C2C General Privacy Policy

 

INTRODUCTION

This C2C Privacy Policy (“Privacy Policy”) provides details on the collection, use, and sharing (collectively referred to “processing” or ”process”) as of personal information by C2C (“C2C”, “we”, “us”, “our”) in connection with our visitors, members, and customers (“you” or “your”) use of C2C’s c2cglobal.com websites (“Websites”), mobile applications (“Mobile App”, when and where available), and social media pages, your interactions with C2C or partners during in-person or virtual meetings or at C2C events, and in the context of other offline sales and marketing activities. This Privacy Policy also explains the privacy rights you have in relation to these processing activities.

The Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. Our current Privacy Policy will always be on our website at www.c2cglobal.com/privacy and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates.

As used in this Privacy Policy, “personal information”, “personal data”, or “information about you” means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, business contact details, or information gathered through your interactions with us via our websites or at events. For more detail about the types of personal information that we process, please refer to Section 4 below.

 

SCOPE

This Privacy Policy applies to the processing of personal information by C2C of:

• visitors and users of the various C2C Websites, including our Websites on C2Cglobal.com, computer or mobile software applications and our social media pages that link to this Privacy Policy (collectively referred to as the Websites);
• attendees of C2C events or C2C-sponsored events;
• customers and prospective customers and their representatives;
• subscribers to C2C newsletters; and
• suppliers and business partners and their representatives.

When interacting with our Websites, you also have the ability to link or connect with non-C2C websites, services, social networks, applications, or other features. Enabling these features may lead to third parties processing information about you. C2C does not have any control over their collection or use of information about you. We encourage you to review the privacy policies of these third parties before using these features.

 

WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

C2C and its affiliated entities are responsible for processing your personal information described in this Privacy Policy. 

 

WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?

C2C can process information about you collected both offline and online.

• Offline information about you originates from our interactions with you during in-person meetings or at C2C events, conferences, workshops, or gatherings;
• Online information about you originates from your activities on our Websites, for example, in relation with your C2C account, sales and pre-sales inquiries, subscription to our newsletters, or from your interactions with C2C via electronic communication tools such as email or telephone. Information about you may also be provided by third party sources, such as data aggregators who may not have a relationship with you.
• Online information about you may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our Websites or websites of third parties. For more information on cookies and similar technologies, please see Section 11 below.

Specific pieces of information about you that C2C collects include:

• name, title, physical address, email addresses, and telephone numbers;
• the type of relationship you have with Google Cloud (e.g., customer, partner, Google Cloud employee, consultant, independent developer, etc.) 
• demographic attributes, when tied to personal information that identifies you;
• photographs, video recording, and audio recording from in-person and/or virtual events;
• reviews, comments, testimonials, and other content you post or share;
• transactional data, including products and services ordered, financial details and payment methods;
• company data such as the name, size and location of the company you work for and your role within the company;
• data and comments from surveys and publicly available information, such as social media posts;
• call recording and chat transcript data from Sales and customer support calls and live chat sessions;
• unique IDs such as your mobile device identifier or cookie ID on your browser;
• IP address and information that may be derived from IP address, such as geographic location;
• information about a device you use, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, and the preferred language; and,
• behavioral data of the internet connected computer or device you use when interacting with the Websites, such as advertisements clicked or viewed, Websites and content areas, date and time of activities or the web search used to locate and navigate to a Website.

Please note that C2C does not control the content that you may post to C2C social networks; in some cases, such content may be publicly available on the internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.

 

FOR WHAT PURPOSES DO WE USE YOUR PERSONAL INFORMATION?

We may use personal information for the following business or commercial purposes:

• To develop, improve, and present our education and learning programs, and for community event communication

We use your personal information to help us develop, improve, and present our programs. We also use your personal information to communicate with you about our community and our events.

• To communicate and respond to your requests and inquiries to C2C

If you get in touch with us (such as by submitting contact forms on our Websites, attending C2C events or other occasions, sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries. We can also process personal information to interact with you on third party social networks.

• To deliver functionality on our Websites and for their technical and functional management

When you choose to register with us (such as to make use of our communities), we need to process the personal information provided by you so that we can create and manage a personal account for you. Upon creating your account, we will send you your personal login information. This personal information enables us to administer your account, for example by changing your password for you.

• To engage in transactions with customers, suppliers and business partners and to process purchases of our products and services

If you place an order for our products and services, or if you provide services to C2C, our employees, customers, or partners as a supplier or business partner, C2C processes information about you to engage in and administer the relevant transactions (such as by sending invoices and making payments), administer your order, and help you get started and adopt our products and services.

• To analyze, develop, improve and optimize the use, function and performance of our Websites and products and services

We may process personal information in order to analyze, develop, improve and optimize the use, function, and performance of our Websites and products and services, including for quality assurance and training purposes, as well as for marketing and sales campaigns. In case the Websites permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities, C2C may process personal information when moderating these activities.

• To manage the security of our Websites, networks and systems

We may collect Website use data for security and operations management to help keep our Websites, networks and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots.

• To comply with applicable laws and regulations and to operate our business

In some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.

• To market our products and services or related products and services and to tailor marketing and sales activities

C2C may use information about you to notify you about new product releases and service developments, events, alerts, updates, prices, terms, special offers and associated campaigns and promotions (including via newsletters). C2C may also use personal information to advertise C2C’s products and services or related products and services, and also to have our distributors, resellers, or partners notify you about our products or services or their related products or services (such as via joint sales or product promotions). We do our best to tailor your website visit, marketing experience, and our communications to your expressed interests.

By registering for an event, you authorize C2C and its service providers, partners, exhibitors, and sponsors to process information about you gathered in relation to the event and to share information about your registration and attendance with your company. We will provide a method for opting out of such sharing at the time you register for the event. C2C may also permit designated event partners or conference sponsors to send you a limited number of communications related to your event attendance. Please note that our partners and event sponsors may directly request information about you at their event booths or presentations, and their use of your information that you provide to them will be subject to their privacy policies.

We may also use your personal information to post on our Websites testimonials you submit to us, but will first obtain your consent to use your full name in connection with your testimonial.

• To provide select services to C2C customers which may include publicly-available information regarding names of company CEOs

For some Services, we may collect the publicly-available names of CEOs of companies to better understand the status of these companies and help inform our services which relate to providing customers information about other companies.

 

WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU?

For residents of the European Economic Area, Switzerland, and the United Kingdom, our basis under the General Data Protection Regulation (“GDPR”) for collection and processing of your personal information (which, for you, is defined in GDPR as “personal data”) is the following:

• In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore we have a legitimate interest in processing this information.
• In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
• We process personal information for marketing and sales activities based on your consent where so indicated on our Websites at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services.
• We rely on our legitimate interest to analyze, develop, improve and optimize our Websites, products and services, and to maintain the security of our Websites, networks and systems.

In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATION

C2C maintains personal information for the following retention periods:

• Information about you we collect to engage in transactions with our customers, suppliers, and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
• If you have registered for an C2C account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for 18 consecutive months. C2C retains records of that deletion for 90 days.
• If you have registered for our newsletters and blogs, your information will be retained for as long as you are subscribed to our distribution lists, and then deleted. We will retain your personal information for as long as your account is active, or as long as you are a registered member or account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
• Contact information such as your email address or phone number collected online on our Websites or offline from our interactions with you at C2C events and conferences, and used for direct marketing and sales activities will be retained for as long as we have an active (customer) relationship with you. We treat you as an active contact if (i) you have interacted with C2C or updated your contact details and preferences in the past 18 months; and (ii) you have not made a deletion request.
• If you have reached out to us via chat, we will delete all chat transcripts 90 days after the chat has concluded.

Personal information needed to retain your opt-out preferences is retained for our archives as long as it is needed (or longer as necessary to comply with applicable law).

WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?

 

Sharing within C2C

As a global organization, information about you may be shared globally throughout C2C’s worldwide organization.

C2C employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share personal information with the following third parties for a business purpose:

• Third-party service providers (for example, credit card processing services, order fulfillment, analytics, event/campaign management, website management, information technology, and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of C2C;
• Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
• As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

We may share personal information with the following third parties for a commercial purpose:

• C2C partners for further follow-up related to your interests, specific partners that offer complementary products and services or with third parties to facilitate interest-based advertising.
• We may share your personal information with our business partners, including Google. For example (but not as a limitation), we provide your name, job title, and email address to Google, who may want to learn who has attended a C2C event so that they can, for example, invite attendees to other events, send product and service information, and send other communications. Google and our other business partners may send you communications separate from those of C2C. 

When we share your personal information with third parties, we will have such third parties under written obligations of confidentiality to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

 

HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

C2C is a global corporation and personal information is processed globally. If personal information is transferred to a C2C recipient in a country that does not provide an adequate level of protection for personal information, C2C will take measures designed to adequately protect information about you.

 

HOW IS YOUR PERSONAL INFORMATION SECURED?

 

C2C has implemented appropriate technical, physical, and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

 

COOKIE NOTICE

WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE ON OUR WEBSITES?

 

The technologies we use for automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.

Cookies (or browser cookies)

A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (Internet Explorer, Firefox, Safari or Google Chrome).

Different types of cookies which have different purposes are used on our Website.

Essential Cookies

These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies

These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Website pages from their website and whether your visit has led to the use or purchase of a Product or Service from our Website, including the references for the Product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Functionality Cookies

These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on websites which do not belong to us.

It is possible that you will come across third-party cookies on some pages of websites that are not under our control.

We also use cookies to implement tracking technology on our Website and Mobile App. This allows us to display advertising that is tailored to you on our Website, to understand which parts of our content interest you the most, and which Product or Service categories you request. This tracking uses De-Identified Personal Information data. Some of our service providers are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider. 

At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Local Storage Cookies

Certain features of our Website may use local stored objects (to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies. 

Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

Pixel Tracking. In addition to using cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other websites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.

GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

IP Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.

Google. Google Analytics. We use, and some of our third-party service providers may use, Google Analytics (click for link to Google’s website) or other analytics service to help us understand the use of our Website and Services. Google Analytics is a web analysis service provided by Google. Google utilizes data it collects to track and examine the use of our Website and Mobile App to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. The Personal Information collected and processed may include cookies, usage data, and other internet information. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties

Google Maps/Google Earth. We also use Google Maps (including the Google Maps API(s)) and/or Google Earth, which may, among other things, request access to your geolocation, and both of which are subject to their own terms of use and privacy policy.

 

WHAT ARE YOUR PRIVACY RIGHTS?

We provide multiple choices in respect of the information we process about you:

• Opt-out of our use or sharing of your personal information

You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by C2C

• Delete personal information

You can ask us to erase or delete all or some of the information about you.

• Change or correct personal information

You can edit some of the information about you by. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.

• Object to, or limit or restrict use of personal information

You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).

• Right to access and/or have your information provided to you

You can also ask us for a copy of information about you and can ask for a copy of information about you provided in machine readable form if you reside in the European Economic Area, or other jurisdiction that provides you this right as a matter of law.

You can exercise these choices in accordance with applicable laws by emailing us at privacy@c2cglobal.com.

 

DO YOU COLLECT SENSITIVE INFORMATION AND INFORMATION FROM CHILDREN?

Sensitive personal information

We currently do not need, and we ask that you do not send us any sensitive personal information, for example, government-issued IDs, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership. If we ever need such information, we will request it and disclose the purposes for which we need such information. 

Children’s privacy

As a company focused on serving the needs of businesses C2C Websites are not directed to minors and C2C does not promote or market its services to minors. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our Websites without appropriate consent, please notify us through our inquiry form so that we may immediately delete the information from our servers and make any other necessary corrections. Additionally, please use this same form to request removal of content or information that was posted to our Websites when the registered user was under the age of 16. Please note that such requests may not ensure complete or comprehensive removal of the content or information, as, for example, some of the content may have been reposted by another user.

 

DATA PROTECTION OFFICER

C2C has appointed a Global Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, please contact the Global Data Protection Officer at privacy@c2cglobal.com. 

Written inquiries to our Global Data Protection Officer may be addressed to:

C2C

Attn: Global Data Protection Officer

20 N Wacker Drive, Suite 1810

Chicago, IL 60606 U.S.A.

 

DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.

If you have an unresolved privacy or data use concern that you believe we have not addressed satisfactorily, please contact TRUSTe, our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. You also have the right to file a complaint with a competent data protection authority if you are a resident or citizen of a European Economic Area member state.

 

17. C2C CORPORATE HEADQUARTERS

C2C
20 N Wacker Drive
Suite 1810
Chicago IL 60606

 

Effective as of: January 26, 2022