PRIVACY POLICY

Context Summits LLC, along with its parent company, Context Capital Partners LP (collectively, "Context"/"us"/"we"), are committed to protecting and respecting your privacy. This Policy (together with our Registration and Event Terms, Subscription and Services Agreement and Website Terms of Use, collectively referred to herein as the “Terms”) sets out the basis on which any personal data or other information we collect from you, or that you provide to us, will be processed by us in connection with our businesses.  This Policy applies to current and former users of our products and services. This Policy also applies to Context Advisors (as defined in the Terms) to the extent of the information covered herein. Capitalized or defined terms not defined herein have the meanings set forth in the Terms.

By using www.contextsummits.com and gocontextsummits.com (and any successor and related sites, collectively, the "Website") and/or Context’s products and services including participating in Summit Events, you are accepting and consenting to the practices described in this Policy.

Information you give us

This is information about you that you give us by filling in forms on the Website or by corresponding with us in person, by phone, email or otherwise. It includes information you provide, or have in the past provided to us, when you: (1) register on our Website, including looking for opportunities, sponsorships, media, association partnerships and suite packages; (2) contact us; (3) register to receive emails from us; (4) subscribe to our services (including registering for Summit Events); and (5) otherwise communicate with us.

Information we collect about you

With regard to each of your visits to our Website, we will automatically collect technical information, including: the IP address used to connect your computer to the Internet; hostname; network name; and location information (city, latitude/longitude and postal code).  See also “Information about Location Tracking” in the Terms.

Information we receive from other sources

This is information we receive about you from sources such as industry contacts, other attendees/participants, the service providers and vendors we use in connection with our products and services, and databases. If you reside in the European Union, we will notify you when we receive information about you from them and the purposes for which we intend to use that information. We will only further use this information if you consent to such use.

Cookies

Our Website uses cookies. A cookie is a small file of letters and numbers that we put on your computer or device if you agree. Cookies help us to provide you with a good experience when you browse our Website.

Our Website will place a cookie on your computer or device when you access a password protected part of the Website such as go.contextsummmits.com. This cookie is placed for security purposes to store your login information and is strictly necessary to enable you to navigate the Website.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of our Website.

 Uses made of the Information

 Information you give to us

 We use information you give to us in the following ways:

·        to share with our employees, agents and representatives who have a valid business reason to have access to such information;

·        if you are a Summit Event attendee or participant, to share with other Summit Event attendees and participants in order for us to give effect to the Context product and services you have chosen;

·        if you are a user of Context 365 Services, to share with other users of Context 365 Services in order for us to give effect to the Context product and services you have chosen;

·        to keep you informed of relevant Context events or related products and services, including the investment products and services of our Affiliates (as defined below) such as Context Advisors;

·        to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

·        to notify you about changes to our products and services, this Policy or our other terms of business; and

·        to ensure that content from our Website is presented in the most effective manner for you and for your computer or device.

Information we collect about you We will use this information:

·        to administer our Website and for internal operations;

·        to improve our Website to ensure that content is presented in the most effective manner for you and for your computer or device; 

·        as described in “Information about Location Tracking” in the Terms;

·        to allow you to participate in interactive features of our service, when you choose to do so;  and 

·        as part of our efforts to keep our Website safe and secure.

Information we receive from other sources

We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive and from what source).

Disclosure of your information

You agree that we have the right to share your personal data with:

·          any member of Context's corporate group, our affiliated businesses, funds and investment management and other affiliated and related entities (collectively, “Affiliates”) which Affiliates may use such information for the purposes permitted under this Privacy Policy; and

·          selected third parties in the normal course of our business, including: (1) companies (including accountants and attorneys) that provide products and services necessary to enable us to provide products and services to you, to effect a transaction that you request or to otherwise service you and/or your account; (2) broker-dealers and similar entities assisting CCP Advisors in offering its investment products and services, and (3) government agencies, courts, parties to lawsuits, regulators or other competent bodies having jurisdiction over Context, in response to inquiries, subpoenas or otherwise, including to meet any legal requirements applicable to Context.  In such cases, Context will share only the information that it is required or requested to share.

We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose. When we provide personal information to a service provider/vendor we expect these providers to safeguard your information, use the information only for the intended purposes and abide by applicable law.

Information you provide to third parties (including, but not limited to, BarclayHedge and any Summit Event attendees) in connection with your registration for, or participation in, any Summit Event or Context event shall be subject to any applicable agreement or privacy policy that governs your relationship with such party.

 We may also disclose your personal information to third parties:

·        in the event of a merger, joint venture, business combination or similar transaction, purchase or sale of any business or assets, in which case we may disclose your personal data to the prospective participant, seller or buyer; or

·        if Context Summits LLC or CCP or all or substantially all of its respective assets are acquired by a third party, in which case personal data held by it about its customers, users or registrants may be one of the transferred assets and we may disclose such data to the prospective acquirer.

Furthermore, you agree that your name and/or participant Company registered for, sponsoring, attending, or otherwise associated with a Summit Event may also be disseminated to other attendees/participants and third parties and posted on the Website.

When we are provided with updated information, we will endeavor to update our records as soon as possible. We do not, however, have a duty to inquire as to changes in the information you provide to us.

Anonymized Data

Notwithstanding anything in this Policy or the Terms to the contrary, we reserve the right to include your personal data as part of an anonymized aggregation of data and such aggregated data may be shared with third parties for any purpose.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by (i) logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences; (ii) by following the opt-out links on any marketing message sent to you; or (iii) by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience or other transactions.

Keeping your Personal Data secure

Context takes appropriate technical and organizational security measures to prevent unauthorized or unlawful processing, accidental loss of or destruction or damage to your personal data. Unfortunately, the transmission of information via the Internet is not completely secure.  Although Context does its best to protect your personal data, we cannot guarantee the security of your data including information transmitted to our Website; any transmission is at your own risk. For that reason, please do not use email to communicate information to us that you consider to be highly confidential.  If you wish, you may contact us instead via telephone.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access or unlawful use. 

Changes to our Privacy Policy

Any changes we make to this Policy in the future will be posted on this page and, in our discretion notified to you  by email. Please check back frequently to see any updates or changes to our Policy.

October 2019

Notice (1) to Persons located in the European Economic Area: Data Controller

For the purposes of EU data protection law, the data controller is Context Summits LLC of 597 5th Ave, 6th Floor, New York, NY 10017, USA. Questions, comments and requests regarding this Privacy Policy (the "Policy") should be addressed to GDPR@contextsummits.com.

Notice (2) to Persons located in the European Economic Area: Personal Data Transfers

The personal data we collect from you will be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It will also be processed by staff operating outside the EEA who work for us. This includes staff engaged in administering your registration for, sponsorship of, or attendance at, our Summit Events and other events or services, dealing with your enquiries when you contact us, and supplying our services to you. By submitting your personal data, you agree to this transfer, storing and processing.

Notice (3) to Persons located in the European Economic Area: Rights and Data Retention

Lawful Basis of Processing

We collect and process your personal information in conformance with applicable law. This includes but is not limited to the following lawful bases for collection and processing:

(i)               With your consent as provided hereunder;

(ii)             In connection with the performance of contractual obligations;

(iii)            As necessary to comply with a legal obligation; and

(iv)            To fulfill our legitimate interest in conducting our business, where your interests and fundamental rights do not override those interests including, but not limited to:

a.      providing the services for which you have enrolled;

b.      to keep our records updated;

c.      to study how customers use our products/services, to develop them and grow our business and inform our marketing strategy;

d.      for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercises;

e.      contacting you about our products, or responding to your requests.

Under certain circumstances, you have rights under data protection laws in relation to your personal data, which may include rights to the following:

•        Request access to your personal data.

•        Request correction of your personal data.

•        Request erasure of your personal data.

•        Object to processing of your personal data.

•        Request restriction of processing your personal data.

•        Request transfer of your personal data.

•        Withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at GDPR@contextsummits.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.