Privacy Policy Last updated: 9th December 2021

1. Introduction

At Selling Simplified Group, Inc. (Reg. No. 27-4882798) (“SSG”), we take your privacy seriously. This Privacy Notice (this “Notice”) states our policy and practices regarding the collection and use of personal data you submit to us, or which we collect via various channels (including our websites; through written correspondence, including e-mail; or through any of our offices or websites globally). When we refer to SSG, “we”, “us” or “our” we mean our entire company, including our divisions, subsidiaries and affiliates.

Through this Notice we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency (and the equivalent under applicable data protection laws) under the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR.

Please read this Notice carefully to understand our policies and practices regarding your data and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our websites or services. By accessing or using our websites, you agree to this Notice, subject to your rights as provided by this Notice or applicable law. This Notice may change from time to time (see Section 16: “Changes to Our Notice”).

2. The Data We Collect

Generally, we collect personal data from two groups of people: our marketing customers and our subscribers. “Personal data” means information that personally identifies someone or that relates to an identified or identifiable person.

i. Business Customer Data – When we enter into a relationship with our business customers, we will collect the personal data that we need to provide our services to them, including name; business contact information, including phone number, email address, and mailing address; company name; job title; and billing and transaction information. We may also collect additional information provided by our customers when they communicate with us.

ii. Subscriber Data – We collect certain data about individuals when they subscribe to our content, including name; business contact information, such phone number, email address, and mailing address; company name; and job title. This information may be publicly available or provided directly to us, such as by our customers or other third-party providers, as permitted by applicable law. This data may include potential subscribers or other parties that have demonstrated an interest in our services or that have registered to attend our corporate events.

3. How We Collect Your Personal Data

i. Through the SSG Websites – Both customers and leads may access our websites and/or communicate with us. In general, you can visit the SSG websites without identifying yourself or revealing any personal data. However, you may choose to provide us with personal data (e.g., via our ‘say hello’ or ‘let’s connect’ web forms). Within the SSG websites, you can make requests for information, register to receive materials, and in some cases, order products or services.

ii. From You – You may provide us additional personal data, such as when you contact us by phone or mail, or when you register for or attend corporate events. In these cases, we will collect your contact information as well as information regarding your communications with us.

iii. From Other Sources – We may collect information, including personal data, from publicly available sources or from other third parties. To the extent that we collect your personal data from these sources, we will treat it in accordance with this Notice, and we will honor your rights regarding your personal data as outlined in this Notice.

iv. Through Your Browser or Device – We also collect certain data automatically when you use our websites. For more information, see Section 9 “Aggregate Information About SSG Online Visitors” and Section 10 “Use of Cookies.”

4. How We Use Your Personal Data

The information you provide voluntarily will only be used in connection with your business relationship with SSG. All personal data will only be processed and used for lawful and legitimate business purposes specified below.

• To present our websites and their contents to you;
• To provide the services, products, or information you request. For example, if you fill out our ‘let’s connect’ web form, we will use the information provided to contact you about your interest in our services;
• Respond to your questions and comments and provide customer support;
• Communicate with you about our products, services, offers, and promotions;
• To better understand your needs and to provide better service;
• To plan and host corporate events and to populate online profiles for attendees on SSG’s websites;
• From time to time, to contact you for market research or to provide you with marketing information we think would be of particular interest. At a minimum, we will always give you the choice to opt-out of receiving such direct marketing or market research contact;
• To carry out our obligations and enforce rights arising from any contracts entered into between you and us;
• To protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
• To notify you about changes to our websites, products, or services;
• To comply with applicable legal requirements and industry standards; and
• Otherwise with your consent or as described to you when you provide the data.

5. The Legal Basis for Processing Your Personal Data

This Section 5 is only applicable to you if you are located in the European Economic Area (“EEA”).

The main grounds that we rely upon in order to process personal data of customers, leads, other users of our websites, and event attendees are the following:

i. Necessary for entering into, or performing, a contract – In order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data.

ii. Necessary for compliance with a legal obligation – We are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency.

iii. Necessary for the purposes of legitimate interests - Either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and inquiries from you or a third party, optimising our websites and customer experience, our market research, informing you about our or our customers' products and services, and ensuring that our operations are conducted in an appropriate and efficient manner. Our legitimate interests also include the following activities:

(a) building datasets by collecting professionals' contact information from a variety of sources, including publicly available information, so that we can market events, products and services, run surveys or research projects on behalf of our customers and share that collected data with our customers as necessary;

(b) verifying and/or enriching our existing datasets;

(c) sending promotional emails to a carefully selected campaign database of business contacts on behalf of our customers; and

(d) sharing personal data with our customers in respect of those contacts who have engaged with the relevant promotional e-mail including by clicking through to the web content or downloading assets.

iv. Consent – We may also ask for your consent to process your personal data in a particular way.

6. How We Share Your Personal Data

Personal data will be kept confidential but, subject to the provisions of any applicable law, may be provided to the third parties specified below (“Third Parties”). Third Parties may be located outside of your jurisdiction and, as a result, such disclosures may involve the transfer of personal data outside of your jurisdiction.

i. To SSG affiliates – We may share it with SSG both inside and outside the EEA. For more information regarding our affiliate locations, please see the “Contact Us” section below.

ii. To third-party service providers and contractors – We will share your personal data with trusted third parties where we have retained them to support our business and who are bound by contractual obligations to keep personal data confidential and to use it only for the purposes for which we disclose it to them. To the extent you are located in the EEA and personal data is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will use approved frameworks, including, with respect to any transfers outside of the EEA or access to the information as above, entering into standard contractual clauses as approved by the European Commission, copies of which are available here.

iii. To our customers – We may share certain lead information with our customers in accordance with applicable law to allow our customers to connect with potential leads for their products or services. We will not share sensitive personal data with our customers, nor do we share personal data with data brokers.

iv. As required by law – We may disclose your personal data as required by applicable law, regulation or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other applicable laws, we may disclose certain personal data to such bodies or agencies.

v. To new business owners – If we or our business merges with or is acquired by another business or company, we will share your personal data with the new owners of the business or company and their advisors, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Notice.

Where we disclose personal data to Third Parties, we do so:

i. To fulfill the purpose for which you provide it.

ii. To carry out our obligations and enforce rights arising from any contracts entered into between you and us.

iii. Otherwise with your consent or as described to you when you provide the data.

We also reserve the right to transfer your personal data to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all our assets, equity or similar transaction. Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use your data in a manner that is consistent with this Notice.

7. How Long We Will Hold Your Information

Unless otherwise required to do so under applicable law, we will retain your personal data for the time necessary to provide the services we perform for you or fulfil the purposes outlined in this Notice, and you can always request that we stop processing or delete your personal data (if you are located in the EEA). The next section sets out more information on your rights.

8. Your Rights Regarding the Information We Hold About You

Depending on where you are located, you have certain rights in relation to personal data we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

i. Right of Access – You have the right at any time to ask us for a copy of the personal data about you that we hold. Where we have good reason, and as permitted by law, we can refuse your request for a copy of your personal data, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so. To exercise this right, please contact us by us using the details in the “Contact Us” section below.

ii. Right of Correction or Completion – If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. To exercise this right, please contact us by us using the details in the “Contact Us” section below.

iii. Right of Erasure – In certain circumstances, you have the right to request that personal data we hold about you is erased, e.g., if the data is no longer necessary for the purposes for which it was collected or processed or our processing of the data is based on your consent and there are no other legal grounds on which we may process the personal data. To exercise this right, please contact us by us using the details in the “Contact Us” section below.

iv. Right to Object to or Restrict Processing – In certain circumstances, you have the right to object to our processing of your personal data, for example, if we are processing your data on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal data for direct marketing purposes. You may also have the right to restrict our use of your personal data, such as in circumstances where you have challenged the accuracy of the data and during the period where we are verifying its accuracy. To exercise these rights, please contact us by us using the details in the “Contact Us” section below.

v. Right of Data Portability – In certain instances, you have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that data to you or directly to a third-party organisation. This right exists only in respect of personal data that:

• you have provided to us previously; and
• is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal data of others without their consent. To exercise this right of data portability, please contact us by us using the details in the “Contact Us” section below.

vi. Right to Revoke Consent – To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. To exercise this right, please contact us by us using the details in the “Contact Us” section below.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your right.

9. Aggregate Information About SSG Online Visitors

We gather information and statistics collectively about all visitors to our websites for example:

• which area users access most frequently,
• which services users access the most,
• the type of operating system and browser software,
• the geographical location of browsers,
• broad demographic information, and
• to monitor mouse clicks and movements and scrolling activity.

We only use such data in the aggregate form. The information and statistics we collect helps us determine what is most beneficial for our users and how we can continually improve our online services to create a better overall experience for our users. Although such data may be shared with third parties, such as advertisers, the underlying data is not shared with anybody else.

10. Use of Cookies

We do automatically track certain information about your behaviour while visiting our webpages. We use this information in order to measure our website’s performance, user traffic, improve its design and functionality and other internal management purposes. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of our website.

The session cookie is never saved nor written to disk, and the information contained in the session cookie is only valid for that particular session and is discarded when the browser is closed. The information we collect in this way does not identify you personally and you remain anonymous unless you voluntarily choose to provide SSG with personal data.

11. Complaints

If you are unhappy about our use of your personal data, you can contact us using the details in the “Contact Us” section below. You are also entitled to lodge a complaint with a relevant data protection regulator. The details for the regulators in the UK and Ireland are as follows:

United Kingdom
Information Commissioner's Office
Telephone: 0303 123 11113
Website: https://ico.org.uk/concerns/

Ireland
Data Protection Commission
Telephone: 076 110 4800
Website: https://www.dataprotection.ie/