Last Updated: June 2025

Privacy Principles

Your privacy is important to us. NXT Capital, LLC and its affiliates (“NXT”, “we”, or “us”) wants you to be familiar with how we collect, use, disclose and protect your information.   This Privacy Policy describes our practices in connection with information that we collect through:

  • Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
  • Software applications made available by us for use on or through computers and mobile devices (the “Apps”);
  • Our social media pages that we control from which you are accessing this Privacy Policy (collectively, our “Social Media Pages”);
  • HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
  • Offline business interactions you have with us.

Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services.” 

If you are a California resident, please see the ADDITIONAL INFORMATION REGARDING CALIFORNIA at the end of this Privacy Policy for further details on how we handle your information and how to exercise your rights.

PERSONAL INFORMATION

Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  The Services collect the following categories of Personal Information:  

Personal Information we receive from you:
Identifiers Such as first and last name, prefix, email address, telephone number, postal address, government-issued ID (such as Social Security number), and professional or occupation-related information.
User Content Such as reviews about our Services and other content that you may create or share with us during our relationship, including posts on our Social Media Pages and comment sections.
Preferences Such as language, interests, and other feedback/preferences that you might express during your use of our Services.
Marketing Data Such as your choices regarding our newsletters, surveys, and other marketing/advertising displayed or provided to you, and preferred methods of such promotional communication.
Visitor and Event Information Such as dietary restrictions, travel, and accommodation details, issued identification pass to access the premises, and other details specific to a particular event or conference that you share with us.
User Photos and Videos Such as photos and videos submitted by you while using our Services.
Commercial Information Such as details of your communications with us, details of your claims, complaints, queries in general, and transaction information.
Financial Information Such as wire transfer instructions or bank account information.
Employment Information Professional or employment-related information, such as work history, company position, and current/prior employer.

Personal Information collected automatically through your use of our Services:

Online Activity Data Pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
Device Information Your mobile device’s operating system type and version, manufacturer and model, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information.

This includes data obtained through cookies and similar technologies, as described in the “INFORMATION COLLECTED AUTOMATICALLY” section below.

Audio/Visual Data Audio, electronic, visual, and similar information, such as call and video recordings, photos and videos taken at one of our events/conferences, CCTV, and site security information.
Geolocation Data Such as approximate location derived from IP address.

Other sources from which we collect Personal Information:

Social Media Such as profile pictures, social media account ID, and other public social media profile information, including lists of friends/followers on social media.
Other Third Parties We collect information from sources such as publicly available databases and affiliated entities.

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services.  If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

PERSONAL INFORMATION PROCESSING PURPOSES

We use Personal Information for legitimate business purposes, including:

Processing Purpose and Examples of Related Activities Personal Information Used
Administering the Services:  Providing the Services’ functionality to you, such as arranging access to your registered account; verifying your information; responding to your inquiries and fulfilling your requests, such as when you contact us via one of our online contact forms or otherwise (e.g., when you send us questions or comments, or when you request other information about our Services); to send you administrative information, such as information regarding the Services and changes to our terms, conditions, and policies; and/or to allow you to send Services-related content to another person through the Services if you choose to do so. Identifiers; User Content; Preferences; Marketing Data; Commercial Information; Visitor and Event Information; User Photographs and Videos; Commercial Information; Financial Information; Employment Information; Online Activity Data; Device Information; Audio/Visual Data; Geolocation Data.
Operations and general business:  Administering online Services (including troubleshooting and diagnostic testing, conducting performance analyses of our systems and Services, testing new system features to evaluate their impact, system and log maintenance, technical support, system debugging, and hosting data); and facilitating mergers, acquisitions, and other reorganizations and restructurings of our business (including prospective transactions). Personal Information as relevant for the specific business operation.
Conferences, visits, and other events:  Facilitating and participating in conferences and events, welcoming guests and visitors to our premises. Identifiers; Preferences; Commercial Information; Device Information; Online Activity Data; Audio/Visual Data.
Marketing:  Sending you newsletters, event invitations, and mailings that we think may be of interest to you; fulfilling your event registration requests; and providing services, including providing events. Identifiers; Commercial Information; Preferences; Marketing Data; Visitor and Event Information; Audio/Visual Data; User Content; Online Activity Data; Device Information.
Personalizing our Services: Personalizing our interactions with you and providing you with information and/or offers tailored to your interests, such as delivering content via our Services that we believe will be relevant and interesting to you. Identifiers; Marketing Data; Commercial Information; Visitor and Event Information; User Photographs and Videos; Online Activity Data; Device Information; Preferences.
Improving and developing Services that we may provide to you:  Conducting data analysis, for example, monitoring and analyzing Services use and using data analytics to improve the efficiency of our Services; developing new Services; considering ways to enhance, improve, repair, maintain, or modify our Services; identifying usage trends, for example, understanding which parts of our Services are most interesting to users; determining the effectiveness of our promotional campaigns, so we can adapt our campaigns to the needs and interests of our users; and operating and expanding our business activities. Identifiers; Commercial Information; Preferences; User Content; Visitor and Event Information; User Photographs and Videos; Online Activity Data; Device Information; Financial Information; Audio/Visual Data.
Relationship building and engagement:  Facilitating and responding to any social sharing and posts on our Services and other customer relationship building activities. Identifiers; Marketing Data; Visitor and Event Information; User Photographs and Videos; Online Activity Data; Device Information; User Content.
Aggregation and/or anonymization:  Aggregating and/or anonymizing Personal Information so that it will no longer be considered Personal Information. Personal Information as relevant for the specific business purpose.
Security and fraud prevention:  Conducting audits, verifying that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements; monitoring for and preventing fraud; and for security purposes, including maintaining system security and on-site security of our premises. Identifiers; Device Information.
Legal and compliance:  Fulfilling our legal and compliance-related obligations, including complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements, compliance with requirements set by industry-specific supervisory bodies. Enforcing our terms and conditions and standards; protecting our operations; protecting our rights, privacy, or property; responding to auditors; and allowing us to pursue available legal remedies and make insurance claims, defend claims, and limit the damages that we may sustain. Personal Information as relevant for the specific legal action, regulatory investigation, and/or legal processes in question.

 

Emergency and incident response:  Ensuring the safety of on-site personnel and visitors; responding to, handling, and documenting on-site accidents and medical and other emergencies; actively monitoring properties to ensure adequate incident prevention, response, and documentation (including CCTV); requesting assistance from emergency services; and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio‑visual device prompts, etc.). Personal Information as relevant for the specific emergency or incident.

Individuals in the EEA/UK: Please view the EEA/UK Privacy Policy Supplement at the end of this Privacy Policy for more information regarding our legal basis for processing Personal Information.

DISCLOSURE OF PERSONAL INFORMAITON

We disclose Personal Information to third parties and for the purposes described below, depending on each specific jurisdiction and applicable law:

Recipients Purpose
Our affiliates For all the purposes listed above, ORIX and the relevant affiliates are responsible for the management of any jointly used Personal Information.  You can consult the list and location of our affiliates here https://www.orix.com/offices/.
Third-party service providers Including service providers that provide Website and App hosting, IT and related infrastructure, email delivery, analytics, and other services for the following purposes:

    • Administering the Services
    • Improving the Services
    • Operations and general business
    • Security and fraud prevention
    • Marketing
    • Personalizing our Services
    • Relationship building and engagement
    • Conferences, visits, and other events
    • Legal and compliance
Analytics providers

 

    • Aggregating and/or anonymizing Personal Information
    • Security and fraud prevention
    • Improving the Services
    • Marketing
    • Operations and general business
    • Personalizing our Services
Business partners
    • Event co-sponsors
    • Third parties in connection with carrying out our respective business purposes, such as conducting transactions and to permit them to send you marketing communications, consistent with your choices.
Law enforcement, public, regulatory, and government authorities, courts, tribunals, or third parties where necessary to comply with applicable law and regulations
    • Emergency and incident response
    • Security and fraud prevention
    • Legal and compliance
    • Responding to a request or providing information to public and government authorities (including authorities outside your country or region of residence)
    • Responding to law enforcement requests and orders or provide information to law enforcement
    • For dispute resolution purposes
    • To enforce our terms and conditions
    • To protect our rights, privacy, safety, property, and/or that of our affiliates, you or others
Professional advisors, such as accountants, actuaries, auditors, experts, consultants, lawyers, banks, and financial institutions
    • Security and fraud prevention
    • Legal and compliance
    • Improving the Services
    • In connection with carrying out our respective business purposes, such as conducting transactions
Third parties, such as an acquiring entity and its advisors, in connection with a sale or business transaction We may disclose or transfer your Personal Information in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You will be notified of any such business transaction and of possible changes to the processing of your Personal Information in accordance with applicable law and the “UPDATES TO THIS PRIVACY POLICY” section.

By using the Services, you may elect to disclose Personal Information on message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages), or through which you are able to send messages through the Services. Please note that any information you post or disclose in this context will become public and may be available to other users and the general public.

INFORMATION COLLECTED AUTOMATICALLY

We and our service providers collect information automatically when you use the Services, such as:

  • Browser and device information;
  • App usage data;
  • Information collected through cookies, pixel tags and other technologies;
  • Demographic information and other information provided by you that does not reveal your specific identity; and
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity.

Collection of Information Automatically

We and our service providers may collect information automatically in a variety of ways, including:

  • Your browser or device.
    • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
  • Your use of the App.
    • When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
  • Cookies.
    • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.  We do not currently respond to browser do-not-track signals.  Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services.  We may also use cookies or other technologies in online advertising to track responses to our ads.   If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.  You also may not receive advertising or other offers from us that are relevant to your interests and needs.
  • Pixel tags and other similar technologies.
    • Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
    • Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to google.com/policies/privacy/‌partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
    • Hotjar. We also use Hotjar, which collects and analyzes information about your use of the Services. You can learn more about Hotjar’s practice by going to https://www.hotjar.com/privacy/, and exercise the opt-out provided by Hotjar by visiting https://www.hotjar.com/privacy/do-not-track.
  • Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies.
    • We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel.  You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time).  Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.

Uses and Disclosures of Information Collected Automatically

We may use and disclose information collected automatically for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat information collected automatically as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine information collected automatically with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS 

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:

    1. Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by following the unsubscribe instructions in each marketing email.
    2. Our sharing of your Personal Information with affiliates for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by contacting us directly by phone at (646) 569-2300 or email at dataprivacy@nxtcapital.com.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information 

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request consistent with applicable law.  If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under applicable privacy law.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when entering into a transaction or promotion, you may not be able to change or delete the Personal Information provided until after the completion of such transaction or promotion).

Depending on your jurisdiction, you may also lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. For example, a list of EEA data protection authorities is available at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.  Information regarding the UK data protection authority is available at: https://ico.org.uk/.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

Jurisdiction and CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA, UK and Cayman Islands: Some non-EEA countries are recognized by the European Commission (and the United Kingdom and the Cayman Islands) as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en#adequacy-decisions-latest).  For transfers from the EEA, UK or the Cayman Islands to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information.  You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.

CONTACTING US

The ORIX group company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy for the Services you interact with in your country or region is available at https://www.nxtcapital.com/.

If you have any questions about this Privacy Policy, please contact us by email at dataprivacy@nxtcapital.com, or mail at NXT Capital, LLC, 191 N. Wacker Drive, 30th Floor, Chicago, IL 60606, Attn: Chief Compliance Officer.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018, and California Privacy Rights Act (collectively, the “CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents.

NOTICE AT COLLECTION

Collection and Disclosure of Personal Information

The following chart includes the categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes, including within the 12 months preceding the date this Privacy Policy was last updated.

Categories of Personal Information Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, contact information, Social Security Number, IP address that can reasonably be linked or associated with a particular consumer or household, and online identifiers. affiliates; service providers; business partners; legal authorities
Personal information as defined in the California customer records law, such as name, employment information, bank account information, signature, address, and telephone number. affiliates; service providers; business partners; legal authorities
Internet or network activity information, such as browsing history, search history and interactions with our online properties or ads. affiliates; service providers; legal authorities
Professional or employment-related information, such as work history, position in company, and current/prior employer. affiliates; service providers; business partners; legal authorities
Characteristics of protected classifications under California or federal law, such as sex, age, race, gender, disability, national origin, medical conditions and information, citizenship, primary language, and immigration status. affiliates; service providers; business partners; legal authorities
Geolocation data, such as approximate location of devices used to access our website or online application portal, derived from IP address. affiliates; service providers; legal authorities
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics. affiliates; service providers; legal authorities
Sensitive Personal Information, such as personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status;

 

affiliates; service providers; legal authorities

We do not “sell” and have not “sold” Personal Information (including Sensitive Personal Information), and we do not “share” or otherwise process Personal Information (including Sensitive Personal Information) for purposes of cross-context behavioral advertising, as defined under the CCPA.  We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated.  Without limiting the forgoing, we do not “sell” or “share” Personal Information (including Sensitive Personal Information) of individuals under the age of 16.

Purposes for the Collection, Use, and Disclosure of Personal Information

We use and disclose this Personal Information for the purposes described in detail above under “Personal Information Processing Purposes” and in “Disclosure of Personal Information” sections.

Collection, Processing, and Disclosure of Sensitive Personal Information

We collect, process, and disclose Sensitive Personal Information for purposes permitted under applicable law, including for purposes of: performing services for our business, providing goods or services, ensuring safety, security and integrity, countering wrongful or unlawful actions, short term transient use such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, providing customer services, verifying customer information, processing payments, providing financing, activities relating to quality and safety control or product improvement, and other collection and processing that is not for the purpose of inferring characteristics about an individual.

We do not use Sensitive Personal Information for additional purposes.

California Retention Period

We retain Personal Information (including Sensitive Personal Information) for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law and consistent with the criteria listed in the “Retention Period” section above.

GO TO TOP OF PRIVACY POLICY

Sources of Personal Information

We collect this Personal Information from you and from the sources described above under “Categories and Sources of Personal Information Collected.”

Individual Rights and Requests

Requests to Know, Correct, and Delete

If you are a California resident, you may make the following requests:

1. “Request to Know

You may request that we disclose to you the following information:

The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

The specific pieces of Personal Information we collected about you, including a copy of your Personal Information in a portable format;

The business or commercial purpose for collecting (if applicable) Personal Information about you; and

The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).

2. “Request to Correct

You may request to correct inaccuracies in your Personal Information.

3. “Request to Delete

You may request that we delete Personal Information we collected from you.

To make a request, you can email us at dataprivacy@nxtcapital.com, fill out the privacy policy form, call 646-569-2300, call toll free at 1-833-358-2395, or contact us in accordance with the “Contacting Us” section above.  We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  We may need to request additional Personal Information from you, such as a few examples of the types of Personal Information you may request, in order to verify a request, verify your identity and protect against fraudulent requests.  You may make a request on behalf of a child who is under 13 years old if you are the child’s parent or legal guardian.  If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted above in this section.  As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.

Right to Non-Discrimination

You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.

De-Identified Information

Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

EEA/UK Privacy Policy Supplement

We process Personal Information based on the following legal bases:

Purpose Legal Basis for Processing
Administering the Services We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Operations and general business We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest, such as maintaining and improving our Services.
Conferences, visits, and other events We engage in these activities to manage our contractual relationship with you and/or based on our legitimate interest, such as improving the quality of our events and responding to complaints and concerns relating to an event.
Marketing Where required under applicable law, we obtain your consent to send you direct marketing communications. Where permitted by applicable law, we also engage in marketing activities based on our legitimate interest, such as to promote our Services.
Personalizing our Services Where required under applicable law, we obtain your consent to provide personalized Services. Where permitted by applicable law, we also personalize the Services based on our legitimate interest, such as providing tailored Services based on your preferences.
Improving and developing Services that we may provide to you We engage in these activities based on our legitimate interests, such as developing new Services, and with your consent to the extent required by applicable law.
Relationship building and engagement We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest, such as improving our Services.
Aggregation and/or anonymization We engage in these activities based on our legitimate interest, such as to generate anonymized data for our own business purposes which does not identify you or another individual.
Security and fraud prevention We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest, such as identifying and preventing fraudulent transactions and cyberattacks.
Legal and compliance We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest, such as our interest in enforcing our terms and conditions and bringing and defending legal claims.
Emergency and incident response We engage in these activities to manage our contractual relationship with you, to protect individuals’ vital interests, to comply with a legal obligation, and/or based on our legitimate interest, such as ensuring the safety of our premises.