Sindstrøm Tek (“we” or “us”) refers to Sindstrøm Tek SVP as well as any respective subsidiaries and affiliates. Sindstrøm Tek is a leading global advisor on the complexity of technology development and integration.

Privacy and data protection is central to what we do and this Privacy Policy and Notice (“Policy” or “Notice”) describes how we collect, uses, discloses and otherwise processes personal information described in “Scope”, as well as the rights and choices individuals have regarding such personal information. This Notice applies to the extent we process personal information on our own behalf, as a controller or business.

For information about the privacy choices you have regarding your personal information, review Section 8.

Your use of our Services (defined below), and any dispute over privacy, is subject to this Notice and our Terms of Use, including their applicable limitations on damages and the resolution of disputes.

1. Scope

Except as otherwise noted below, this Notice applies to the personal information that Sindstrøm Tek processes as a controller related to: 

• our Services

• individuals that register for or participate in our webinars and other events; 

• current, former and prospective customers, vendors and partners; 

• individuals who are subscribed to receive news, information and marketing communications from us; and 

• individuals that communicate with us or otherwise engage with us related to our Services.

Not In Scope. This Policy does not apply to the personal information that we collect and process about employees, job applicants, and contractors. Please contact us using the details found on our website if you require these notices.

1. Personal Information Collected

As further described below, we may collect personal information directly from individuals, from third parties, and automatically when such data relates to the use of our Services or other interactions with us.

Personal Information Collected Directly. The personal information we may collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes:

• Registration and profile information. When you register for an account in connection with our Services, or we provide you with account login credentials to access our Services, we may collect certain personal information from you, such as your name, phone number, date of birth, and email address, as well as any personal information that you otherwise submit to us through your account.

• Survey responses. When you provide answers to the surveys we publish in connection with our Services, we may collect such survey responses, including but not limited to information regarding demographics, your food and drink consumption and preferences, your workplace, your education level and your opinion about products and services. Participation in our surveys is completely voluntary. You may choose not to answer any particular survey. 

• Payments and purchases. When you make a purchase or payment through the Services, we may collect purchase and payment information in order to process your payment, such as your credit card number and applicable billing address. 

• Communications and interactions. When you email, call, or otherwise communicate with us and with members of our team, we may collect and maintain a record of your contact details, communications and our responses. We also maintain records communications regarding information you provide to us related to any customer support requests. 

• Events and other requests. We may also collect personal information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event. When you contact us via email, sign up for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests, including through forms you may complete on our website. 

Personal Information from Third Parties. We may collect personal information about you from third party sources, such as public databases, joint marketing partners, social media platforms or other third parties.

• We may receive lead and prospect information from third parties about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information.

• In order to use certain features of our Services, you may choose to share content from third party accounts. If you grant us permission to access this data by enabling this sharing, we will access and export this third-party content. Consent for this process is controlled by you. You can revoke your consent to our access any time. Where you have given us permission to access your third-party account, the specific information we collect is limited to your purchase transactions.

• We work with third parties to gather information about how users interact with their or our services. This may include information such as demographic information, preference information, what you watch or buy, what video games you play, or your exposure to advertising. These sources include, for example: census data, the manufacturers or sellers of the products you purchase or use, organizations that collect online data, data suppliers, companies that combine purchase information, and other entities that have a legal right to provide such information to us.

Personal Information Collected Automatically. We automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:

• Device and browsing information. We may use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see Section 6. Cookies, Targeting and Analytics , below. 

• Activities and usage. We may also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, content viewed, time spent within the Services.

1. Purposes of Use and Legal Bases for Processing Personal Information

Generally, we may collect, use, disclose and otherwise process the personal information we collect for the purposes set forth in this section. This section also sets forth the legal bases for which we process personal information, as required by the EU General Data Protection Regulation (the “GDPR”).

Legal Bases for Processing. Pursuant to the GDPR (and other relevant laws), we generally process your personal information pursuant to the following legal bases (the “EU Legal Bases”):

• Performance of our contract with you. Where we have a contract or agreement with you personally, certain personal information we collect is used to perform our agreements with you, including our Terms of Use and other terms and conditions applicable to the Services you use.

• To comply with a legal obligation to which Sindstrøm Tek is subject. The personal information we collect may be processed in order to comply with the law and our legal obligations.

• For our legitimate business interests. We may process personal information in furtherance of our legitimate business interests such as, providing access to the Services that we have contracted to your employer, protecting, maintaining and improving the Services; developing new Services; marketing and promoting our Services (including by profiling and marketing to customers); protecting our legal rights and interests; in support of mergers, acquisitions, reorganizations and other business transactions; and to generally operate and improve our business.

• With your consent. We may process personal information about you based on your consent, for example (where required by law) to send you marketing communications, surveys, news, updates and other communications. In addition, where required by applicable law, Sindstrøm Tek will obtain your consent to this Policy and our collection, use and disclosure of your personal information. Users of our Services may be able to withdraw their consent at any time in accordance with applicable laws; please see Section 8. Your Privacy Choices below for information on how to withdraw your consent. 

Purposes of Use and Processing. While the purposes for which we may process personal information may vary depending upon the circumstances in which we collect such personal information, in general, we may use, disclose and otherwise process personal information for the purposes set forth below. 

• Services and support. To provide and operate our Services, manage your account, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your requests, facilitate payment processing, communicate with you about the Services, and for similar service and support purposes. (EU Legal Basis: performance of our contract with you; your consent; and/or for our legitimate business interests).

• Analytics and improvement. To better understand how users access and use the Services and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes. (EU Legal Basis: our legitimate business interests).

• Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and to otherwise personalize your experiences and offerings. (EU Legal Basis: our legitimate business interests; and/or your consent).

• Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as offers, promotions, newsletters and other marketing content, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content. (EU Legal Basis: our legitimate business interests; and/or with your consent).

• Planning and managing events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services. (EU Legal Basis: our legitimate business interests).

Research and surveys. To administer surveys and questionnaires, such as for market research or customer satisfaction purposes. (EU Legal Basis: our legitimate business interests).Developing insights and enhancing data. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts. In most cases, the information that we may combine with the personal information collected through the services for market research, such as demographic information, does not directly identify consumers. (EU Legal Basis: our legitimate business interests).Security and protection of rights. To protect the Services, users of our Services, and our business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use. (Legal basis: our legitimate business interests; to comply with a legal obligation; and/or performance of our contract with you).Compliance and legal process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings. (Legal basis: our legitimate business interests; and/or to comply with a legal obligation).General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions. (Legal basis: our legitimate business interests; and/or to comply with a legal obligation).

1. Disclosures of Personal Information

We may disclose the personal information that we collect for the purposes described above, in order to provide our Services to you, to respond to and fulfil your requests, as otherwise directed or consented to by you, and as follows: 

• Vendors and service providers. We may disclose personal information we collect to our service providers, processors and others who perform functions on our behalf. These may include, for example, IT service providers, payment processors, analytics providers, consultants, auditors and legal counsel.

• Our affiliates and subsidiaries. We may disclose personal information we collect to our affiliates or subsidiaries, who will use and disclose this personal information in accordance with the principles of this Policy, and the more specific policies.

• Customers. We may disclose deidentified, aggregated information regarding your use of our Services to help our business customers better understand consumer behavior. For example, we may combine and/or aggregate information or survey responses that you allow us to collect with the responses of others to produce deidentified reports. We may also create aggregated reports based upon deidentified modeled information. “Modeled information” is data based upon demographic and behavioral characteristics (e.g., gender, age, and purchasing habits) to predict what people with similar or matching characteristics would buy.

• Customers. If you are using a product or service we may disclose any personal data provided, including your usage statistics to the party we have an agreement or license in place with permitting your use of such product or service.

• Third party platforms, providers and networks. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make certain information that includes personal information available to third parties in support of our marketing, analytics, advertising and campaign management (see Section 6. Cookies, Targeting and Analytics for more information).

• Commercial Partners and Other Third Parties. (i) In connection with our business, we may disclose demographic information (e.g., gender, household size, and number of children) to commercial partners and other third parties in either single or aggregate summary form and may also provide other aggregate or deidentified information to such third parties (singular summary includes demographic information about a person without specifically identifying the person and aggregate summary includes demographic information about a group of persons without specifically identifying any person within the group); or (ii) we may also provide your personal information, with respect to some of our Services, to commercial partners and other third parties, such as retailers, brands, and partners we co-sponsor surveys with, for marketing research and analytics purposes (for example, to create models that estimate consumer preferences in the total population or to inform market segments).

• Panel Owners. Where you have registered to become a member of a market research panel operated by another company (“Panel Owner”) and chosen to participate in a survey, we may provide information to the Panel Owner for purposes of confirming whether or not you have taken our survey.

• Data contributors with respect to media products. In limited instances, specifically with respect to Sindstrøm Tek’s media products, Circana combines its own market data with the data of its customers and other third parties. To ensure the combined data can be continuously updated by all parties contributing data, the data is associated with a unique ID that is made available to all data contributors. The data made available does not directly identify consumers (i.e., name, email, physical address, and other directly identifying information is not made available to data contributors).

• In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.

• Compliance and legal obligations. We may also disclose personal information to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. In addition, it may include certain disclosures that we are required to make under applicable laws, such as the names of sweepstakes and contest winners.

• Security and protection of rights. We may disclose personal information where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of, our Terms of Use. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

1. Aggregate Data and Non-identifiable Data

We may also receive, use and disclose aggregate and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Some of this information may be considered “deidentified” under privacy laws (i.e., data that it is no longer linked or reasonably linkable to an identified or identifiable consumer). Where we rely on data that has been “de-identified” as defined by EU privacy laws, we will maintain and use such information in deidentified form and will not attempt to reidentify such information, except in order to determine whether our deidentification processes are reasonable and adequate or as otherwise set forth by these laws.

1. Cookies, Targeting and Analytics

We and our third-party service providers may use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect information browsing, activity, device and similar information within our Services and to target advertising and content. We may use this information to, for example, analyze and understand how users’ access and use our Services, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve the performance of our Services. You have certain choices about our use of cookies and tracking within the Services, as described in this section. For more information on the types of personal information we collect via cookies and similar mechanisms, please see Section 2. Personal Information Collected .

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service. 

Pixel tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics and Tools. We may use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. 

Cross-device Tracking. We and our third-party providers may use the information that we collect about you within our Services and on other third-party sites and services to help us and these third parties to identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). This information may be used as set forth in this section and Section 6. Cookies, Targeting and Analytics .

Targeted Advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites, mobile apps and online services. We may share certain information with these third-party ad companies, and we and they may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content. 

Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email address and other contact information) with third parties (i) so that we can better target ads and content to you across third party sites, platforms and services, and (ii) in some cases, these third parties may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns. 

Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or ‘contextual’ ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

• Browser settings. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Services who disable cookies will be able to browse the website, but some features may not function.

1. International Transfers of Data

Sindstrøm Tek may collect your personal information from the EU, and we may transfer your personal information to and process your personal information from other jurisdictions where we and our affiliates and service providers have operations. Some of these jurisdictions may not provide equivalent levels of data protection as compared to your home jurisdiction.

1. Your Privacy Choices

We make available a number of ways that you can manage your privacy choices and submit privacy requests related to your personal data. These include:

• Account information. You can review and update some of the personal information that we maintain about you by logging into your account, where applicable, and updating your account information.

• Push notifications. In connection with some of our Services, we may send push notifications from time-to-time in order to communicate with you regarding your account and promotions. If you no longer wish to receive these types of communications, you may turn them off at the device level.

• Targeted advertising/cookie preferences. As described in Section 6. Cookies, Targeting and Analytics there are several ways that you can manage your preferences for targeting cookies and advertising by us and on our website. You can review or change your preferences for many cookies and tags on our website, other than those that are necessary to operation and functionality, by adjusting your cookie settings in your browser. These preferences are browser and device specific. So, you will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies you may need to reapply these settings. 

For more information about our privacy practices and your privacy choices, you may contact us as set forth in the ‘Contact Us’ section below.

1. Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected or as otherwise necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. 

1. Security

We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

1. Contact Us

If you have questions about this Notice or our privacy practices, you may contact us through by email at info@sindstromtek.com.