personal information, when you use the Site.  This information may be provided by you directly, such as when you complete a form on the Site, it may be automatically collected from your browser or mobile device using technologies such as cookies, or it may be obtained from other sources. CDS Global also obtains personal information about CDS Global Client representatives as part of the contracting or account registration processes.

Information we collect directly from you:
We may ask you to provide your information when you use the Site, such as when you sign up to our email list.  You may not be able to use certain features if you choose not to submit the requested information.  

The information you give us may include details such as:

• Contact information (e.g., name, email address, company name and address).
• Demographic and interests information (e.g., region and industry sector).
• Other information you choose to share with us (e.g., when you complete a “Contact Us” form on the Site).
• Log in information (e.g., credentials for signing in to your CDS Global account).
• Transactional and activity information (e.g., when you download a White Paper).

Information automatically collected:  
We and our service providers automatically obtain certain information when you access the Site from your web browser or mobile device, such as information about the number and frequency of visitors, technical information about browsers and devices used to access the Site, and information about crashes or other technical issues.  In addition, we and third parties may automatically collect certain information through automated means about your activities over time across the browsers and devices you use to access the Site as well as across third-party sites, apps or other media.  These technologies may assign or collect a unique identifier on your browser or device, and may reside, among other places, on your computer or device, within webpages or mobile apps.  We may use these technologies to administer the Site, understand usage of the Site and improve the content and offerings of the Site. 

Cookies and similar technologies on the Site may be served directly by CDS Global (referred to as ‘first-party cookies’) or by others such as data analytics companies (referred to as ‘third-party cookies’). Cookies and similar technologies are browser- and device-specific and may endure for different periods of time. Some are deleted automatically once you close your browser or exit the Site. These are sometimes referred to as ‘session cookies’. Other cookies are ‘persistent cookies’, meaning that they remain on your device after your browser is closed.

You have the right to choose whether or not to accept certain cookies and similar technologies. However, if you choose to refuse or remove cookies and similar technologies, this could affect the availability and functionality of the Site.

The Site uses analytics to measure usage and help improve both the user experience and functionality, including third-party analytics provided by Google Analytics. To opt-out of Google Analytics on your device or browser, please visit https://tools.google.com/dlpage/gaoptout and follow the instructions.

Information we obtain from other sources: 
We may use information we obtain through the Site with other information we may have about you, including information obtained offline.  If you are a representative of a CDS Global Client or potential CDS Global Client, we may obtain information about you from your organization, for example, through the contract negotiation process.  We may obtain your information if you attend an industry conference or event.  We may also obtain information from third-party data providers.

HOW WE USE INFORMATION WE OBTAIN (Business or Commercial Purpose for Collecting Personal Information)
CDS Global uses the information we obtain in connection with the operation of the Site for a number of purposes, including, but not limited to:

• Providing you with the Site, and information you may request, responding to inquiries, and for customer support.
• Sending you communications, including to market and advertise CDS Global products, services, and events.
• Improving the Site and the services we provide and customizing the user experience.
• Generating and analyzing statistics about your use of the Site.
• Detecting, preventing, and responding to violations of this Notice or the Terms of Use, violations of law, or other misuse of the Site. 
• Performing audits, assessments, and testing or troubleshooting activities.
• Complying with and enforcing applicable contractual obligations or industry and legal requirements (including legal process such as court orders, warrants, or subpoenas).

HOW WE PROVIDE PERSONAL INFORMATION TO OTHERS (Business or Commercial Purpose for Providing Personal Information to Third Parties and Other Entities)
CDS Global shares the information we obtain from you through the Site:

• With our affiliates and subsidiaries.
• With third-party vendors that provide services or handle transactions on our behalf.
• As we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Site or other individuals and entities, or to comply with or enforce applicable law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities.

We also reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation; and we may share your information with third parties when you consent to or request such sharing.

HOW WE PROTECT YOUR INFORMATION
We maintain reasonable administrative, technical and physical safeguards to protect the personal information we obtain through the Site.  However, no method of transmission over the internet, or method of electronic storage, is 100% secure.  Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

Third-Party Links and Features
The Site may contain links to third-party websites, mobile apps or features, including through social media features and widgets on our website.  CDS Global is not responsible for the collection or use of your information by such third parties.  We encourage you to review the privacy policies or other similar statements applicable to third-party websites, mobile apps or features.

YOUR PRIVACY RIGHTS

Residents of states with applicable privacy laws are afforded certain rights with respect to their personal information. Depending on where you live, and subject to certain exceptions, you may be entitled to the rights described below. Please note that we are not responsible for and have no control over the privacy and data security practices of CDS Global Clients. With respect to privacy rights you may have with regards to personal information CDS Global Clients may collect and provide to CDS Global for processing, please contact the applicable CDS Global Client directly to submit your request.

If you are a Site visitor, prospective CDS Global Client, representative of a CDS Global Client, or third-party partner who may have interacted with the Site and you would like to submit a request to exercise rights with respect to the personal information we collected about you through our Site, please contact us with your request by email at info@cds-global.com. For such requests, please put the statement “Privacy Rights Request” in the body of your email, as well as your full name, the email address you use to interact with us, and the business you are affiliated with, and specify the privacy right you wish to exercise at this time. If you submit a request to exercise any of the below rights (each a “Privacy Rights Request”), we may request additional information to enable us to process your request.

Under applicable privacy laws, certain types of sharing of personal information may constitute a "sale" of your personal information. As described above, in order to maintain the Site, communicate with you, and provide you with information you may request, we may provide your personal information to others for certain purposes. Please note that this interaction does not constitute “selling” or “sharing” your personal information as such terms are defined under applicable privacy laws. In addition, certain pieces of personal information that we may have about you may be considered “sensitive” under applicable laws (e.g., account login credentials, payment information). Please note that we only process such information in order to provide you with the Site or other contracted services.

Do Not Track
CDS Global does not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

NOTICE AT COLLECTION /ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

Under California law, specific disclosures are required, and California residents have additional rights regarding their personal information. Depending on the nature of your relationship with us, you may have certain rights. Please review this section to learn more.

Subject to certain exceptions, you may be entitled to the rights described below. Please note that we are not responsible for and have no control over the privacy and data security practices of CDS Global Clients, which may differ from those explained in this Notice.

If you are a Site visitor, prospective CDS Global Client, representative of a CDS Global Client, or third party partner who may have interacted with the Site and you would like to submit a request to exercise your CCPA rights with respect to the personal information we collected about you through our Site, please contact us with your request by email at info@cds-global.com. For such requests, please put the statement “California CCPA Rights” in the body of your email, as well as your full name, the email address you use to interact with us, and the business you are affiliated with, and specify the CCPA right you wish to exercise at this time.

Under CCPA, certain types of sharing of personal information may constitute a “sale” of your personal information. As described above, in order to maintain the Site, communicate with you, and provide you with information you may request, we may provide your personal information to others for certain purposes. Please note that this interaction does not constitute “selling” or “sharing” your personal information as such terms are defined under applicable privacy laws. In addition, certain pieces of personal information that we may have about you may be considered “sensitive” under applicable laws (e.g., account login credentials, payment information). Please note that we only process such information in order to provide you with the Site.

INTERNATIONAL DATA TRANSFERS

Information collected through the Site will be processed in and subject to the laws of the United States, which may not provide the same level of protection for your personal information as your home country.

When CDS Global transfers your personal information outside the European Economic Area (EEA), United Kingdom or Switzerland to a non-EEA country, we rely on one or more of the following legal mechanisms: in the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”), Standard Contractual Clauses, or your consent.

For more information about the safeguards we use, please read our Data Privacy Framework Statement, or contact us via the details listed at the end of this Notice.

CHILDREN’S INFORMATION
The Site is not directed to, nor does CDS Global knowingly collect personal information from, children under the age of 18.  If you become aware that your child or any child under your care has provided us with information without your consent, please contact us as indicated below.

CHANGES TO THIS PRIVACY NOTICE
We may update this Notice from time to time to reflect changes in our privacy practices or applicable laws.  We may, as permitted by law, make such changes without prior notice.  We will publish the updated version on the Site and indicate at the top of the Notice when it was most recently updated.  Your use of the Site will be governed by the current version of this Notice.

ADDITIONAL INFORMATION FOR EUROPEAN AND UK VISITORS
Consumers in the EEA, UK and Switzerland whose data is processed by CDS Global as a data processor on behalf of a CDS Global Client should contact the relevant CDS Global Client with any requests or complaints.  Each CDS Global Client is the responsible data controller for the personal information of their respective consumers. 

The Site is made available for informational and research purposes and is intended for users acting in a professional capacity.  This section applies to such users only. 

Who is Responsible for Your Information?
When you interact with the country-specific webpage www.cdsglobal.co.uk, the data controller will be CDS Global Limited. The contact details for this entity are as follows: 

CDS Global Limited
Tower House, Sovereign Park
Market Harborough
Leicestershire LE16 9EF
United Kingdom 

When you interact with the US portion of the Site, the data controller will be CDS Global, Inc.  You can contact CDS Global, Inc. at info@cds-global.com.

Legal Bases for Using Your Information
We process personal information obtained in connection with the operation of the Site for different purposes (as described in the “How We Use Information We Obtain” section, above) on the following legal bases: 

• To pursue our legitimate interests. We process your information to meet our legitimate interests when we use your information to provide you with the Site, to communicate with you and for our advertising and marketing purposes.  For example, our legitimate interests include making improvements to, customizing and understanding how you interact with the Site and sending you communications about products and services we think may be of interest to you.  To accomplish our legitimate interests, we may share your information with our affiliates and subsidiaries and service providers (including for our advertising and marketing purposes) and in the context of a corporate transaction.  We maintain safeguards to protect the information we process to pursue our legitimate interests.

• To comply with our legal obligations. We process and share your information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights.

• With your consent. We obtain your consent to process your information when we are required to do so by law.  If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time by contacting us using the information provided in the “Contact Us” section above.

Your Rights Over Your Information
In certain circumstances, you have a right to access or object to the use of personal information we hold about you in relation to your use of the Site (including in relation to direct marketing).  You can also ask us to rectify, update, erase, restrict or to share such information in a usable format with another company.  Such requests are subject to applicable law. 

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

If you would like to discuss or exercise such rights, please contact us at gdpr@cdsglobal.co.uk.  We will contact you if we need additional information from you in order to honor your requests.

Storing Your Information
We will keep your personal information obtained through the Site for as long as we have a relationship with you. Once our relationship with you has come to an end, we retain your personal information for a period of time that enables us to:

• Maintain business records for analysis, understanding market trends and/or audit purposes and to improve the Site.
• Comply with record retention requirements under applicable laws or other relevant legal or regulatory requirements.
• Defend, establish, exercise or bring any existing or potential legal claims.
• Carry out fraud detection and prevention.
• Deal with any complaints regarding the Site, our products and services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

Contact, Questions and Complaints
Visitors from the EEA, UK, and Switzerland can contact us at gdpr@cdsglobal.co.uk.  Consumers in the EEA, UK and Switzerland whose data is processed by CDS Global as a data processor on behalf of a CDS Global Client should contact the relevant CDS Global Client with any requests or complaints. 

We are committed to working with you to obtain a fair resolution in the event you have a complaint or concern about our data processing in relation to the Site. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a data protection authority.

CONTACT US
If you have any questions about this Notice or, in accordance with applicable laws, you would like to review or request changes to the information collected in connection with your use of the Site, please contact us at info@cds-global.com.