Website Privacy Policy

Introduction
This privacy policy applies to Twenty-4 Seven Global Media Limited and our subsidiaries (collectively, “Twenty-4 Seven Global Media Limited” and as the context may require, “our,” “us” or “we”). At Twenty-4 Seven Global Media Limited, we respect your privacy and seek to provide you with a powerful and secure online experience. This policy describes the type of information we gather from you from 247webcasting.com and how we may use or disclose that information. This policy should be read in conjunction with the Twenty-4 Seven Global Media Limited Terms of Use located on 247webcasting.com, which are incorporated herein by reference.

Types of Information Collected
We collect information directly from you and automatically about you as you use our website. The type of information that we collect about you varies based on your interaction with our website.

Information We Collect Directly From You. In connection with your use of our website, we ask for and may collect a variety of information from and about you in different ways. For example, when you request that we contact you, we may ask for and store your and/or your business’s name, address, email address, and other identifying contact data.

Information We Collect Automatically. We, and our service providers, collect information about you automatically through cookies, web beacons, and other tracking technologies as you use our website. Please see “Cookies and Other Tracking Technologies” below for additional information.

How We Use Your Information
We use your information, including your personal information, primarily to market and provide our services to you. In particular, we may use your information as follows:

To provide our website and services to you.

For the purpose for which you provided the information to us, such as to respond to your inquiries and to provide information in response to your request.

For marketing and promotional purposes, for example, where permitted by law, we may use your information, such as your email address, phone number, or mailing address to contact you about services or information we think may interest you.

To tailor the content and information that we may send or display to you, to offer location customization (where permitted by applicable law), and to otherwise personalize your experiences while using our website.

As permitted by applicable law, to assist us in advertising our services in various mediums including, without limitation, sending you promotional emails, advertising our services on third party sites and social media platforms, direct mail, and by telemarketing.

To better understand how users access and use our services, both on an aggregated and individualized basis, to administer, monitor, and improve our services, for our internal purposes, and for other research and analytical purposes.

To protect our customers, employees or property — for instance, to investigate fraud, harassment or other types of unlawful activities, to enforce this policy and our Terms of Use.

When We Disclose Your Information

Affiliates. We may disclose the information we collect from you to our affiliates (companies related by common ownership or control), which may use your information for various purposes, including, to market their services to you.

Service Providers. We may disclose the information we collect from you to third party service providers who perform functions on our behalf. Third party service providers will only process your personal data in accordance with our instructions and will implement adequate security measures to protect your personal data.

In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, judicial proceedings, a court order, or other legal process, such as in response to a court order or a subpoena.

To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this policy, or as evidence in litigation in which we are involved.

Business Transfers. If we are acquired by or merge with another company, or if substantially all of our assets are transferred to another company, we may transfer the information we have collected from you to the other company.

Security of Your Personal Information
Twenty-4 Seven Global Media Limited has implemented processes in an attempt to protect your personal information from misuse. Your information may be stored and processed in the United States or any other country where Twenty-4 Seven Global Media Limited, its subsidiaries, or its third party service providers are located.

Control of Your Password(s)
You are responsible for all actions taken with your User ID and password, if any. Therefore, we recommend that you do not disclose your password to anyone. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf.

Protection of Children’s Personal Information
Twenty-4 Seven Global Media Limited does not publish content that is targeted at children.

Cookies and Other Tracking Technologies
We and our third party service providers use “cookies” and other tracking technologies on our website. A “cookie” is a small text file that may be used, for example, to collect information about website activity. Some cookies and other technologies may serve to recall personal information previously indicated by a web user. Currently, our website does not automatically recognize browser requests not to be tracked. Most browsers, however, allow you to control cookies, including whether or not to accept them, and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our website is accessed. Our use of cookies and other tracking technologies allows us to improve our website and your web experience. We, and our third party service providers, may also analyze information for trends and statistics.

Choice
You may choose whether or not to provide personal information to Twenty-4 Seven Global Media Limited. This policy should help you to make that choice. If you choose not to provide the personal information we request, you can still visit Twenty-4 Seven Global Media Limited’s website, but you may be unable to access certain options, offers, and services that involve our interaction with you. If you chose to have a relationship with Twenty-4 Seven Global Media Limited, such as a contractual or other business relationship or partnership, we will naturally continue to contact you in connection with that business relationship.

Security
Wherever your personal information may be held within Twenty-4 Seven Global Media Limited or on its behalf, we take reasonable steps to protect the personal information that you share with us from unauthorized access or disclosure, including, without limitation, restricting access to certain portions of our website through access controls, and using firewalls. Regardless of the precautions taken by us, Twenty-4 Seven Global Media Limited cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk.

Access
To the extent that you do provide us with personal information, Twenty-4 Seven Global Media Limited wishes to maintain accurate personal information. Where we collect personal information from you on the web, our goal is to provide a means of contacting Twenty-4 Seven Global Media Limited should you need to update or correct that information. If for any reason those means are unavailable or inaccessible, you may send updates and corrections about your personal information to privacy@247webcasting.com and we will make reasonable efforts to incorporate the changes in your personal information that we hold as soon as practicable.

Consent and Changes to the Privacy Policy
Twenty-4 Seven Global Media Limited reserves the right to change this policy at any time without prior notice. Revisions will be posted on our website. This statement of privacy is for the information of our users and does not constitute a contract or modification of any contract. Your use of this website implies your consent to the collection of the information described in this policy. When changes are made to this policy, Twenty-4 Seven Global Media Limited will post these changes to this page of the website so that you will be aware of the information we collect and how we use it.

Disputes
Any disputes relating to the subject matter of this policy shall be handled by the means set forth in the Twenty-4 Seven Global Media Limited Terms of Use.

Contact Information
Twenty-4 Seven Global Media Limited welcomes your comments regarding this privacy policy. Please feel free to email us at privacy@247webcasting.com or via postal mail at Twenty-4 Seven Global Media Limited, Attn: Privacy, Unit 4 Wilderbrook Way, Mullacott Cross Industrial Estate, Ilfracombe, Devon, EX34 8FN. If you would like to unsubscribe from Twenty-4 Seven Global Media Limited email subscriptions or otherwise change your email preferences with Twenty-4 Seven Global Media Limited, please click here.

GDPR

EU General Data Protection Regulation (GDPR), which was approved to replace the previous EU Data Protection Directive, and will take effect on May 25, 2018, and Twenty-4 Seven Global Media Limited (“247 Webcasting”) welcomes GDPR as an important step forward in streamlining data protection requirements across the EU, and as an opportunity for our companies to deepen our commitment to data protection.

Compliance with GDPR requires a partnership between 247 Webcasting and our customers in their use of our services. We are dedicated to helping our customers comply with GDPR. We have made enhancements to our products, systems, procedures and documentation to help support our customers’ compliance with GDPR.

247 Webcasting has created the 247 Webcasting Data Processing Addendum to meet that requirement. It has been tailored to address the unique aspects of 247 Webcasting’s platform and services and reflects our data security procedures and data processing activities.

Cookie declaration last updated on 28/05/2018 by Cookiebot:

Necessary (6)

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Name Provider Purpose Expiry Type
__cfduid [x4] bleeper.io
hs-analytics.net
hs-scripts.com
hubspot.com
Used by the content network, Cloudflare, to identify trusted web traffic. 1 year HTTP Cookie
CookieConsent 247webcasting.com Stores the user’s cookie consent state for the current domain 1 year HTTP Cookie
PHPSESSID 247webcasting.com Preserves user session state across page requests. Session HTTP Cookie

Preferences (2)

Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

Name Provider Purpose Expiry Type
_icl_current_language 247webcasting.com Saves the user’s preferred language on the website. Session HTTP Cookie
wplc_chat_status 247webcasting.com Unclassified Session HTTP Cookie

Statistics (5)

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Name Provider Purpose Expiry Type
_ga 247webcasting.com Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 2 years HTTP Cookie
_gat 247webcasting.com Used by Google Analytics to throttle request rate Session HTTP Cookie
_gid 247webcasting.com Registers a unique ID that is used to generate statistical data on how the visitor uses the website. Session HTTP Cookie
bleeper_current 247webcasting.com Unclassified Persistent HTML Local Storage
bleeper_first 247webcasting.com Unclassified Persistent HTML Local Storage

Marketing (9)

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Name Provider Purpose Expiry Type
__hssc 247webcasting.com Collects anonymous statistical data related to the user’s website visits, such as the number of visits, average time spent on the website and what pages have been loaded. The purpose is to segment the website’s users according to factors such as demographics and geographical location, in order to enable media and marketing agencies to structure and understand their target groups to enable customised online advertising. Session HTTP Cookie
__hssrc 247webcasting.com Collects anonymous statistical data related to the user’s website visits, such as the number of visits, average time spent on the website and what pages have been loaded. The purpose is to segment the website’s users according to factors such as demographics and geographical location, in order to enable media and marketing agencies to structure and understand their target groups to enable customised online advertising. Session HTTP Cookie
__hstc 247webcasting.com Collects anonymous statistical data related to the user’s website visits, such as the number of visits, average time spent on the website and what pages have been loaded. The purpose is to segment the website’s users according to factors such as demographics and geographical location, in order to enable media and marketing agencies to structure and understand their target groups to enable customised online advertising. 2 years HTTP Cookie
__ptq.gif hubspot.com Sends data to the marketing platform Hubspot about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels. Session Pixel Tracker
ads/ga-audiences google.com Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites. Session Pixel Tracker
hubspotutk 247webcasting.com Keeps track of a visitor’s identity. This cookie is passed to the marketing platform HubSpot on form submission and used when de-duplicating contacts. 10 years HTTP Cookie
PREF youtube.com Registers a unique ID that is used by Google to keep statistics of how the visitor uses YouTube videos across different websites. 8 months HTTP Cookie
VISITOR_INFO1_LIVE youtube.com Tries to estimate the users’ bandwidth on pages with integrated YouTube videos. 179 days HTTP Cookie
YSC youtube.com Registers a unique ID to keep statistics of what videos from YouTube the user has seen. Session HTTP Cookie

Platform Privacy Policy

Channel Partner/Reseller/Data Sub-Processor:
TWENTY-4 SEVEN GLOBAL MEDIA LIMITED hereby referred to as 247 Webcasting1-5 Market Square, Ilfracombe, Devon, UK, EX34 9AU

Contact: Martyn Cox
Title: Director
Telephone: +44 (0) 207 1939 758

Date of Last Revision: September 2, 2020

ON24, Inc. and its subsidiaries (collectively, “ON24,” “we” or “us”) understand the importance of privacy. This Platform Privacy Policy (this “Policy”) explains how ON24 collects, stores, uses and shares personal information collected, stored or processed by us through ON24’s Virtual Communication Platform, which includes services related to our Webinars, Virtual Environments, Channels, and Portals (collectively, the “Platform”). In this Policy, “personal information” is information that identifies or could be used to identify an individual.

The ON24 Platform is a tool used by businesses (including direct customers of ON24 and customers who access the Platform through an ON24 Reseller such as 247 Webcasting) and their employees, agents and authorised users (the “Business Customers”) to deliver webinars and other content to registrants, attendees, participants, and other end users (the “End Users”). Collectively, End Users and Business Customers are “Platform Users”.

1. Scope

This Policy applies to the personal information that ON24’s Business Customers submit to us via the Platform, as well as the personal information we collect, access, store, use or otherwise process (collectively, “process”) via the Platform on behalf of Business Customers, including the Registrant Information, Other Information and User Communications (each defined below), as well as other personal information we process from End Users of the Platform (together the “Platform Data”).

Controller and Responsible Entity

With respect to the Platform Data, ON24 is a “data processor” or “service provider” under applicable data protections
laws. Channel Partners (such as 247 Webcasting) act as a “data sub-processor”, and as such do not store any sensitive data or client information. As a data processor, service provider, or data sub-processor, we will only process the Platform Data pursuant to our client’s instructions, as set forth in our applicable client agreements, and as otherwise required by applicable privacy and data protection laws. This Policy does not apply to processing of Platform Data or any other personal information collected via the Platform by clients, which is subject to their own policies and practices.

With respect to the Platform Data we process, that is subject to EU and Swiss data protection laws, ON24, Inc. has certified its adherence to and will comply with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, which can be found
at www.privacyshield.gov/ (collectively, “Privacy Shield Principles”). You can review the Privacy Shield Principles, learn more about Privacy Shield, and view our Privacy Shield certification at www.privacyshield.gov/. ON24’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission. Please note: On July 16, 2020, the European Court of Justice invalidated the EU-US Privacy Shield Program as an adequacy mechanism for transfers of personal data to the United States. ON24 will continue to comply with its Privacy Shield commitments for so long as it remains an active participant in the program. In addition, we will work with clients to implement additional adequacy measures where necessary under applicable data protection laws in the European Economic Area (EEA) and the United Kingdom (UK), such as the EU standard contractual clauses for the transfer of personal data to processors established in third countries. You can view the 247 Webcasting DPA for GDPR compliance statements here.

For more information about how ON24 processes personal information as a controller, please see the ON24 Online Privacy Policy.

2. Data Collected Information Collected Directly

Account Information. To access various parts of the Platform, and to create webinars and events, you must have an online account or have an agreement in place with an ON24 Channel Partner such as 247 Webcasting. To register for an account on
the Platform, or be provided with access via a Channel Partner, you must provide your name, email address, telephone number, company name, and other information necessary to confirm that you are an authorised user of a Business Customer (where relevant). We may also collect additional information such job title, information about your company (such as country and industry sector) and other user profile information such as age, gender, zip/post code, and areas of special interest to you. Our processing of account information is subject to the ON24 Online Privacy Policy.

End User Information. To access webinars, virtual environments and other events administered by Business Customers via the Platform as an End User, you may be required to register. While our Business Customers determine what information to collect from End Users, the requested personal information typically includes name, email address, telephone number, company name and job title as well as information about your company such as country and industry sector.

User Communications. When you send email or other communication to ON24, a Channel Partner Reseller such as 247 Webcasting, or another user, we may retain those communications in order to process your enquiries, respond to your requests and to improve our services.

Affiliated Sites. We may offer services in connection with other websites or suppliers. Personal information that you provide to those sites may be sent to us in order to deliver these services. We process such information in accordance with this Policy.

Other Information. ON24’s Business Customers (both direct and in-direct via a Reseller) may request additional information, like surveys or polls, be filled out in some webinars or virtual environments. Business Customers (or the instructed Reseller) are responsible for configuring the Platform to collect such personal information.

Information Collected Automatically

Log Information. When you use ON24, our servers record, in a server log, information that your browser sends whenever you visit a website. Server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Cookies, clear GIFs, etc. The Platform may use cookies (small pieces of information that are stored by your browser on your computer’s hard drive), clear GIFs, java script and other technology to collect and store information about your use of the Platform, such as your search activity, the pages you view, and the date and time of your visit, your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location information, and requested and referring URLs. We may combine this information with other information that we have collected about you, including, where applicable, your username, name, and other personal information. Please see our Cookie Policy for more information.

Aggregate and De-Identified Information

ON24 may process (i.e., collect, use and disclose) aggregate de-identified information, and other information that is not personally identifiable, for research, analytics and other purposes, provided such information does not identify, and could not reasonably be used to identify a particular Business Customer or End User.

3. Ownership; Client Information

A) “Intellectual Property” means patents, copyrights, trademarks, service marks, trade names, trade dress, domain names, know- how, technology, inventions, methods and processes, trade secrets, and all other intellectual property and proprietary rights, and all developments, enhancements, derivatives, improvements, modifications or extensions thereof, anywhere in the world.

B) As between ON24 and Client, or between Reseller and Client, ON24 retains all right, title and interest in and to the Platform, the Services, all other Intellectual Property owned, acquired or developed by ON24, and any improvement or modification

thereto. ON24’s licensors and suppliers own all right, title and interest to Third Party Applications that ON24 may make available as part of or in connection with the Platform or Services.

C) If Client or any Attendee provides any suggestions, ideas, feedback, improvements, or recommendations to ON24 relating to the Platform or other ON24 proprietary rights (collectively, “Submissions”) Client hereby grants ON24 a nonexclusive, perpetual, sublicensable license to exercise all Intellectual Property rights in such Submissions.

D) As between ON24 and Client, or between Reseller and Client, Client retains all right, title and interest in and to all materials and data it enters into the Platform or otherwise provides to ON24 under an Agreement or via a Channel Partner Reseller such as 247 Webcasting, including slides, audio files, video files, branding elements, recordings generated from a Webinar, and photographs (“Client Materials”), any contact information or other personally identifiable information of Attendees of Client’s Webinars and Virtual Environments (“Attendee Data”) and all other Intellectual Property of Client (together with the Client Materials and
Attendee Data, the “Client Information”).

E) Client hereby grants ON24 or the Reseller the right to use Client Information to the extent needed by ON24 or the Reseller to provide the Services to Client. Client acknowledges that ON24 does not exercise any control over the content of Client Information. Client shall bear the sole responsibility to ensure that all Client Information, and Client’s use and collection thereof, complies with all applicable laws and regulations. ON24 or the Reseller has no obligation, and expressly disclaims any obligation to review Client Information for accuracy or for any other reason.

F) Client agrees that ON24 may de-identify or aggregate Client Information and other data related to the Services to render it Anonymous Data, which may then be used for the purposes of operating and improving ON24’s services and operations, and other research, analytics, marketing and related purposes. ON24 may maintain Anonymous Data as part of its own records and information and such data shall no longer be subject to these Terms or an Agreement. “Anonymous Data” means data that has been de-identified and/or aggregated with other data to such an extent that Client and Attendees are no longer identifiable, and individuals are no longer identified, identifiable, linked or linkable, or otherwise ascertainable by reference to or combination with other datasets.

G) ON24 has implemented commercially reasonable safeguards to protect the Platform and the Client Information (defined above) that ON24 processes via the Platform. The parties acknowledge, however, that the security of transmissions over the internet cannot be guaranteed. ON24 or any authorised Reseller shall not be responsible for Client’s access to the internet, for any interception or interruption of any communications through the internet, or for changes to or losses of data through the internet.

H) Client may access and download Client Information related to a Webinar that is stored in the Platform by accessing their account during the period in which such Webinar is made available on an on-demand basis as listed in the applicable Agreement (“On-Demand Access Period”). Client acknowledges that ON24 may maintain in its backup archive unaltered copies of Client’s Webinars, but shall have (i) no obligation to store any Client Information beyond the On-Demand Access Period, and (ii) no liability for the deletion or destruction of Client Information thereafter.

4. Use of Information

ON24 uses the personal information we collect via the Platform to provide our services to Business Customers, including to operate and improve the Platform and our services, to provision Platform Users’ accounts, to carry out the transactions Platform Users request via the Platform, and to respond to Platform User requests.

As noted above, ON24 is a data processor of the personal information collected via the Platform. Business Customers are data controllers with respect to Platform User personal information; this Policy does not apply to the processing (including collection, use and sharing) of Platform User personal information by Business Customers.

Business Customers may use the personal information they collect via the Platform for additional purposes, such as to deliver targeted content within the Platform, to contact End Users about their use of the Platform, for marketing and promotional purposes, and for other purpose; you should review their privacy policies for more information about how they collect, use and share the personal information collected via the Platform.

5. Sharing of Information; Onward Transfers

As noted, Platform User information, including End User personal information, is shared with the Business Customer upon whose behalf the information was collected or Platform is being operated; this Policy does not apply to the processing (including collection, use and sharing) of Platform User personal information by Business Customers, and we are not responsible for such processing.

ON24 will not share personal information about Platform Users with third parties except to provide the products or services you have requested, with consent, or under the following circumstances:

  • We will make personal information available to the Business Customer on whose behalf the personal information has been collected, as explained above.
  • We may provide personal information to our agents, service providers, contractors and others acting on our behalf. These parties do not have any independent right to use or share this information.
  • We may disclose the information we collect from you to ON24 affiliates and subsidiaries; however, if we do so, their use and disclosure of your information will be subject to this Policy.

Third parties who process personal information on our behalf must agree to use such personal information only for the purpose for which it is provided by us and they must contractually agree to provide adequate protections for personal information; ON24 will continue to be liable for any onward transfers of personal information to such third parties.

We may also disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, as well as where is necessary to satisfy any applicable law, regulation, legal process or enforceable government request, to enforce our User Agreement and investigate violations thereof, to prevent, detect and address fraud, security or technical issues, or to protect against harm to the rights and property of ON24. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company (including as due diligence and for other purposes prior to the closing of such a transaction), or as part of a bankruptcy proceeding, we may transfer the information we have collected (including personal information) to the acquiring company.

6. Accessing, Amending and Limiting Use of Your Personal Information

Individuals have the right to access the personal information that is maintained about them, and in some cases to limit use and disclosure of such information. Registered Platform Users may log into their accounts to view and amend certain personal information in their profile. EU and Swiss End Users who would like to request access to, to limit use of, or to limit disclosure of their personal information collected via the Platform by a Business Customer should contact that Business Customer directly; EU and Swiss End Users may also make such requests by contacting us via privacy@247webcasting.com and providing the name of the Business Customer. We will refer such requests to that Business Customer and will support them as needed in responding to your request.

7. Security

To secure your personal information access to your data is password protected, and sensitive information is protected by encryption when it is exchanged between your Web browser and our Web site. It is your responsibility to keep your password confidential and not to share this information with anyone. While we will implement the security measures detailed above, transmission of information via the internet is not completely secure and therefore transmission via the internet is at your own risk.

8. Complaints and Disputes

Individual Platform Users who have any questions, complaints, or disputes regarding this Policy or the manner in which ON24 handles or protects personal information may contact us at legal@247webcasting.com. We will promptly investigate and attempt to resolve any complaints and disputes and will respond within 45 days of receiving any such complaint.

For EU and Swiss Platform Users whose complaint cannot be resolved through this process, ON24 agrees to participate in a dispute resolution process administered by JAMS. For information about how to initiate a Privacy Shield claim with JAMS,
go here. If neither ON24 nor JAMS resolves your complaint, you may be able to engage in binding arbitration through a Privacy Shield arbitration panel (for more information, go here).

9. Changes

ON24 may update this Policy from time-to-time. In the event we make material changes in the way we treat user personal information; we will notify you by email.

10. Contact Us

Please email us at privacy@247webcasting.com with any questions about this Policy.