Updated: June 5, 2024

These updates provide details concerning our webinars and other interactive content, third-party events, prize drawings, and skill assessments. Click here to see the previous version of our privacy policy.

Privacy Policy Effective Date

This privacy policy (the “Policy”) is effective as of June 5, 2024. We may amend this Policy from time to time, and changes will be posted on this web page with the effective date noted here.

We encourage you to review this Policy periodically. If we make significant changes to this Policy, we will place a prominent notice on this page for a reasonable period of time afterwards, so that it will be easier for you to see that changes have been made.

Summary

This Policy applies to the Personal Information that Episode Six, Inc., or its subsidiaries and affiliates (collectively, “E6”) collect when:

• You use our public website at episodesix.com or our customer documentation web portal (collectively, the “Websites”)
• You access webinars, e-books, or other interactive content produced by E6
• You provide your name and/or contact details to E6 by other means for marketing purposes
• We obtain your name and/or contact details from third parties for marketing purposes
• You communicate with us for business purposes in your role as a member of staff for one of our corporate customers or vendors
• You apply for a job at E6
• We obtain publicly available information about you in connection with a job you are a candidate for or in connection with the business relationship between our companies.

“Personal Information” is any information we collect about you that could reasonably be used to identify you, either directly or indirectly, as well as any other information we collect or process about you that can reasonably be connected with your identity.

This Policy explains how we collect, process, and store your Personal Information. This Policy also describes your options and rights with respect to your Personal Information, as well as how to exercise those rights. Before engaging with us, submitting information to us, or buying or using our services, please review this Policy carefully. You may print this Policy or download a PDF version.

Unless otherwise noted in this document, we act as the controller of Personal Information that we collect and process within the scope of this Policy.

Please note that, where our Websites or emails contain links to third-party websites, their privacy policies will govern any Personal Information collected by those third parties when you follow the links to their websites, except insofar as they are collecting your Personal Information on our behalf (for example, when you are applying for a job or submitting a request regarding exercise of your rights).

This Policy applies to:

• Visitors to our Websites
• Individuals who attend or access E6 webinars, e-books, and other interactive content
• Individuals who have requested additional information about E6 products and services
• Our contact list for E6 news and updates (“newsletter”) and other marketing communications
• Individuals who communicate with us for other business purposes, typically in their roles as members of staff for our customers or vendors
• Job candidates who have not yet received a conditional job offer, where other confidentiality agreements or data protection notices are not in effect.

Where other confidentiality agreements or data protection notices govern the use and handling of Personal Information provided to us by our customers, by our staff (including job candidates who have received a conditional offer of employment), and by our vendors, this Policy does not apply and the terms of these other agreements or notices shall prevail. Please note that, if you receive and choose to accept a conditional offer of employment from us, our internal policies on confidential information will govern our handling of your Personal Information from that point forward.

Personal information you provide to us

When you request information or content from us

When you sign up for our newsletter, register for one of our webinars, download one of our e-books or other online content, or submit a request for information about our company or our products and services via our Website, you submit contact details relevant to your request. Likewise, you may provide your contact details to a member of E6 staff in order to receive additional information about our company or our products and services.

These types of Personal Information may include your name, email address, company name, job title, and phone number. If you request a physical copy of E6 marketing materials, we may ask for your business mailing address.

If you communicate with us in order to exercise your rights regarding your Personal Information, we will collect the contents of your request and any subsequent related correspondence, including metadata from electronic communications (e.g., IP addresses, originating phone numbers or servers, time stamps, etc.).

When you enter a prize drawing

From time to time, we may hold prize drawings in order to promote E6 at industry events; individuals who wish to enter provide their contact details, and we select a prize winner at random from among the entrants. If you choose to enter the prize drawing, you typically provide your name, contact details, and information about your job such as job title and company name.

When you communicate with us for other business purposes

If you communicate with us for other business purposes, including as part of your work at a current or prospective E6 customer or vendor, Personal Information we collect may include your name, business contact details you provide, the name of the company you work for, and your job title. Contact details may include but are not limited to your email address, phone number, fax number, business mailing address, and office location. We also collect the contents of any emails and electronic messages, webinar feedback, faxes, voicemails, or postal correspondence you send to us, including metadata from electronic communications (e.g., IP addresses, originating phone numbers or servers, time stamps, etc.).

When you apply for a job with us

If you send us your résumé or CV, and/or complete a job application by following one of the links on our Careers webpage, we will have the information you submit to us, which may include your name, your contact details (e.g., email address, phone number, mailing address), your work history, and your educational and/or professional credentials. We also collect the contents of any emails and electronic messages, faxes, voicemails, or postal correspondence you send to us, including metadata from electronic communications (e.g., IP addresses, originating phone numbers or servers, time stamps, etc.). If you undertake a skills assessment as part of the interview process with E6, we will collect the information produced by that assessment and, where applicable, associated metadata.

Please do not send us unsolicited documents containing sensitive information, namely: any photographs of yourself or anyone else; any government-issued identification numbers; your date or place of birth; or any information about your marital or family status, immigration status, arrests or criminal convictions, national origin, racial or ethnic background, religious or philosophical beliefs, trade union membership, health or sex life, or sexual orientation. If you include these types of sensitive information in any résumé or CV you send to us, we may permanently delete the document for security reasons.

Personal information collected automatically

When you visit our Websites

When you visit our Websites, we may automatically collect Personal Information such as:

• Your IP address and associated location information
• Other information about your device which is automatically sent by your web browser (your device fingerprint)
• Information derived from analytics cookies about how you use our Website
• Information derived from analytics or third-party cookies linking your visit to our Website with our contact profile for you or with your LinkedIn profile

We use third-party cookies and tracking pixels on our Websites. You can read more about our use of analytics and advertising cookies, including how to block them, in our Cookie Policy.

If you use our customer documentation web portal by logging in using your assigned credentials, in addition to collecting the above information we may also log your activities on the portal, including pages visited and actions taken on those pages.

When you download or access our other interactive content

When you attend or download our webinars, download our e-books, or download or access any of our other interactive content, we may automatically collect Personal Information such as your IP address, associated location information, and other metadata; when you registered; and which content you have accessed and when.

When you receive our marketing communications

When you receive our newsletter or other marketing communications from us by email, we may collect information about whether you have viewed the email by use of a tracking pixel in the email. More information about what a tracking pixel is and how we use them is available in our Cookie Policy.

In our marketing emails, each hyperlink to our Website has a unique web address (uniform resource locator, or URL) which is different from every other URL in other marketing emails we out. When you click a link in one of our marketing emails, we collect information associating the visit to that specific web page with your email address and our associated contact profile for you.

Personal information collected from third parties

Contact details

We may collect Personal Information from third parties who have received your consent to share your contact details. For example, if you attended a payments industry conference and you gave consent for the conference organizer to share your business contact information with exhibitors and other third parties offering related products and services, the conference organizer may share your name and contact details with us.

If you register with a third party for a webinar, other event, or other interactive content produced by that third party which is sponsored by E6 or includes content provided by E6 (an “E6 Event”), we may collect your registration details where permitted by applicable data protection laws, even if the producer of the E6 Event did not explicitly obtain your consent. If applicable data protection laws in your region require your consent for the E6 Event producer to provide your registration details to us, then E6 will only receive them if the E6 Event producer has documented your consent.

Publicly available information

We may collect Personal Information, such as contact details and information about your employment, which you have made publicly available on web pages which are indexed by Internet search engines.

We may also use Personal Information we have collected from our business communications with you, for example in your role at one of our corporate customers or vendors, to look up additional publicly available information about you that is relevant to our legitimate business purposes, such as effectively marketing our products and services to your company or performing due diligence on products and services your company offers. We may look up such information using Internet search engines like Google, professional networking sites like LinkedIn, and public records of government or professional bodies.

We will not intentionally collect or process sensitive information about you from public sources except where (a) either you have manifestly made that information public yourself or the information has been published in a major media publication and (b) the information is essential for our legitimate business interests that are not overridden by your fundamental privacy rights. We will not collect or process sensitive information about you for marketing purposes.

Information about job candidates

When we are hiring for a job opening, sometimes we work with third-party recruiters to find suitable candidates. If you have provided your résumé or CV to a third-party recruiter and given your permission to share it with prospective employers, we may receive that information (e.g., your name, your contact details, your work history, and your educational and/or professional credentials) from the recruiter. If we are subject to additional contractual privacy restrictions on the use of Personal Information we receive about you from the recruiter, we will honor those in addition to the provisions in this Policy. We may also search for these types of employment-related information on LinkedIn and other public websites in order to approach suitable candidates as part of our in-house recruiting processes.

If you apply for a job with us, we may collect additional publicly available information about you that is relevant to our hiring processes (for example, industry awards, publications you have authored, regulatory enforcement actions against you, public commendations by colleagues, etc.) using Internet search engines like Google, professional networking sites like LinkedIn, and public records of government or professional bodies. We will not intentionally collect or process sensitive information about you from public sources except where (a) either you have manifestly made that information public yourself or the information has been published in a major media publication and (b) the information is directly relevant to whether you are a fit and proper person to undertake a specific role.

Personal information generated by us

As disclosed in this section, we may communicate with and/or about you, and draw inferences from Personal Information we hold about you. These processes may generate new Personal Information about you which is also subject to this policy.

Marketing activities

We may combine publicly available information about you and your company with other Personal Information we hold in order to draw inferences, such as information regarding your and your colleagues’ preferences and interests. Where these inferences can be linked with your individual identity, they are Personal Information.

Business-to-business activities

When we communicate with you in your role at one of our current or prospective customers or vendors, or we communicate about you and/or your company internally, we may produce decisions or other records that are linked to your individual identity. Insofar as this information relates to you personally rather than to the company you are working for, it may be Personal Information.

Data protection activities

We may combine Personal Information that has been automatically collected about you and others in order to investigate suspicious activity, data breaches, or other information security incidents, and to identify affected parties and provide any required notifications. These processes may produce records containing new Personal Information (for example, the fact that we sent you a data breach notification). We may also generate records containing new Personal Information by communicating with you regarding your requests about your Personal Information and by communicating internally or with third parties in order to fulfill these requests.

Recruiting and hiring activities

In order to ensure compliance with applicable laws, we maintain documentation regarding hiring processes and decisions. This may include internal notes and communications, and communications to recruiters, that contain Personal Information we have produced (for example, notes on answers to interview questions).

No personal information collected from or about children

We never knowingly collect Personal Information from or about anyone under 18 years of age. If we become aware that we have inadvertently collected the Personal Information of someone younger than 18, we will permanently delete that Personal Information as soon as possible.

Personal information you provide to us

Marketing and responding to requests for information

If you have signed up for our newsletter or requested us to contact you with more information about our company or our products and services, we will use the Personal Information you have provided in order to fulfill your request.

If you have previously provided your contact details to us when requesting additional information about our company or our products and services, or when entering a prize drawing intended to promote our company, we may send you our newsletter and other marketing communications in pursuit of our legitimate interest in marketing our products and services to individuals we have reason to believe are interested. Likewise, if you have registered with a third party for an E6 Event, we may use your registration details to send you marketing communications on the basis of this legitimate interest.

When you register for one of our webinars or to download one of our e-books or other online content, we will ask whether you agree to receive other communications from us about our products and services as well as other content that may be of interest to you. If you have indicated that you agree, then we may contact you on the basis of your consent.

If you do not want to receive our newsletter or other marketing communications, please click the Unsubscribe link in one of our emails, reply with “Not interested,” or contact us at Compliance@episodesix.com.

If you have contacted us in order to exercise your rights regarding your Personal Information, we will use the information you provide to locate your Personal Information that your request concerns; to verify your identity in order to keep your Personal Information secure; to reasonably fulfill your request or explain why it cannot be fulfilled, or can be fulfilled only in part; and to demonstrate our compliance with applicable data protection laws and defend ourselves against any legal claims that may arise pertaining to your request.

Business-to-business purposes

If you work for a current or prospective customer or vendor, we will use your contact information to communicate with you for legitimate business purposes, such as negotiation and execution of contracts, and other legal matters; billing and payment; implementation and support of your company’s products and services; and marketing, implementation and support of our company’s products and services. Likewise, we will use the contents and metadata of communications that you send for legitimate business purposes, including investigation of any suspected cyber incidents or suspicious activity. We will retain these types of Personal Information in accordance with our corporate data retention policy. We may also use Personal Information you have provided to look up publicly available information about you, and the company you work for, that is relevant to our legitimate business purposes such as effectively marketing our products and services to your company or performing due diligence on products and services your company offers. We will not intentionally collect or process sensitive information about you for marketing purposes.

Recruiting and hiring

If you have applied for a job with us or emailed us your résumé or CV, we will use the Personal Information you have provided to evaluate whether you may be a good candidate for any roles we have available, and to contact you if we would like to interview you. This processing may include automated searching of your Personal Information for relevant skills and qualifications. If you undertake a skills assessment as part of the application process, we will evaluate the results of that assessment as part of our decision-making. For certain types of assessment, automated scoring may be applied. No hiring decisions will be based solely upon automated processing.

If we contact you for an interview, we may also use your Personal Information to look up additional publicly available information about you that is relevant to our hiring processes, with appropriate limitations. We will not use your Personal Information to conduct criminal or financial background checks without your written consent. As noted above, we may delete your résumé or CV immediately if it contains sensitive information that we prefer not to store.

We will not use your Personal Information to conduct criminal or financial background checks without your written consent. We also will not use Personal Information collected in connection with recruiting and hiring for marketing purposes.

Personal information collected automatically

We use IP addresses and device information from visitors to our Websites and other online content to detect, prevent, and investigate cyber attacks. We may also use this information, along with information from analytics cookies, tracking URLs, and usage metadata from our marketing communications, to generate insights about the audience our Websites and interactive content are reaching, to market our products and services more effectively, and to improve the user experience.

Analytics and third-party cookies may also be used to link your visit to our public Website with our contact profile for you or with your LinkedIn profile. This information allows us to understand who is visiting our Website and to provide you with marketing information that is more relevant to you. We can also associate information about click-through of links in our marketing emails and interaction with our interactive content with your contact profile and with the company you work for.

You can read more about our use of analytics and third-party cookies, including how to block them, in our Cookie Policy.

Information we log about your use of our customer documentation web portal when you are logged in using your assigned credentials, including through the use of analytics cookies, may be used to generate insights about which content is most useful to our customers, to optimize content presentation, to develop product features, and to detect and investigate any potential misuse of our information assets.

Information obtained from tracking pixels about whether you have opened our newsletter or other marketing emails may be combined with information about which links you have clicked on from the emails in order to optimize our marketing communications, and may be combined with similar information about other people with email addresses at your company in order to build a better picture of what information is relevant to your business for our marketing purposes. We may also use information about email opening rates to update our lists of marketing contact information to remove email addresses of individuals who repeatedly do not open our emails, in order to avoid sending unwanted communications.

Personal information collected from third parties

Marketing purposes

We may use contact details we collect from third parties to contact you with information about our company and our products and services, and to send you our newsletter. Where required by applicable laws, we will only contact you for these marketing purposes if the third party has obtained your consent for this type of communication.

If you do not want to be contacted by us, please click the Unsubscribe link in any emails you receive from us, reply with “Not interested”, or contact us at Compliance@episodesix.com. Please note that even if you opt out of receiving promotional communications from us, we may continue to contact you about business transactions or in response to your requests.

Business-to-business purposes

We may use publicly available information about you and your company, and may combine this information with other information we have about you and your company, to draw inferences, such as information regarding your preferences and interests, and to improve our sales and marketing strategies by ensuring that our communications are relevant to you, or as part of undertaking due diligence on your company’s products and services, and for other legitimate business purposes such as collecting payments that are due or enforcing our legal rights.

Recruiting and hiring

When we collect employment-related information on LinkedIn and other public websites as part of our in-house recruiting processes, we use public information to draw inferences about the suitability of skilled professionals for job openings we have available, and to contact individuals whom we would like to interview. If we collect publicly available information about you for our in-house recruiting, we will provide you with notification, including a link to this Policy, in a timely manner where required by applicable law. If we then contact you regarding an interview and you decline or do not respond within a reasonable time, we will delete any Personal Information we collected about you in this manner.

If your résumé or CV is provided to us by a third-party recruiter with your consent, we will use the Personal Information you have provided to evaluate whether you may be a good candidate for any roles we have available, and to contact you if we would like to interview you. This processing may include automated searching of your Personal Information for relevant skills and qualifications, but no hiring decisions will be based solely upon automated processing.

If you have applied for a job with us and we look up publicly available information about you, we may make a note of any public information found that is directly relevant to our hiring process, including the source of that information; with the exception that, if the information is sensitive in nature, including any information about arrests or criminal convictions, we will not record or further process that information unless either you clearly made the information public yourself or the information was published in a major media outlet. We will not record any public information about you that is not directly relevant to whether you are a fit and proper person to undertake a specific role. Any Personal Information obtained from public sources in this manner may be included in our evaluation of your job application.

We will not use your Personal Information to conduct criminal or financial background checks without your written consent. We also will not use Personal Information collected in connection with recruiting and hiring for marketing purposes.

Personal information generated by us

Marketing purposes

We may use inferences we have drawn regarding your preferences and interests to provide you with marketing information that is more relevant to you. We may also combine these inferences with information about other people to better understand the audience for our marketing communications and to improve our products and services.

Business-to-business purposes

Any records we create about you relating to business-to-business transactions will be used to further purposes such as documentation of contracts and other legal matters; billing and payment; implementation and support of your company’s products and services; and implementation and support of our company’s products and services.

Data protection purposes

Any records we create in the course of investigating information security incidents or in the course of remediating data breaches, will be used for these purposes; for the establishment, exercise, and defense of legal claims; and for demonstration of compliance with applicable law. Likewise, any records we create in the course of responding to your requests about your Personal Information, or in the course of communicating internally or with third parties in order to fulfill your request, will be used for these purposes.

Recruiting and hiring

Any records we create in the course of our recruiting and hiring processes will be used to inform and document our hiring decisions, and to demonstrate compliance with applicable law.

We may share your Personal Information with our vendors and service providers in order to fulfill your requests and to provide you with a product or service, to operate our Websites, to market and improve our products and services, to manage our email and business contact information, to store our corporate records, to conclude or perform contracts, to complete audits, and to manage our hiring processes. We may also share Personal Information with law firms representing us where necessary to establish or defend legal claims. Our vendors and service providers are contractually obligated to safeguard your Personal Information and to use it only as permitted by us or as required by applicable law; they are not permitted to use your Personal Information for their own marketing or recruiting purposes.

We may also share Personal Information where required by legal authorities of competent jurisdiction; when we believe such sharing is necessary to protect the vital interests of an individual or to protect overriding interests of E6 or other entities in the safety and security of their property and personnel; and in the case of a corporate transaction, such as a merger, acquisition, or divestiture.

When using your Personal Information in the ways described in this Policy, we may share your Personal Information with service providers based outside of the European Economic Area (“EEA”), including in the United States. If you are located in the EEA, Switzerland, or the United Kingdom (“UK”), we will ensure that your Personal Information is protected at a level at least equivalent to that mandated by the laws where you are, either through the existence of a decision by the European Commission that the country where the service provider is based offers an adequate level of data protection, or through appropriate contractual safeguards between E6 and the service provider. Please contact us if you would like additional information about the safeguards we use when transferring your Personal Information.

Customer relationship management (CRM), web analytics, and fulfillment services

When you register to access our webinars and other online content, and when we use your Personal Information to send you our newsletter or otherwise communicate with you about our company, products, and services, we share your information with third-party vendors whose products and services enable us to manage our marketing contacts and email. If you unsubscribe or contact us to opt out from receiving these marketing communications, those preferences will also be shared with these vendors to ensure that we are able to honor your preferences going forward and don’t communicate with you by mistake.

When we use your Personal Information to send you marketing communications, we may use third-party fulfillment services to prepare and send those materials to you. If you opt out of future marketing communications from us, we will stop sharing your Personal Information with those vendors.

If you communicate with us for business-to-business purposes in your role working for one of our corporate customers or vendors, we may also share your contact information with these cloud-hosted third-party CRM tools so that we can manage our contact list and track our sales and marketing activities.

Other Personal Information we collect about you for marketing purposes, such as data from analytics cookies, third-party cookies, tracking URLs, and tracking pixels may also be shared with these third-party CRM tools and/or web analytics platforms.

The providers of these third-party CRM tools and web analytics may use aggregated, de-identified data derived from Personal Information we share with them in order to generate audience insights and improve their products and services. They are not allowed to use your Personal Information for other purposes except as directed by us or as required by applicable law.

Messages and corporate records

When you send us email for business-to-business purposes, your email and its associated metadata will be stored on a third-party cloud-hosted email service. Likewise, if you leave us a voicemail, it will be stored, with any associated metadata, on a third-party cloud-hosted voice-over IP (VoIP) phone system. If you send us electronic messages over a messaging application such as Microsoft Teams for business purposes, those messages and their associated metadata will be shared with the third-party cloud-hosted messaging service. If you send us a fax, it may be shared with a third-party e-fax service which converts the fax to email. Files and documents that you send to us for business purposes, as well as due diligence materials, may be saved to third-party cloud-hosted storage platforms and project management platforms. Personal Information that we receive from third parties or create by communicating with and/or about you, including through online feedback you provide, may also be saved to relevant cloud-hosted storage or communications platforms.

The providers of these third-party platforms are only allowed to process your Personal Information as directed by us or as required by applicable law, and may not reuse your Personal Information for their own purposes.

Human resources management

When you have applied for a job with us, your Personal Information may be uploaded to a third-party cloud-hosted human resources management platform for secure storage and management of job applications and résumés. Emails, including attachments, that you or recruiters representing you send will be stored on a third-party cloud-hosted email service. Likewise, your résumé or CV and related information may be sent by email within E6 during the hiring process and thus shared with a third-party cloud-hosted email service. Your résumé or CV may also be saved to a third-party cloud-hosted document storage platform, subject to suitable access restrictions, during the hiring process for access by interviewers at E6. If you undertake a skills assessment using an online platform, your Personal Information will be processed by the cloud-hosted assessment platform.

We will not share your Personal Information with third parties for purposes of background checks or credit checks without your written consent. We also will not share or sell Personal Information, where collected in connection with recruiting and hiring, to third parties for their own marketing or product development purposes.

Cyber security

When we use Personal Information collected via our Websites to detect and prevent cyber attacks, we may upload the data to third-party analysis tools in order to find any patterns requiring investigation. Reports from these third-party analysis tools are made available only to us and our auditors. If we detect suspicious activity on our Website based on the Personal Information we have automatically collected and we believe that a crime may have occurred, we may share that evidence with law enforcement.

Sharing within the E6 group of companies

Episode Six, Inc., is the parent company of several wholly owned subsidiaries. All members of this E6 group of companies agree to abide by the commitments of this Policy. Where your Personal Information has been collected by one member of the E6 group of companies, your Personal Information may be transferred to another member of the E6 group of companies where that transfer is necessary in order to fulfill the purpose for which the Personal Information was collected. All E6 member companies follow the same high baseline of data protection and information security standards and are obligated to provide your Personal Information with a level of data protection that is at least equivalent to that required by local law in the jurisdiction where you are located.

We take all due care to protect your Personal Information from accidental or unlawful destruction, unapproved alteration, loss, and unauthorized disclosure or access. We use state-of-the-art technical and organizational measures to safeguard your information. Among other technical measures, we use encryption, password complexity and session timeout requirements, multifactor authentication, network monitoring, and audit logging; among other organizational measures, we employ the principle of least access (i.e., our staff can only access the fewest systems and least amount of Personal Information required to do their jobs), remove terminated and inactive accounts, undertake log reviews, perform vendor due diligence, and maintain up-to-date business continuity and cyber incident plans. All of our staff are contractually committed to confidentiality and security requirements, and are required to undertake security training when they begin their roles and at least annually thereafter.

Because no security measures are perfect, we also have policies and procedures to provide timely notification to affected parties and relevant supervisory authorities in the event of a data breach.

We only keep Personal Information for as long as it is needed. When Personal Information is no longer needed for the purpose it was collected for, we will permanently delete or anonymize the Personal Information unless we are required to retain the Personal Information based on your requests or in relation to legal claims and obligations. If we collected Personal Information based on your consent, we will also delete your Personal Information when you withdraw your consent, except to the extent that we need a record (if any) of your consent withdrawal.

Please see the Overview Table at the end of this Policy for more details on how long we retain different types of Personal Information we collect.

If you ask us to erase your Personal Information, we will do so without undue delay, except insofar as it is necessary to store and process your Personal Information either (1) to fulfill a mandatory legal obligation we are subject to; (2) for the establishment, exercise, or defense of legal claims; or (3) to pursue overriding legitimate business interests that cannot be fulfilled without continuing to process your Personal Information, such as (a) entering into or performing contracts with our customers and vendors, (b) maintaining adequate records of our employees and contractors, (c) investigating cyber attacks on our Websites, and (d) protecting our intellectual property. If we cannot completely erase your Personal Information for one of these reasons, we will delete your Personal Information to the greatest extent possible and ensure that it is not used for any other purposes.

We use the following legal bases for collecting Personal Information:

• We may collect or process Personal Information with your consent, such as when you subscribe to our newsletter, submit a request for information, agree that we may contact you when you register for webinars or other online content, or apply for a job with us.
• We may collect or process Personal Information that is necessary to provide our products and services and fulfill your requests.
• We may collect or process Personal Information where required by applicable law.
• We may collect and process Personal Information when we have a legitimate interest in doing so, such as marketing our services, fulfilling our contractual obligations, providing our products and services, hiring suitable job candidates, preventing cyber attacks, or protecting the safety and security of our property and personnel, as long as our legitimate interests are not outweighed by your fundamental privacy rights. We may also process Personal Information where necessary for the legitimate interests of third parties in protecting the safety and security of their property or personnel.
• We may collect or process Personal Information if necessary to protect the vital interests of the user or another individual.

Please see the Overview Table at the end of this Policy for additional details about our legal bases for collecting and processing different types of Personal Information.

If you are located in the EEA or the UK, you may have the following legal rights regarding your Personal Information:

• Right to object. You have the right to object to processing of your Personal Information on the basis of our legitimate interests or for direct marketing. If you object to our processing your Personal Information for direct marketing purposes, including building a profile for direct marketing purposes, we are obligated to stop.
• Right to withdraw consent. If you have given us consent to collect or process your Personal Information, including by submitting your information directly to us, you may withdraw that consent at any time. You have the right to withdraw your consent without any negative effects on you except insofar as we are unable to process your Personal Information for the purpose you consented to.
• Right of access. You have the right to find out what Personal Information we have about you, and to receive a copy of your Personal Information without undue delay if you request it. Normally, such copies will be provided free of charge. However, if your requests are clearly unfounded or become excessive in nature, we may charge a reasonable fee taking into account the administrative costs of fulfilling your request or we may refuse to act on the request. Please note that, particularly where Personal Information we hold about you is interlinked with the Personal Information or intellectual property of others, we are only allowed to disclose your Personal Information in such a way that it does not infringe upon the rights and freedoms of others. This means that copies of information relating to you may contain redactions in order to protect the rights of others.
• Right to rectification. You have the right to correct or update Personal Information we hold about you if you believe it is incorrect or out of date.
• Right to erasure / right to be forgotten. You have the right to ask us to permanently delete or destroy your Personal Information.
• Right to restriction of processing. You have the right to ask us to restrict the processing of your Personal Information if you object to our processing on the basis of our legitimate interests, or if we no longer need your Personal Information for the original purposes of processing but you require it for establishment, defense, or exercise of legal claims. You can also request restriction of processing if time is needed to verify the accuracy of the Personal Information, or if you believe that our processing was unlawful but do not want us to erase the data.
• Right to data portability. You have the right to request a digital copy of your Personal Information in a commonly used, machine-readable format that may be transferred to another organization.
• Rights regarding automated processing. You have the right not to be subject to decisions based solely on automated processing that have significant effects on your life, except where the automated decision-making is necessary for performance of or entering into a contract, where the automated decision-making is authorized by your local laws that provide suitable safeguards, or where the automated decision-making is based on your explicit consent.
• Right to complain to a supervisory authority. You have the right to complain to a supervisory authority for data protection matters in the country where you are located, details of which can be provided upon request.

We will never discriminate or retaliate against you in any way for exercising your privacy rights.

While these rights are guaranteed by law to individuals located in the EEA, the UK, and in certain other jurisdictions to an equivalent or partial extent, we aim to provide at least this level of privacy protection to everyone covered by this Policy.

If you would like to exercise your rights regarding your Personal Information that we may have collected, please contact us according to the area in which you live, as set out in the subsections below.

European Economic Area

E6 has appointed VeraSafe Ireland Ltd. as our designated representative in the European Union for data protection matters (“EU Designated Representative”), pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are located in the EEA and would like to exercise your rights regarding your Personal Information that we may have collected, please contact our EU Designated Representative using the following contact details:

Secure online enquiry form: https://verasafe.com/public-resources/contact-data-protection-representative

Telephone:       +420 228 881 031

Postal mail:       VeraSafe Ireland Ltd.
                          Unit 3D North Point House
                          North Point Business Park
                          New Mallow Road
                          Cork T23AT2P
                          IRELAND

United Kingdom

If you are located in the UK, please contact our designated representative in the UK, Episode Six Ltd., using the following contact details:

Email:               Compliance@episodesix.com

Telephone:       +44 117 205 1277

Postal mail:       Episode Six Ltd.
                          7 Bell Yard
                          London
                          WC2A 2JR
                          UNITED KINGDOM

Singapore

If you are located in Singapore, please contact our data protection officer for Singapore using the following contact details:

Email:               Compliance@episodesix.com

Telephone:       +65 3158 9790

Postal mail:       Episode Six Pte. Ltd.
                          10 Collyer Quay
                          Ocean Financial Centre
                          Level 40, Office 4057
                          SINGAPORE 049315

Rest of World

If you are located elsewhere in the world, please submit your request using the following details:

Email:               Compliance@episodesix.com

Telephone:       +1 757 530 5294

Postal mail:       Episode Six, Inc.
                          201 West 5^th St., Ste. 1100
                          Austin, TX 78701
                          UNITED STATES OF AMERICA

Verifying your identity

Please note that we may request additional information from you in order to verify your identity before acting on your request. Please do not send copies of any identifying documents or government identification numbers via unencrypted email.