Nachas Networks – Privacy Policy

Your privacy and trust are important to us. This Statement explains how Nachas Services Limited and its affiliates and subsidiaries (collectively “Nachas”, “we”, “us” or “our”) processes (e.g., collects, handles, stores, uses, shares or transfers, and protects) personal information about you as further described below. It also provides information about your rights and about how you can contact us if you have questions about how we handle your information.

Who this statement applies to and what it covers

This Statement applies to individuals who access, use, and/or interact with our products, services, websites, digital properties, platforms, software, and application(s), including mobile application (“app”) (including third-party platforms that host our websites and/or content) that hyperlink to this Statement (we call these our “Services”), attend our events or events hosted at our premises; to independent contractors or consultants whom we engage to perform and/or provide a service; and to subcontractors, vendors, suppliers, or service providers and to the personnel of the same.

This Statement covers the content that forms part of our Services.

Children’s Privacy. Our Services are not generally aimed at children. We do not intentionally collect personal information from or about individuals under the age of thirteen (13); however, in the event that we learn or discover that we have collected personal information inconsistent with this statement, we will ensure that the processing of such personal information is for a lawful and legitimate purpose and we will make reasonable efforts to delete and remove such personal information following the expiration or termination of the lawful and legitimate purpose.

Depending on the Service, we may provide additional or different privacy statements or notices for specific interactions you have with us or to highlight how we use your personal information for specific Services. Where we do this, it will be clear which statements apply to which interactions and Services. For example, if you use one of our mobile apps, we may provide you a separate notice in relation to a particular data type collected through that app.

Within our Services, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third-party websites or applications. You should check those websites or applications for their privacy statements and terms that apply to them.

This Statement does not apply when we are acting in the role or capacity of a processor or service provider (or any other similar role or capacity) of personal information on behalf of a third-party. In such case, we are processing personal information at the direction and instruction of the third-party and the third-party’s privacy statement(s) will govern and control.

Who we are

Nachas Services Limited is a limited company incorporated under the laws of England and Wales, with Companies House registration no. 12224091 and registered offices at 30 Churchill Place, London E14 5RE, United Kingdom.

Sources of personal information

We collect personal information about you (e.g., your access, use, and/or interactions with us and our Services) from certain third parties and other sources.

We obtain personal information from you:

• through your interactions with us and our Services, such as, when you purchase or use our Services, when you supply or provide services to us, sign-up to use a Service, request information or to receive marketing or other communications from us (e.g., marketing emails, alerts, newsletters, etc.), register for or attend an event, apply for or carry out a regulated role or position identified in our market rules for one of the companies listed on our markets or their relevant advisors, or call us for support (please note that we may record or monitor our telephone calls for compliance and quality assurance purposes)
• through your system/device and use of our Services. Our servers, logs and other technologies may automatically collect certain information from or about you and your systems and devices (e.g., IP address, UserID, etc.) and usage information to help us administer, protect (i.e., to detect and prevent fraud and security threats), and improve our Services, analyse usage and improve users’ experience
• through cookies and similar technologies included on our Services
• through your engagement with us as an independent contractor/consultant

We may also collect personal information about you from third parties such as:

• the party or person(s) arranging for you to access our Services (e.g., your employer, subscriber, an organization, group, or association to which you belong or are associated with) in order to set up a user account or otherwise to access and/or use our Services
• partners and service providers who work with us in relation to our Services
• companies that provide content or information to be used in our Services
• public domain sources (e.g., sources available to the public and typically over the internet (e.g., websites available to the general public), available in or through widely distributed media, and from government databases, records, and system (e.g., U.S. Securities and Exchange Commission, U.K. Companies House, sanctions lists, etc.)

To the extent that any personal information is provided to us by a third-party, other than the data subject, such third parties are also responsible for their own compliance with applicable data protection and privacy laws.

What types of personal information we collect

The types and categories of personal information we collect depends on how you are interacting with us, which Services you are purchasing or using, and on the type of Service(s).

Depending upon the Services you use or your interactions with us, on the relevant Service(s), the personal information we collect may include:

• Name and contact data, such as first and last name, email address, postal address, phone number, and other similar contact data
• Employer and Professional Level data, such as the names of your current and/or former employers, job title(s), business contact information, industry, certifications, etc.
• Educational data, such as your education history
• Account credentials, such as passwords and other security information for authentication and access
• User content, such as communications and files provided by you in relation to your use of the Services
• Payment information, such as payment card number (credit or debit card), and the security code associated with your payment instrument, if you make a payment
• Device information, such as information about your device, such as IP address, location, device identification numbers, or provider
• Usage information and browsing history, such as, information about how you navigate within our Services, your browsing history and which elements of our Services you use the most
• Location data, for Services with location-enhanced features. If we need your consent to collect geo-location data, we will collect this separately
• Demographic information, such as, your country, and preferred language
• CCTV, if you visit or work from our offices or attend our event
• Images and/or Photographs, if you visit or work from our offices or attend an event that we sponsor or organise
• Identification documentation, such as copies of passports, drivers’ licenses, other government issued identification documents, etc., if you submit a data subject rights request, attend an in-person event, etc.
• Special categories of data or sensitive personal information, such as information on health/disabilities or religion, as it relates to your use of or access to our Services or events (e.g., health/disability information relating to your access to and use of our offices or attending our events, religious information as it relates to dietary requirements for attending an event or meeting, etc.)  
• Identifiers, such as unique identification numbers, cookie identifiers, account numbers, social security numbers, national identifiers, etc.

In addition to the above personal information, which may be sourced from public sources, additional personal information may be sourced from public sources, such as personal information (1) originally available to the public and typically over the internet; (2) that Nachas has a reasonable basis to believe is lawfully made available to the general public by or from: (i) the data subject (or consumer or individual to whom the personal information relates), (ii) widely distributed media, or (iii) from a person to whom the data subject has disclosed the personal information (provided that Nachas does not have knowledge that the data subject has restricted the information to a specific audience); or (3) lawfully made available from records, databases, and/or systems of government agencies, departments, divisions or other operating units, in electronic, paper or any other format. Examples include personal information found on: (i) sanction or watch lists; (ii) law enforcement, court, regulatory, registry or other governmental websites and databases; (iii) political websites and publications such as parliamentary, local government or individual politician websites; (iv) reputable news media and publications; and (v) information sources made public by an individual themselves, for example on their website, blog or any social media application. The public source data may also include or reveal, directly or indirectly, information about age/date of birth, race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, health data, sex life, sexual orientation, criminal offense data or family circumstances (e.g. marital status, dependents, etc.).

How we use personal information

This section includes details of the purposes for which we use personal information and also the different legal grounds upon which we process that personal information. Further information is set out below.

Some laws require us to explain our lawful reason for processing your personal information. Personal information may be processed under more than one lawful reason/basis. We process personal information about you on the basis that it is:

• necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfil that contract (i.e., to provide you with Services)
• in our or a third-party’s legitimate interests: details of those legitimate interests are set out in more detail below (e.g., provision of Services that we are contractually obliged by a third-party, such as your employer or our subscriber, to deliver to you)
• substantial public interest on the basis of applicable law (e.g., to help prevent and detect unlawful acts (e.g., money laundering, terrorism, fraud and/or other criminal activity (including, without limitation, modern slavery)))
• where you give us your consent (e.g., signing up to receive marketing and promotional communications from or about Nachas, competitions administered by or on behalf of us): we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent
• for compliance with a legal obligation (e.g., to respond to a court order or a regulator; comply with statutory and regulatory requirements within the jurisdictions within which we operate (including those relating to bribery and corruption, money laundering and sanctions; sharing personal information with external organizations (e.g., police, tax authorities, or other public authorities or government enforcement agencies))

In the limited circumstances where we process sensitive personal information, we normally do so where:

• necessary in relation to employee obligations
• personal information is within the public domain
• necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity
• processing is necessary for reasons of substantial public interest, on the basis of applicable law

You are welcome to contact us for further information on the legal grounds that we rely on in relation to any specific processing of your personal information.

Legitimate interests for use

We use personal information for a number of legitimate interests. More detailed information about these legitimate interests is set out below.  

We use personal information:

• to set up and administer your account and your use of our Services (including for access credentialing purposes, provide technical and customer support and training, verify your identity and perform authentication activities, facilitate and process transactions, provide suggestions and recommendations related to our Services, service our customers’ needs (including delivering the Services) and send important account, subscription and Service information)
• to administer our relationship with you, our business and our third-party providers (e.g., to send invoices)
• to understand the patterns, preferences and interests of our customers to improve and enhance our Services
• to handle enquiries and complaints
• to contact you for participation in, and to conduct, and manage, events, webinars, seminars, meetings, and/or other related gatherings or similar activities
• to run or operate competitions, prize draws, promotions, or sweepstakes that you participate in
• to undertake screening, investigation and enforcement activity in respect of companies listed on our markets, their officers and their relevant advisors
• to deliver and suggest tailored content such as news, research, reports and business information. We analyse the way you use our Services  
• to make suggestions to you for features or Services that we believe you will also be interested in, and so that we can make our Services more user-friendly
• to personalize your experience with our Services. We may retain your browsing and usage information to make your searches within our Services more relevant and use those insights to target advertising to you online on our websites and apps. Your choices in relation to marketing are explained here. We may sometimes share your personal information across our Services so that we can make all of the Services we deliver to you more intuitive (e.g., rather than requiring you to enter the same data many times)
• to contact you in relation to, and to conduct, surveys, polls or other research activities and to analyse the data collected for market research purposes, including, without limitation, related to creating and improving our Services
• to display information you choose to post, share, upload or make available in chat rooms, messaging services, and community and event forums (including in community and event profiles) and for related collaboration, peer connection, games and information exchange
• to provide any third-party, who has made our Services available to you (e.g., your employer or our subscriber), insights about use of the Services
• for internal research and development purposes and to improve, test and enhance the features and functions of our Services
• to provide you with marketing as permitted by law
• to meet our internal and external audit requirements, including our information security obligations (and if your employer or our subscriber provides for your access to our Services, to meet their internal and external audit requirements)
• for regulatory reporting, oversight and co-operation
• to enforce our terms and conditions
• to protect our rights, privacy, safety, networks, systems and property, or those of other persons including, without limitation, verifying identity at our premises (e.g., collecting a personal identification document and related information) and monitoring our premises for safety and security (e.g., CCTV) purposes

• for the (i) onboarding of, and management of relationships with, clients/customers, vendors/service providers, business partners, professional advisors and/or any other counterparties; (ii) negotiation and finalization of, and/or participation in, any sale, merger, acquisition, restructure, 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) or any similar transaction(s); and (iii) appointment and periodic review of any individuals in ownership, shareholder, member, manager, director, officer and/or any other executive-level positions, roles, or capacities for or with companies within the Nachas group of companies and in connection with the matters covered in (i) – (iii) immediately above, to carry out any background and screening checks (including screening checks using third party service providers)  
• for the prevention, detection or investigation of a crime or other breach of law or requirement, loss prevention or fraud
• to build, update, supplement and manage content databases made available to our customers in connection with our Services;
• to comply with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence
• in order to exercise our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to us or third parties with whom we work

Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms. For more information on how this balancing exercise has been carried out, please contact the Data Protection Officer.

Marketing

We deliver marketing and event communications to you across various platforms such as email, telephone, text messaging, direct mail and online. Where required by law, we will ask you to explicitly opt in to receive marketing from us. If we send you a marketing communication, it will include instructions on how to opt out of receiving these communications in the future.

Honouring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising.

• We use tools and technologies to deliver or display targeted marketing and advertising content on or through our Services, which may involve the use of cookies and related technologies, the tracking of IP addresses and/or assigning and tracking unique identification numbers.
• We also may engage in marketing and advertising activities through chat or messenger functionality available through our Services.
• We use email tracking technology including, without limitation, dynamic links and image files, when we send you marketing communications to review your engagement and the effectiveness and relevance of the communications.
• We use tools and technologies to distinguish known and unknown users of our Services and to record, review, track and analyse engagement and use of our Services (e.g., recording or tracking hovers, clicks, key word searches, personal information entered into forms, etc.).
• We may also engage in marketing activities on third-party platforms, including, without limitation, social media platforms; however, such activities are subject to the privacy statements and terms and conditions applicable to such third-party platforms.

How to opt out of marketing  

Where we engage in direct marketing activities, including, without limitation, direct marketing via email, post, and telephone/mobile phone, we provide individuals the ability to opt-out or unsubscribe from such marketing activities. You can use the “Contact Us” feature of a particular Service, you can use the specific opt-out or unsubscribe mechanisms made available to you in connection with a specific type of marketing communication, you can discuss with your Nachas contact, or contact the Data Protection Officer. As an example, for email marketing activities, we provide several opt-out or unsubscribe options including, without limitation, via the opt-out/unsubscribe options in emails or through contacting the Data Protection Officer.

Even if you opt out of receiving marketing communications, we may still send you service communications or important transactional information related to your accounts, subscriptions and applicable products (for purposes such as providing customer support).

Interest-based advertising

Interest-based advertising (“IBA”) allows us to deliver targeted advertising to users of our Services. IBA works by showing you advertisements, or sending you marketing emails, that are based on the type of content you access or read. For example, as you browse our Services, one of the cookies placed on your device will be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests. For more information about IBA, you can visit the Internet Advertising Bureau here.  

Opting out of IBA

If you want to opt out of receiving interest-based advertising, it does not mean that you will no longer receive advertising when you are using our Services. It just means that we will not use your personal information for IBA and that any advertising you see will not be customized to you. You can exercise your online advertising choices here or by clicking the AdChoices icon in an ad and following the instructions. You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative’s (NAI) Opt Out Tool and in the EU. If you delete cookies, use a different device, or change web browsers, you may need to opt out again.

Advertising on mobile devices

Mobile devices have an identifier that gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. Another tool you can use to control advertising on your mobile device is the AppChoices App. You may also choose to turn off location tracking on your mobile device. If you turn off ad tracking or location tracking, we will no longer use information collected from your device’s advertising identifier for the purposes of advertising. You may still see the same number of ads but they may be less relevant because they will not be based on your interests. Where we need your consent to gather information about your location we will obtain this from you.

How we share personal information

We share personal information with various parties and persons including with our business partners and third-party service providers, the party or person providing your access to our Services (if that is not you), in accordance with law and as otherwise described in this Statement. Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us. In connection with the sharing of personal information, additional notice may be provided, and consent obtained, as required under applicable law.

We share your information for the purposes set out in this Statement, with the following categories of recipients:

• Nachas and its affiliates to be used as described in this Statement
• the person providing your access to our Services (e.g., your employer or our subscriber)
• business partners with whom we deliver co-branded Services; business partners with whom we engage in product or service co-selling activities; business partners with whom we provide content, or to host events, conferences and seminars
• third parties that help us deliver Services or act on our behalf (e.g., vendors, service providers, subcontractors, processors)
• our customers who are purchasing or using our Services or the service providers or vendors of our customers for the purpose of facilitating our customers’ use of our Services
• third parties where we have a duty to or are permitted to disclose your personal information by law (e.g., government agencies, law enforcement, courts and other public authorities)
• third parties in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, 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) or other similar transaction(s), in which case we may disclose your personal data to prospective buyers, sellers, advisers or partners and your data may be a transferred asset in a business sale
• third parties where reasonably required to protect our rights, users, systems and Services (e.g., legal counsel and information security professionals)
• any person you have asked us to share information with (e.g., if you upload information into a public forum it is shared publicly)

International transfers

Nachas operates internationally, with partners and service providers located in different countries, and your personal information may be stored and processed outside of your home country, including in countries that may not offer the same level of protection for your personal information as your home country. We have measures in place to ensure that when your personal information is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. Often, these include contractual safeguards.  

Nachas has networks, databases, servers, systems, support and helpdesks around the world. We collaborate with third parties like cloud hosting services, suppliers and technology support located around the world to serve the needs of our business, workforce and customers. We take appropriate steps to ensure that personal information is processed, secured and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within Nachas or to third parties in areas outside of your home country, including to countries that have not been declared adequate for the purposes of data protection by data protection regulators/supervisory authorities, including, without limitation, the UK and the European Commission.  

The areas in which these recipients are located will vary from time to time, but include the United States, Europe, Canada, Asia (including Australia and India), Sri Lanka and Malaysia, and all other countries where Nachas has a business presence.

When we transfer personal information internationally, we put in place safeguards in accordance with applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation). If you would like to know more about our data transfer practices and obtain copies of any relevant safeguarding measures, please contact the Privacy Office.

How we secure personal information

Nachas takes the security of personal information seriously and we use appropriate technologies, security controls, and procedures to protect personal information (including administrative, technical and physical safeguards) according to the risk level and the service provided.

We have in place a global cyber information security team, led by our Chief Technology Officer, who is responsible for implementing secure data handling practices at Nachas.

Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet the sensitivity of the personal information we handle, our business needs, changes in technology and regulatory requirements. While we use reasonable means to protect your security as described above, data transmission over the internet cannot always be guaranteed to be one hundred percent (100%) secure. We cannot and do not warrant the security of any personal information you transmit, and all such transmissions are done at your own risk.

How long we keep personal information

We retain your information in accordance with the applicable records retention schedules/policies. These schedules/policies may be company and/or Service specific. You can find more information on the criteria used to calculate the retention periods set out below.

Nachas implements policies and rules relating to the retention of personal information. We have a records retention process that is based upon a classification scheme consisting of business functions, record classes, and record types.

We calculate retention periods for your personal information in accordance with the following criteria:

• the length of time necessary to fulfil the purposes we collected it for
• when you or your employer (or other subscriber providing for your access to our Services) cease to use our Services

• the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations
• any limitation periods within which claims might be made
• any retention periods prescribed by law or recommended by regulators, professional bodies or associations
• the existence of any relevant proceedings

Your rights

You may have rights under UK, European and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.

We will honour your rights under applicable data protection laws. You have the following rights under UK and European laws, and may have similar rights under the laws of other countries.

• Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information
• Right to rectification: The right to have inaccurate information about you corrected or removed
• Right to erasure (‘right to be forgotten’): The right to have certain personal information about you erased
• Right to restriction of processing: The right to request that your personal information is only used for restricted purposes where:

• the accuracy of personal information is contested;
• the processing is unlawful, but you object to the erasure of the personal information; or
• we no longer require the personal information, but it is still required for the establishment, exercise, or defence of a legal claim.

• Right to opt out of marketing: The right to request that you not receive marketing communications from us, which can be for a specific type of marketing communication or for all marketing communications
• Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third-party’s legitimate interests

• Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third-party in machine-readable format
• Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent

These rights are not absolute and they do not always apply in all cases.

In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.

In order to exercise your rights please contact us via email.

Cookies and similar technologies policy

Nachas sets and uses first-party and third-party cookies and similar or related technologies (collectively referred to as “cookies”) to allow for the proper functioning of our Services, store and manage user preferences, deliver targeted advertising, engage in marketing activities, enable personalized content, and gather, analyse and report on analytic and usage data. The use of cookies may occur across websites and apps through which information is collected about your online activities across applications, websites, or other services. More information about how we use cookies and similar technologies and how you can control and manage them is set forth below.

Through the use of cookies, we and our third-party providers may process (e.g., store or retrieve) information on or from your browser, including identifiers (e.g., cookie IDs and other unique identification numbers), which may be used:

1. to enable your use of our Services and the proper functioning of our Services;

2. to record, track and reviewing your activity, interactions and communications with, about, or on Nachas and Services for the purposes of:

1. analysing and reporting on website and content usage, marketing campaigns, and interest in our Services;  

2. creating, personalizing and delivering marketing and advertising content;  

3. connecting data from different databases, systems, and/or websites for various purposes including, without limitation, creating, personalizing and delivering content (including marketing content) and analysing and reporting on the use of our Services; and  

4. creating look-a-like models and segments for the purpose of engaging in marketing, advertising, and promotional activities on or through our Services and/or third party platforms and services (e.g., social media sites, etc.) that are directed to, or targeting individuals or data subjects who fall within such look-a-like models or segments.

More information about how we use cookies and how you can control and manage them is below and in the applicable cookie preference centre for a website or domain.

Certain websites or domains are part of the same or similar domain structure and deploy and use the same cookies, and cookie preferences set on or for one website or domain within the group applies to all websites or domains within the group. For the list of websites or domains that are covered under the same user cookie preference settings please click here. After the cookie preferences are set for one website or domain within the group, the user will not see another banner addressing, and/or will not be required to consent to (where applicable), the deployment of cookies on or for the other websites or domains within the group unless the user clears the applicable cookie cache. Clearing the applicable cookie cache will delete or remove the cookie containing the user’s preferences.

What is a cookie?

A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of five categories, depending on their function and intended purpose: strictly necessary cookies, performance cookies, functional cookies, targeting cookies and social media cookies. Some cookies may fulfil more than one purpose.

Types of cookies and why we use them

Strictly necessary cookies: These cookies are necessary for websites to function and cannot be switched off through the applicable cookie preference centre. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

• Performance cookies: These cookies collect information, including analytics, about how you use our Services. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, actions taken, and pages viewed. These cookies may be used to record or track your interaction and/or use of our web and/or mobile sites, platforms and/or digital properties. Performance cookies help us measure the activity on our Services, create reports and statistics about the performance of our Services, improve the user-friendliness of the Services and improve the quality of our Services. These types of cookies typically stay active on your computer until they are deleted or until the cookies expire (as applicable).
• Functional cookies: These cookies allow the website to remember information about you (e.g., your username or ID,) and the choices you make (e.g., your language preference, or the area or region you are in) and provide enhanced, more personalized features or content to you. These cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide Services you have asked for, such as watching a video or commenting on a blog. If you do not allow these cookies or if you toggle these cookies off, then some or all of these Services may not function properly. These cookies cannot track your browsing activity on other websites.
• Targeting cookies: These cookies track browsing habits (on and off of our websites and digital properties) and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information may be shared with other organizations, such as advertisers and Nachas’ advertising partners, who might use it with information about how you use other websites, including identifying shared interests and behaviours across groups of users who visit our (and other) websites. In connection with this type of cookies, your activities may be tracked or reviewed using identifiers (e.g., a cookie ID). These types of cookies will typically stay on your computer until they are deleted or until they expire (if applicable).

Social media cookies

These cookies are set by third-party social media services that we have added to the site to enable you to share our content with your friends and networks and to log-in to, and share information with, Nachas’ Services.

Some of our Services may include social networking features, such as the Facebook® “Like” button and widgets, “Share” buttons, and interactive mini-programs. Additionally, you may choose to use your own social networking logins from, for example, Facebook or LinkedIn®, to log into some of our Services. If you choose to connect to our Services using a social networking or similar service, we may receive and store authentication information from that social media service to enable you to log in and other information that you may choose to share when you connect with these Services. These Services may collect information such as the web pages you visited and IP addresses for various purposes and may set cookies to enable features to function properly.  

Nachas is not responsible for the security and privacy practices of the third parties who set or deploy cookies in connection with social media services. You should review the applicable third-party privacy statements carefully to understand their collection and processing of personal information. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on or in connection with the Services.

Certain cookies deployed by social media services may be listed under the Targeting Cookies category in the preference centre available through the Cookie Settings. All references to “Cookie Setting” means that cookie preference centre for each applicable website or domain, which is available on or through each applicable website or domain. If there is no “Cookie Settings” functionality for a website and you wish to opt-out of, or remove, Cookies please clear or delete cookies through your browser settings.

Managing cookies

You can manage cookies through your browser settings, and our preference centre available through the Cookie Settings. The preference centre available through the Cookie Settings on our Services allow you to enable or disable cookies that are not strictly necessary. If you disable or do not accept certain cookies, you may find that certain functions and features will not work as intended on the Services. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser. Please note that changing your cookie preferences in or for one browser does not change your cookie preferences for all browsers. Please note that a preference cookie will be set in connection with our cookie banner and preference centre to record and honour your preferences. Please note that if you delete or clear your cookies, you will delete the preference cookie and clear your recorded preferences.

We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org  or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:

• Mozilla Firefox®
• Microsoft® Internet Explorer
• Google Chrome™
• Safari®

• Microsoft® Edge

Subject to compliance with the applicable notice and consent requirements, we may use certain other similar or related technologies in addition to traditional cookies:

Local shared objects/Flash cookies: Flash cookies, also known as local shared objects, are designed to support browser content supported by Adobe® Flash. They are usually used to enable ads and video content on websites. Like other cookies, they will store information on your device, some of which will be specific to the Flash-enabled content. Flash cookies can only be deleted within Adobe Flash rather than via your browser. Please refer to the following help page for information on how to manage your privacy settings and about the deletion of Flash cookies.

HTML Web Storage: With web storage, web applications can store data locally within a user’s browser. We utilize two types of web storage; Session Storage Object (“SSO”) and Local Storage Object (“LSO”). SSO stores data only until the browser session ends and then all data is removed/deleted. LSO stores data without an expiration date. Web storage can be used for various purposes, including displaying the last page viewed by a user when the user logs back into a website, keeping a session active (i.e., keeping a user logged-in), and providing more website accessibility features to a user. The web storage is categorized in the same manner as traditional cookies and you can toggle on or off the categories of cookies under which web storage data is categorized.

Web beacons: Our web pages may contain electronic images known as web beacons (also called single-pixel gifs and transparent graphic images) that we use to help deliver cookies on our sites, count users who have visited those sites, record or track your interactions with Nachas’ web and mobile sites, platforms, and/or properties, deliver Services, and analyse the effectiveness of our promotional campaigns, for example. We may also include web beacons in our marketing email messages or newsletters to determine whether an email is opened or if links are clicked. Web beacons are also used to deliver you interest-based advertising.

Web server & application logs: Our servers automatically collect certain information to help us administer and protect the security of the Services, analyse usage, and improve the quality, performance, and personalization of the Services. The information collected includes:

• IP address and browser type
• Device information including Unique Device Identifier, MAC address, Identifier For Advertisers, and similar identifiers we or others may assign
• Device operating system and other technical facts
• The city, state, and country from which you access our website
• Pages visited and content viewed, stored, and purchased
• Information or text entered
• Links and buttons clicked
• URLs visited before and after you use our Services

Certain of these tracking technologies may be listed under the Performance, Functional or Targeting Cookies categories in the Cookie Settings. If you do not wish these technologies to be deployed on the Services, you should adjust your Cookie Settings accordingly.

"Do not track" signals

Some browsers transmit Do Not Track (“DNT”) signals to websites. Some of the cookies deployed, set, or utilized by or on behalf Nachas’ may respond to DNT requests or signals from these browsers. Please note that if we respond to DNT requests, this may alter our services and therefore may limit functionality and use of our websites. We continue to monitor industry activity in this area and reassess our DNT practices as necessary.

Duration

Certain of the cookies used on or in connection with our Services expire after a period of time. Please refer to the “Cookie Details” section of our Cookie Settings for information regarding the duration of each cookie.

Third-party Cookies

The cookies described in this Policy include third-party cookies which may enable third parties to access to the information collected. The identity of these third parties is included in the “Cookie Details” section of our Cookie Settings.

Where to find further privacy information on Nachas’ Services

Data Content Products

In connection with our Services, Nachas builds, supplements and manages various content databases, which include personal information of or about certain data subjects (e.g., officers and directors; ownership and shareholders; investment professionals; research analysts). The information contained in these databases are collected from various sources, including, without limitation, from public sources (e.g., corporate websites), approved financial publications, from data subjects, from government records or databases (e.g., U.S. Securities and Exchange Commission, Companies House in the U.K.), and from third parties (e.g., business partners, colleagues of the data subject). We build and manage these content databases to provide a directory service to users of the content and the users of the content are solely responsible for ensuring that they process the content in accordance with applicable data protection, privacy and marketing laws.

The personal information available in the content databases may be used for several purposes including, without limitation, conducting research and performing due diligence activities, engaging in contact mapping, verifying existing contact information, and facilitating discussions or communications regarding business opportunities.

The sources from which the personal information may be received or collected are responsible for their own compliance with applicable data protection/privacy laws and for ensuring the accuracy and completeness of the personal information maintained by such third parties or persons.

If you have any enquiries or wish to exercise your rights under data protection and privacy laws or would like to make further inquiries about how personal information is used within a specific Service, please contact us.

How to contact us

If you have any questions, comments, complaints or suggestions in relation to data protection or this Statement, or any other concerns about the way in which we process information about you, please contact us as follows:

Nachas Services Limited
30 Churchill Place
Canary Wharf
London E14 5RE
England
United Kingdom

Attn: The Data Protection Officer

Filing a Complaint. If you are not content with how Nachas manages your personal information, you can lodge a complaint with a privacy supervisory authority. In the European Economic Area, the relevant supervisory authority is the one in the country or territory where:

• you are resident
• you work,  
• or the alleged infringement took place

A list of National Data Protection Authorities in the European Economic Area can be found here. For the Information Commissioner’s Office in the United Kingdom, please visit https://ico.org.uk/.

‍

Updates to this statement

This Statement may be subject to updates. Any material future changes or additions to the processing of personal information as described in this Statement affecting you will be communicated to you through an appropriate channel. For example, we may place a prominent notice on a product site or email you to let you know of an updated Statement.