Introduction
Tech-CIO (“Tech-CIO”, “we”, “us” or “our”) is committed to protecting your privacy and handling your personal data responsibly.
This Privacy Notice (the “Notice”) explains how we collect, use, share and safeguard the personal data you provide to us, or that we collect through our websites, written correspondence (including email) and any of our offices worldwide. References to Tech-CIO include our divisions, subsidiaries and affiliates.
This Notice is also designed to meet the transparency requirements of the EU General Data Protection Regulation 2016/679 (“GDPR”) and the national laws that implement it. It sets out:
- The personal data we collect
- How and why we use it
- The legal basis for processing it
- Who we share it with
- How long we keep it
- Your rights and how to exercise them
Please read this Notice carefully. By accessing or using our websites, you agree to this Notice, subject to your rights under this Notice and applicable law. If you do not agree with our policies and practices, please do not use our websites or services. We may update this Notice from time to time (see Section 16, Changes to Our Notice).
The Data We Collect
We collect personal data from two main groups: our business customers and our subscribers. “Personal data” means any information that identifies, or relates to, an identified or identifiable individual, as defined by applicable law.
- Business Customer Data
When you enter into a business relationship with us, we collect the personal data we need to provide our services, including:
- Name and job title
- Company name
- Business phone, email and mailing address
- Billing, transaction and payment card details
We may also collect any additional information you choose to share when communicating with us.
- Subscriber Data
Our audience is IT professionals and technology decision-makers, from CIOs and IT directors to architects and developers, who follow our coverage of databases, CRM, enterprise applications and development tools. When you subscribe to our content, we collect:
- Name and job title
- Company name
- Business phone, email and mailing address
- IT role and areas of technology interest
This information may come directly from you, from publicly available sources, or from our customers and other third-party providers, as permitted by law. It may also relate to prospective subscribers, people who have expressed interest in our services, and registered attendees of our corporate events.
How We Collect Your Personal Data
- Through our websitesYou can browse the tech-cio.com website without identifying yourself. If you choose to, you can share personal data with us, for example through our “Say hello” or “Let’s connect” forms, to request information, register for materials or order products and services.
- Directly from youWhen you contact us by phone or mail, or register for or attend our corporate events, we collect your contact details and a record of your communications with us.
- From other sourcesWe may obtain personal data from publicly available sources or other third parties. Any data we receive this way is handled in line with this Notice, and your rights apply to it in full.
- Automatically, from your browser or deviceSome information is collected automatically when you use our websites. See Section 9, Aggregate Information and Section 10, Use of Cookies.
How We Use Your Personal Data
Information you provide voluntarily is used only in connection with your business relationship with Tech-CIO. We use personal data for the following legitimate business purposes:
Delivering our services
- Presenting our websites and their content to you
- Providing the services, products or information you request; for example, replying to a “Let’s connect” enquiry
- Understanding your needs so we can serve you better
- Notifying you of changes to our websites, products or services
Events and marketing
- Planning and hosting corporate events, and creating attendee profiles on our websites
- With your consent, contacting you for market research or with content and offers we believe will interest you, such as updates on databases, CRM, applications and development tools. You can opt out of this at any time
Contracts, security and compliance
- Performing our contracts with you and enforcing our rights under them
- Preventing fraud, unauthorised transactions, claims and other liabilities, including identifying hackers and unauthorised users
- Complying with legal requirements and industry standards
- Any other purpose you consent to, or that we describe when you provide the data
Payment card data: we use credit card information only for payment processing and related purposes.
The Legal Basis for Processing Your Personal Data
Under the GDPR, we rely on the following legal grounds to process the personal data of customers, leads, website users and event attendees:
- Performance of a contractProcessing that is necessary to deliver a service to you, or to take steps at your request before entering into a contract with us.
- Legal obligationProcessing that is required to meet our legal obligations, including disclosures we may be legally required to make to regulators or law enforcement agencies.
- Legitimate interestsProcessing that is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms. These interests include responding to enquiries, improving our websites and customer experience, conducting market research, informing you about our products and services, and running our business appropriately and efficiently.
- ConsentWhere we ask for your consent to process your personal data in a specific way.
How We Share Your Personal Data
We may disclose your personal data to the following recipients:
- Tech-CIO affiliatesWe may share personal data across the Tech-CIO group, both inside and outside the European Economic Area (“EEA”). See Section 19, Contact Us for our locations.
- Service providers and contractorsTrusted third parties who support our business and are contractually bound to keep personal data confidential and use it only for the purposes we specify. Where data is transferred outside the EEA, we use approved safeguards, including the European Commission’s Standard Contractual Clauses.
- Our customersWe may share certain lead information with our customers, typically technology vendors, in accordance with applicable law, so they can connect with IT professionals interested in their products or services.
- Regulators and law enforcementWhere required by law, regulation or legal process, or in response to a lawful request from a regulatory body or law enforcement agency, as permitted by the GDPR and other laws.
- New business ownersIf we merge with or are acquired by another business, personal data may be transferred to the new owners and their advisors, who must use it only for the purposes set out in this Notice.
- Other circumstancesTo fulfil the purpose for which you provided the data, to perform and enforce our contracts with you, or otherwise with your consent.
Our commitment: we never share sensitive personal data with our customers, and we do not share personal data with data brokers.
How Long We Will Hold Your Information
We keep personal data only for as long as necessary to provide our services to you or to fulfil the purposes described in this Notice.
You can ask us at any time to stop processing or to delete your personal data. Your rights are explained in the next section.
Your Rights Regarding the Information We Hold About You
You have the following rights in relation to the personal data we hold about you. Before acting on any request, we will ask you to verify your identity.
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Right of Access
Request a copy of the personal data we hold about you at any time. Where permitted by law, we may refuse all or part of a request for good reason, and we will always explain why.
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Right of Correction or Completion
Have personal data that is inaccurate, out of date or incomplete corrected, updated or completed.
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Right of Erasure
Ask us to erase your personal data in certain circumstances; for example, where it is no longer needed for its original purpose, or where processing was based on consent and no other legal ground applies.
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Right to Object to or Restrict Processing
Object to processing based on our legitimate interests where no compelling grounds override your rights, and object at any time to direct marketing. You may also restrict processing, for example while the accuracy of your data is being verified.
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Right of Data Portability
Receive personal data you have provided to us, and that we process by automated means, in a structured, commonly used and machine-readable format, or have it sent directly to another organisation. We cannot guarantee compatibility with third-party systems, or act on requests involving other people’s data without their consent.
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Right to Revoke Consent
Where processing is based on your consent, withdraw that consent at any time.
How to exercise your rights: contact our Privacy Team using the details in Section 19, Contact Us. Most of these rights are subject to limitations and exceptions. If we are unable to fulfil a request, we will tell you why.
Aggregate Information About Tech-CIO Online Visitors
We collect statistics about visitors to our websites as a group, including:
- The areas of the site visited most often
- The services used most
- Operating system and browser type
- Approximate geographic location
- Broad demographic information
- Mouse clicks, movements and scrolling activity
We use this data only in aggregate form, to understand what is most useful to our visitors and to keep improving our online services.
We may share these aggregate statistics with third parties such as advertisers, but we never share the underlying individual data.
Use of Cookies
We automatically record certain information about how you use our web pages. We use it to measure website performance and traffic, improve design and functionality, and for other internal management purposes.
- Session cookies onlyOur session cookie is never saved or written to your device’s disk. It is valid only for your current visit and is deleted when you close your browser.
- You remain anonymousInformation collected this way does not identify you personally, unless you choose to share personal data with us.
Complaints
If you have concerns about how we use your personal data, please contact us first using the details in Section 19, Contact Us. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):
Wycliffe House, Water Lane
Wilmslow, Cheshire
SK9 5AF
If you live or work outside the UK, or your complaint concerns our activities outside the UK, you may prefer to contact another supervisory authority. A list of data protection authorities in the EEA is published by the European Data Protection Board.
Security
We use reasonable measures to protect your personal data from unauthorised access and disclosure. No system is completely secure, however, and we cannot guarantee the absolute security of the data we collect and store.
What we do
- Apply network and database security measures
- Encrypt sensitive data, such as credit card information, when it is collected or transferred
What you can do
- Keep any password for our websites confidential
- Never share your password with anyone
Other Websites
Links and banner advertisements on our websites may take you to third-party websites whose privacy practices differ from ours.
We are not responsible for, and have no control over, any data submitted to or collected by those third parties. Please review their privacy policies before sharing any information with them.
Internet-based Transfers
Because the internet is a global environment, collecting and processing personal data online necessarily involves transferring data internationally.
No transmission over the internet is completely secure. Although we take commercially reasonable steps to protect your data, we cannot guarantee the security of data sent to our websites over third-party networks, and any transmission is at your own risk. Once we receive your data, we apply strict procedures and security features to prevent unauthorised access.
Do Not Track
Some web browsers let you signal that you do not want your online activity tracked over time and across websites (“Do Not Track”).
Our websites do not currently respond to Do Not Track signals, and may continue to collect information as described in this Notice.
Changes to Our Notice
We will post any changes to this Notice on this page and update the revision date shown at the top. If we make material changes to how we handle personal data, we will notify you by email at the primary address on your account, or by a notice on our websites.
Please keep your email address with us up to date, and review this Notice periodically for any changes.
California Privacy Rights
If you are a California resident, please see our Privacy Notice for California Residents for details of the additional rights available to you.
Children’s Information
Our services are not directed to children under the age of 16, and we do not knowingly collect or solicit personal data from them.
If we learn that we have collected personal data from a child under 16, we will delete it promptly. If you believe we may hold information from or about a child under 16, please contact us.
Contact Us
For any questions about this Notice or how we process your personal data, including requests to exercise your rights, please contact our Privacy Team. We will ask you to verify your identity before responding.
1309 Coffeen Avenue, STE 1200
Sheridan, Wyoming 82801
Privacy Notice for California Residents
Last updated May 25, 2020This notice supplements the Tech-CIO Privacy Policy above, which is incorporated by reference. It applies only to residents of the State of California (“consumers” or “you”) about whom we collect personal information, including visitors to our websites and our subscribers.
We provide this notice to comply with the California Consumer Privacy Act of 2018, as amended, and its implementing regulations (the “CCPA”). Terms defined in the CCPA have the same meaning in this notice.
Information We Collect
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In the last 12 months, we have collected the following categories of personal information:
| Category | Examples | Collected |
|---|---|---|
| Identity Data | Name, business email address, phone number, mailing address | Yes |
| Customer Records Data | Billing, transaction and payment card information | Yes |
| Professional Data | Company name, job title, IT role, areas of technology interest | Yes |
| Internet Activity Data | Browser and operating system, pages visited, clicks and scrolling, approximate location | Yes |
Personal information does not include
- Publicly available information from government records
- De-identified or aggregated consumer information
- Information outside the scope of the CCPA, such as health or medical information covered by HIPAA or the California Confidentiality of Medical Information Act (CMIA), and personal information covered by sector-specific laws including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994
Why we collect it
In the last 12 months, we have collected each category above for the following business and commercial purposes:
- Processing your requests and transactions, and preventing transactional fraud
- Providing support, responding to enquiries, investigating concerns, and improving our responses
- Creating, maintaining, customising and securing your account
- Testing, research, analysis and product development
- Providing, personalising and developing this Site and our products and services
- Maintaining the safety, security and integrity of this Site, our products, services, databases, technology assets and business
- Delivering relevant content, offers and advertising through this Site, third-party sites, email or text message (with your consent where required by law)
Other uses and disclosures
We may also use or disclose personal information:
- To respond to law enforcement requests, or as required by law, court order or government regulation
- As described to you at the time of collection, or as otherwise permitted by the CCPA
- To evaluate or carry out a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of our assets, including in bankruptcy, liquidation or a similar proceeding, where personal information about Site users is among the assets transferred
We will not collect additional categories of personal information, or use it for materially different, unrelated or incompatible purposes, without notifying you.
Disclosures for a Business Purpose
In the preceding 12 months, we have not disclosed consumers’ personal information for a business purpose.
Sales of Personal Information
In the preceding 12 months, we have sold the following categories of personal information:
| Category sold | Category of recipient |
|---|---|
| Identity Data | Our business customers, for their own internal marketing use |
| Customer Records Data | Our business customers, for their own internal marketing use |
| Professional Data | Our business customers, for their own internal marketing use |
It is not Tech-CIO’s practice to sell personal information to data brokers. You can opt out of sales at any time; see Opt-Out and Opt-In Rights.
Your Rights and Choices
The CCPA gives California residents specific rights over their personal information. This section explains those rights and how to exercise them.
Right to know and data portability
You may ask us to disclose what we have collected and how we have used it over the past 12 months. Once we receive and verify your request (see Exercising Your Rights), we will tell you:
- The categories of personal information we collected about you
- The categories of sources of that information
- Our business or commercial purpose for collecting or selling it
- The categories of third parties we share it with
- The specific pieces of personal information we collected about you (a data portability request)
- If we sold or disclosed your personal information for a business purpose, two separate lists showing:
- Disclosures for a business purpose, with the categories of personal information each category of recipient obtained
- Sales, with the categories of personal information each category of recipient purchased
Right to deletion
You may ask us to delete personal information we have collected from you and retained, subject to certain exceptions. Once we verify your request, we will delete your information and instruct our service providers to do the same, unless an exception applies.
We may decline a deletion request where we or our service providers need to retain the information to:
- Complete the transaction it was collected for, fulfil a written warranty or product recall under federal law, provide a requested product or service, take actions reasonably anticipated in our ongoing business relationship, or otherwise perform our contract with you
- Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible
- Debug products to identify and repair errors that impair existing functionality
- Exercise free speech, protect another consumer’s right to free speech, or exercise another legal right
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.)
- Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that complies with applicable ethics and privacy laws, where deletion would make the research impossible or seriously impair it, and you previously gave informed consent
- Enable solely internal uses reasonably aligned with your expectations based on your relationship with us
- Comply with a legal obligation
- Make other internal and lawful uses compatible with the context in which you provided the information
Exercising Your Rights
To exercise your rights to know, data portability or deletion, please submit a verifiable consumer request by any of these methods:
1309 Coffeen Avenue, STE 1200
Sheridan, Wyoming 82801
Who can make a request
Only you, or a person legally authorised to act on your behalf, may make a verifiable consumer request about your personal information. You may also make a request on behalf of your minor child. You do not need an account with us to make a request.
What your request must include
- Enough information for us to reasonably verify that you are the person whose data we collected, or their authorised representative
- Enough detail for us to understand, evaluate and respond to your request
We cannot respond if we are unable to verify your identity or authority, or to confirm that the personal information relates to you. We use information provided in a request only to verify the requester’s identity or authority.
Response timing and format
We will respond electronically. If we cannot comply with a request, our response will explain why. For data portability requests, we will provide your information in a readily usable format that allows you to transfer it to another entity without hindrance.
If we decide a request warrants a fee, we will explain why and give you a cost estimate before completing it. Alternatively, we may decline the request and tell you our reasons.
Opt-Out and Opt-In Rights
You have the right to opt out of the sale of your personal information. You, or your authorised agent, can submit a request through our “Do Not Sell My Personal Information” page. You do not need an account to opt out, and we will use the information in your request only to process it.
An authorised agent acting for you must provide either:
- Your written permission to submit the request, together with information sufficient to verify the agent’s identity; or
- A power of attorney under the California Probate Code
After you opt out, we will wait at least 12 months before asking you to reauthorise the sale of your personal information. You can opt back into our subscription program at any time.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless the CCPA permits it, we will not:
- Deny you goods or services
- Charge you different prices or rates, including through discounts, other benefits or penalties
- Provide a different level or quality of goods or services
- Suggest that you may receive a different price, rate, level or quality of goods or services
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code § 1798.83) allows California residents to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please use the contact details below.
Changes to this Notice
We may update this notice at any time. When we do, we will post the updated version on this Site and revise the “Last updated” date at the top of this notice. Please review it periodically.
Your continued use of this Site after changes are posted means you accept those changes.
Contact Us
If you have questions about this notice or our privacy practices, or wish to exercise your rights under California law, please contact us:
1309 Coffeen Avenue, STE 1200
Sheridan, Wyoming 82801