The following Additional Privacy Statements (the "Additional Statements") have been added by the Event Organiser and are specific and in relation to this Event ("SIW22") only. These set out additional Promotion and Insight activities that are being conducted by the Event Organiser and sets out additional data processing that they expect to do:
This website, https://siw22.heysummit.com, is for an event which is delivered by Scottish Business Network.
You can learn more about Scottish Business Network on their website here: https://www.sbn.scot/your-privacy.
This notice provides you with the information necessary to understand what Personal Data we collect, why we collect it and how we use it.
Our Products and Services
Scottish Business Network is an independent international membership organisation for Scottish entrepreneurs and business leaders. Scottish Business Network was created to facilitate greater communication, connectivity and support within the international Scottish business community.
The aim of Scottish Business Network is to create the largest network of Scottish business leaders in the world, making us the go-to network for businesses with the passion and ambition to export goods and services from Scotland. In addition to hosting regular events, Scottish Business Network proactively assist and support Scottish based companies to expand internationally.
Data Controller
For the purposes of Data Protection laws, the Scottish Business Network is the Data Controller of Personal Data covered by this Notice.
You may contact Christine Esson (christine@sbn.scot) about all issues related to this Policy, your Personal Data and to exercise your rights under Data Protection laws.
Why you should read this Policy
The Scottish Business Network (we, us or our) takes the privacy of its visitors, members and clients,(you, you or your) very seriously. We ask that you read this policy carefully because it contains important information about how we collect and use your personal data.
Our Commitments
Transparency
We are committed to you understanding and controlling the processing of your Personal Data.
Security
We are committed to maintaining and enhancing the privacy and confidentiality of your Personal Data. We take various steps to protect the information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology.
What - Personal Data We Collect
We collect and processes different types of personal data. There are three basic categories of personal data we collect:
Personal Data you give us Personal Data we get when you use our Product(s) Personal Data we get from third parties in relation to the Product(s)
Personal Data you give us
As part of the sign up process to become a member of the Scottish Business Network, we collect the following Personal Data about you: Name, email address, your Location and Linkedin Profile.
This personal data is captured as it is necessary to allow our network members to interact with each other on our site.
If you have consented to marketing, personal data may also be disclosed to other Recipients including Business Partner, Business Affiliates and Third Parties for the purposes of providing information on our products, services and offers that may be of interest to you.
Information we get when you use our services(s)
In some instances, as part of our consulting services, we may gather Personal Data from our client organisations.
The reason we capture this data is to assist us in supporting your business development.
Information we get from Third Parties in relation to the Services
As part of our membership sign up protocol, it is a requirement that we gather Personal Data on our members. In additon, we may indirectly capture additional Personal Data about our members from third parties with whom you have placed your personal.
The reason we capture this data is in order to assist us in supporting your business development .
Who - Sharing Your Personal Data
Who - Sharing Your Personal Data
In support of our business operations and to further business growth, we may share information about you with the following Recipients:
Business Partners:
Much of the interaction that occurs between our members will occur through our Business Partner, Very Connect. This involves the exchange of your Personal Data, for the purposes of setting up your profile. It is a requirement from the proper functioning of the Scottish Business Network that we do so and, is done in the course of our legitimate business.
Third Parties: We take the protection of your data extremely seriously. Accordingly, we do not share any of your Personal Data with any third parties.
How - Using Your Personal Data
We comply with the EU General Data Protection Regulation and UK Data Protection Legislation. We only collect, utilise and share personal data in strict adherence with Data Protection laws and principles. Your personal data has only been collected, utilised or shared by if:
you have consented to the processing the processing is necessary for the performance of (or entering into) a contract the processing is a result of an existing legal obligation to which we are subject the processing is in your vital interests the processing is in the public interest the processing is in our legitimate interests
Your Consent
In certain situations, we may obtain, collect and process your Personal Data to send you marketing communications about our offers, services and products. We will only send you these materials if you have consented and in accordance with your preferences for receiving marketing communications.
You have the right to withdraw your consent at anytime for any processing activities that you have consented to.
Contractual Necessity
In order for us provide you with the Product(s) you have requested, it will be necessary for us to capture Personal Data to process your request.
To fulfil the contractual obligations between you and us, it is also necessary to process Personal Data in order to perform the contact.
In this regard, we may use Personal Data to process your application and to liaise with you about this. We also need to administer contracts and agreements between you and us in relation to the Product(s).
Legal Obligations
We obtain, collect and process your Personal Data in order to comply with all our legal obligations.
Your Vital Interests
We may process Personal Data where it is deemed to be in your vital interests. This is an extremely rare circumstance for processing Personal Data and usually only occurs when essential for the life of the data subject or that of another.
Our Legitimate Interests
We may process Personal Data where it is within our legitimate interests to do so. We process Personal Data on this basis for financial and statistical analysis
Where we process your Personal Data on this basis for direct marketing (including profiling related to direct marketing), you have a right to object to us processing your information. Your right to object is detailed below in this policy and can be exercise at anytime, free of charge, where applicable.
Your Data Protection Rights
You have rights which allow you to address any concerns or queries regarding the processing of your Personal Data
Right of Access
You have the right to access and obtain a copy of the Personal Data that we hold about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive.
Right to Rectification
You have the right to request that we correct any inaccuracies in the Personal Data stored about you.
Right to Erasure
In certain circumstances, you have the right to request that we erase your Personal Data. For example, you may exercise this right in the following circumstances:
your Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by us;
where you withdraw consent and no other legal ground permits the processing;
where you object to the processing and there are no overriding legitimate grounds for the processing;
your Personal Data have been unlawfully processed; or
your Personal Data must be erased for compliance with a legal obligation.
Where we store your Personal Data for statistical purposes, we may not be able to comply with such a request where it would likely impair such statistical purposes or where we require your Personal Data for compliance with a legal obligation or in connection with legal proceedings.
Right to Restriction
You have the right to restrict our processing of your Personal Data where any of the following circumstances apply:
where you feel that the Personal Data which we hold about you are not accurate. This restriction will be in place for a period to enable us to verify the accuracy of your Personal Data;
where the processing is unlawful and you do not want your Personal Data be erased and request the restriction of its use instead;
where we no longer need to process your Personal Data (e.g. any of the Purposes outlined above have been completed or expire), but we require it in connection with legal proceedings;
where you have objected to our processing of your Personal Data pending the verification of whether or not our legitimate business interests override your interests, rights and freedoms.
Where you exercise your right to restrict our processing of your Personal Data, we will only continue to process it with your consent or in connection with legal proceedings or for the protection of the rights of other people or for reasons of important public interest.
Right to Communication
Any rectification or erasure of personal data or restriction of processing shall be communicated by us to any Recipient of your Personal Data. You will be informed about these Recipients should your request.
If a breach or loss of your data occurs you will be notified immediately by us.
Right to Data Portability
To further strengthen your control over your Personal Data, you have a right to receive and transfer the Personal Data that you provide to us in a structured, commonly used and machine readable format where we process your Personal Data on the legal bases of: a) your consent; or b) where it is necessary to perform our contract with you and such processing is carried out by automated means. Where you make such a request, we will directly transfer your Personal Data on your behalf to another controller of your choice (where it is feasible for us to do so).
Right to Object to Processing
In certain circumstances, you have a right to object to our processing of your Personal Data where we process it on the legal bases of: a) our legitimate business interest (e.g. the statistical purposes outlined above), including profiling based on our legitimate business interests; or b) your consent to marketing. We may not be able to comply with such a request where we can demonstrate that there are compelling legitimate grounds for us to process your Personal Data which override your interests, rights and freedoms or where the processing of your Personal Data is required for compliance with a legal obligation or in connection with legal proceedings.
Right to Object to Automated Decision-Making, including Profiling
You have a right not to be subjected to decisions based solely on automated decision-making, including profiling, which produce legal effects concerning you or similarly significantly affects you.
We may not be able to comply with such a request where we rely on the legal bases of: a) your explicit consent; or b) where it is necessary to enter and perform our contract with you (as detailed in section 2 above). You will however be entitled to have a person from our team review the decision so that you can query it and set out your point of view and circumstances to us.
Enforcing Your Data Protection Rights
If you feel that the processing of your Personal Data is not in line with our data protection obligations, you can complain to a data protection supervisory authority.
Our Data Protection Supervisory Authority
You can contact the UK Data Protection Commissioner offices at:
Telephone: +44 303 123 1113 Lo Call Number: 0303 123 1113
Postal Address: E-mail:
Wycliffe House, casework@ico.org.uk.
Water Ln,
Wilmslow
SK9 5AF,
UK
Data Retention - How long do we keep your Personal Data
We will not retain your Personal Data longer than is necessary to fulfil the purposes for which it was collected. However, we may be required by applicable laws and/or regulations to hold your personal data longer than this period. If no contradicting legal obligation exists, Scottish Business Network will delete your Personal Data in line with our Retention Policy or when you request that your Personal Data be erased and no longer processed by us. Additionally, where there is a contradicting statutory obligation for us to retain your Personal Data, we will restrict/block further processing and then erase the relevant Personal Data when we no longer have a requirement to retain it.
Notification of a Data Breach
If a security breach causes an unauthorized intrusion into our system that materially affects you, we will notify you as soon as possible and later report the action we took in response to any breach
Where we send and store your Personal Data
We will make reasonable efforts to ensure that your data is not transferred outside the European Economic Area (EEA). Where we use data servers that may transfer data out of the EEA we will take steps to ensure adequate protections are in place to ensure the security of your information and give you remedies in the unlikely event of a security breach.
However, certain Recipients (our third party service providers) who process your Personal Data on our behalf may transfer your Personal Data outside the EEA to a country that does not have an Adequacy Decision of protection to your Personal Data. Where such transfers occur, we ensure that: a) they do not occur without our prior written authority; and b) that an appropriate transfer agreement is put in place to protect your Personal Data. If you would like to find out more about any such transfers, please contact our Data Protection Officer.
Changes to this Policy
We may change this Policy from time to time, in whole or part, at our sole discretion or to fulfil a legal obligation. We encourage you to check our website to view the most recent version of this Policy. You may also request a copy of the most recent version of this Policy by contacting us.
If, at any time, we decide to use your Personal Data for a purpose that is different from the original purpose of collecting your Personal Data, we will contact you regarding this changes.
HeySummit is not responsible for any part of the above Additional Statements and is only responsible for the Core Privacy Statements set out hereunder:
The following Core Privacy Statements (the "Privacy Statements"), together with the Core Terms of Service and any other documents referred to herein set out we will use the data you provide us at www.HeySummit.com and/or www.app.HeySummit.com (the "Platform") and what Insight activities are ongoing there too.
Please read these Privacy Statements carefully and ensure that you understand them. You will be able to change your Privacy Preferences at any time throughout your time using the Platform and thereafter.
HeySummit’s purpose in establishing this Privacy Statement is to give you information about how HeySummit collects and processes your personal data through your use of the HeySummit Services, including any data you may provide through the HeySummit platform. If you do not agree with the terms, do not access or use the HeySummit Services, websites or any other aspect of HeySummit’s business.
This Privacy Statement applies to all users of HeySummits Platform and associated technology. It is important that you read this Privacy Statement together with any other Privacy Statement or fair processing policy we may provide on specific occasions when we are collecting, or processing, personal data about You, so that you are fully aware of how and why we are using your data. This Privacy Statement supplements other notices and privacy policies and is not intended to override them.
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. HeySummit and Event hosts are independent controllers of certain types of your personal data, such as your registration data (like name and email) and attendance data (like Event name, date and time of Event, and Event sessions attended). Event hosts are the controller, and HeySummit is the processor of Event data, such as information and materials submitted to, or during an Event.
We keep our Privacy Statement under regular review and it may be updated periodically. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will notify you by posting an updated, date-stamped version of this Privacy Statement on our website. If we make changes that materially alter your privacy rights, we will provide notice to you in accordance with applicable law. Notice may be by posting a notice on our website, by email to you at the email address that you most recently provided to us, or by other means, consistent with applicable law. Accordingly, please keep your account information, including email address, updated.
The HeySummit Services include links to third-party websites and applications as well as to partner providers of multiple different types of services associated with a particular Event.
Clicking on links to third party websites, content or applications may allow those third parties to collect or share data about you. We do not control those third-party websites or content and are not responsible for their privacy statements or the way in which they collect or use your data.
Where you access or use third party services provided by an Event organiser, advertiser, sponsor or any other party who participates in an Event, we encourage you to request details of and read the Privacy Statement of that party. We do not control those third parties and are not responsible for their privacy statements or the way in which they collect or use your data.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identifying information has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with access to the HeySummit Services).
We use different methods to collect data from and about you including through:
The legal basis for using your information as set out in this Privacy Statement are as follows:
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a user of the HeySummit Event Platform |
(a) Identity (b) Contact |
Performance of a contract with you |
| To process any paid entry to an Event:
(a) Managing payments, fees and charges (b) Verifying your identity and details of your payment method or credit card account (c) Communicating with you, for example sending you confirmation of your attendance for an Event. |
(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests |
|
To manage our relationship with you which will include: (a) Providing access to Platform services (b) Notifying you about changes to our terms or Privacy Statement (c) Asking you to leave a review or take a survey (d) Investigating complaints |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use the HeySummit Event Platform and associated products/services) |
| To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, administering our CRM, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how users use the HeySummit Event Platform and to grow our business and inform our marketing and growth strategy) |
| Share your information to support the Host or Event Organiser or Team Member(s) to create, manage and deliver the Event. |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
To provide our own services as per our collective agreements and support the Event Organiser to conduct their agreements with you. |
| To use data analytics to improve our Platform, products/services, marketing, user and Partner relationships and experiences. |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of users for certain Platform services and to keep our services and web site updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about Events or other services available through the HeySummit Event Platform that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop the products and services available through the HeySummit Event Platform) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may opt out of any non critical marketing communications but some communications are directly related to the provision of our Services.
Recommendations from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which services and offers may be relevant for you. Subject to applicable law, we may send you information that we think may be of interest to you.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time. You can contact us or, where applicable, use the instructions located at the bottom of your email. Please note that regardless of your request, we may still use and share certain information as permitted by this Privacy Statement or as required by applicable law. For example, you may not opt out of certain operational communications, such as those reflecting our relationship or transactions with you.
Cookies
We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the HeySummit Services and your experience, see which areas and features of our Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Advertising and Analytics Services Provided by Others
We may allow others to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the HeySummit Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by HeySummit and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the HeySummit Services and other websites and better understand your online activity.
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.
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
Where third parties provide Events or support the provision of Services made available to you, these third parties may receive certain personal data about you. Whilst we are not in control of these third parties, we require all third parties to respect the security of your personal data and to treat it in accordance with the law.
To help constantly improve and tailor the service we provide to you, we may use aggregated information so that we can administer and improve our services, analyze trends, gather broad demographic information and detect suspicious or fraudulent transactions and most importantly monitor and improve our operations on a day to day basis. In carrying out this activity, we may pass some information to third parties in aggregate and anonymized format.
Your disclosure to third parties
Except as otherwise expressly included in this Privacy Statement, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, different rules may apply to their use or disclosure of the information you provide to them. HeySummit does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.
We may transfer your personal data outside your country of residence, including the European Economic Area (EEA), in our performance of services.
Whenever we transfer personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place commercially reasonable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. That said, no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or as required or permitted by applicable law.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
If you provide personal data in connection with the submission of Event Content, we may process sensitive personal data as part of the HeySummit Services.
This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
Time limit to respond
We try to respond to all legitimate requests within one month or within the timeline provided by applicable law. 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.
If you have any questions about this Privacy Statement or our privacy practices, including any requests to exercise your legal rights, please contact us as follows:
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). You may also direct your complaint or concern to your applicable data protection authority. We would, however, appreciate the chance to address your concerns before you approach the ICO or another data protection authority.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In respect to HeySummit, that is the performance of our agreement with you to make the HeySummit Services available. We are not involved in the processing of your Personal Data during any engagement you enter into with our third party partners.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
Requests to exercise your rights may be submitted by emailing us at support@heysummit.com Please be prepared to provide your first and last name and email address that matches information we currently have on file. Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from California consumers as required by law.