This Privacy Notice is effective as of December 2023, and supplements the information contained in S2W Media's  Privacy Policy. S2W Media will regularly review and update this Notice to reflect changes to applicable privacy laws and how we handle your personal information. We will notify you of any changes to this Notice by posting updates on our website and modifying the Notice's effective date.

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This Notice applies solely to State of California residents ("you" or "consumer") whose personal information S2W Media ("we" or "us") collects through S2W Media's websites and other methods discussed herein and processes under the California Consumer Privacy Act of 2018 (CCPA). If you do not reside in the State of California, please visit  S2W Media Privacy Policy.‍

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This Notice covers how we process, protect, and control consumer personal information. Furthermore, this Notice covers consumers' rights under CCPA concerning processing consumer personal information by S2W Media. 

This Notice does not cover employment-related personal information collected from employees, job applicants, consultants, contractors, or individuals acting in a similar capacity to employees who reside in the State of California. 

This Notice does not apply to information that we receive or maintain on behalf of our customers in our role as a service provider since such terms are governed by the applicable service agreements with our customers.

S2W Media's Privacy Policy is located at https://www.s2wmedia.com/company/privacy-policy

Which categories of personal information do we collect and process?

We collect your personal information when you subscribe to our website or give your consent to our agents to collect and process your personal information. If the information we collect is not listed in this Notice, we will provide consumers with an appropriate Notice of which other information we will collect and how we will process it. 

In the context of this Notice, personal information refers to information that can be used to identify, locate, or contact a consumer. 

The categories of personal information we collect and process in the context of the processing activities outlined in this Notice are:

• Identifiers, including your first and last name, email address, telephone number, online and social media usernames, or other similar identifiers
• Position and professional or employment-related information, including your job title, position description, employer, location (i.e., office address)
• Internet or other similar network activity, including information posted on your LinkedIn profile

We do not use cookies and similar optimization technologies on our website to measure website traffic and usage activity or gather information, such as the date and time of visits, geographic location, pages viewed, IP address, links to/from any page, browser type and version, operating system, referral source, and time spent on our website.

With your consent, we may also collect additional personal information, including emails, surveys, and other forms of communication.

Suppose you provide us with personal information about another person. In that case, you are responsible for notifying such person of the information in this Notice and obtaining consent from such person to share the information with us. 

How do we collect your personal information?

The categories of personal information referenced above are collected directly from you through your interactions with our website, for example, when signing up for our monthly newsletter, downloading certain content, communicating with us, etc. Your personal information may also be collected from public sources, such as social networking websites. Your decision to provide us with your personal information is voluntary, except where laws or S2W Media policies require us to collect specific information from you. Please, be advised that we may not be able to provide some or all of our services that require the use of your personal information if you do not provide us with certain personal information. 

How do we protect your personal information?

S2W Media offers lead generation, ABM execution campaigns, BANT leads, and data services to businesses that market and sell to other companies. We take great responsibility for ensuring the privacy and security of our websites' visitors and every prospect who has given us consent to receive marketing materials from our clients and us. 

We protect your personal information by maintaining appropriate technical, security, and administrative controls on our systems storing, transmitting, and processing your personal information to minimize the risk of unauthorized access, disclosure, unlawful processing, accidental or unlawful loss, destruction, alteration, or damage per applicable laws and privacy policies. We follow protocols, policies, procedures, and guidelines aligned with leading industry standards to protect your personal and our company information. 

While we take reasonable steps to maintain the security of your personal information, you should understand there is always a level of risk assumed by sharing personal data online. If you have reason to believe that your interaction with our website is no longer secure, please immediately inform us per the "How to reach us for privacy concerns" section below.

What sensitive personal information do we collect?

We do not collect sensitive personal information as defined below through our website or otherwise. In the unlikely case where we seek to collect such data, we will do so per applicable privacy laws after obtaining your consent. 

Sensitive personal information refers to various categories of personal information requiring special treatment per data privacy laws, including in some circumstances obtaining your explicit consent before collecting it. These categories include racial or ethnicity information, political affiliations, religious, philosophical, and other similar beliefs, trade union memberships, health information, biometric or genetic data, sexual life or orientation, criminal convictions, and offenses. 

For which purposes do we use and process your personal information?

We limit access to your personal information to our employees and contractors who have a legitimate need to use it. We use your personal information only as needed to fulfill a specific purpose, including:

• Complying with legal requirements to which we are subject
• Responding to your inquiries, fulfilling your requests, providing customer service, sending administrative information, and personalizing your experience with our services
• Improving the content and functionality of our website
• Marketing and promoting our services to you to ensure we can conduct, improve, and increase our business. For example, we may use the information you provide to contact you in the manner(s) you request when the information is collected. We may collect your email address to send you content and newsletters or contact you about services or information in which you expressed interest
• Managing our contractual relationship with you
• Communicating with you to ensure proper communication and emergency handling with our company
• Contacting you in the future regarding services, opportunities, and other general information about us that we believe will be of interest to you
• Operating and managing our business operations and provisioning our services to you
• General market research to gain market insights
• Social listening to identify what is being said about us on social media to protect our brand
• Performing data analytics to ensure the proper functioning of our business operations

We will process your personal information for the purposes stated above after obtaining your consent, to the extent that such consent is mandatory under applicable laws. Unless required or authorized by law, we will not use your personal information for purposes not specified in this Notice.

Our legal basis for collecting and using the personal information described in this Notice will depend on the pieces of personal information we collect and the specific context in which we collect it. However, we will generally collect personal information from you only:

• Where the processing is in our legitimate interests and not overridden by your rights
• Where we need the personal data to perform a contract with you
• Where we have your consent to do so

Will we share your personal information with third parties?

We may share your personal information with third parties when you ask or authorize us to do so or in connection with the purposes described in this Notice. We will, whenever possible, obtain confidentiality agreements from any person or entity to whom your personal information is disclosed. Furthermore, we will take appropriate action to ensure that any recipient of your personal information has appropriate security measures to protect it and a valid reason for processing and using it per applicable laws and our internal policies. We may transfer your personal information to any of our locations and subsidiaries of S2W Group. We may also share your personal information with third parties as required to fulfill a corporate transaction, such as the sale of a website, mergers, consolidations, initial public offering, or in the unlikely event of a bankruptcy. 

In general, we may share your personal information in connection with the purposes described in this Notice with the following categories of third parties:

• Service providers in connection with particular services we provide to you, such as customer support, email delivery, data processing and management, survey administration, and other fulfillment
• Business partners, clients, advertisers, subsidiaries, and other third parties to tailor and deliver ads and content to you on their Services or to help you get the best marketing content
• Law enforcement, regulators, courts, and other Governmental authorities when responding to subpoenas, court orders, legal processes, and other legal matters. We may also share your personal information with this category of third party to protect the rights, property, safety, security of other parties, our website visitors, or the general public
• Business or Asset transfers in connection with a merger, acquisition, transfer of control, bankruptcy, reorganization, or asset sale

We may disclose the following categories of personal information to the above third parties for a specific business purpose:

• Identifiers
• Position and professional or employment-related information
• Internet or other similar network activity

We may sell the following categories of personal information to our business partners, subsidiaries, advertisers, clients, and other third parties or as part of a business or asset transfer:

• Identifiers
• Position and professional or employment-related information
• Internet or other similar network activity

Where will your personal information be processed?

Our business operations expand globally, with subsidiaries in New York, London, San Francisco, Belfast, Sydney and Pune (India). Your personal information may be transferred or accessible internationally throughout S2W Media's global business per applicable privacy laws and our internal policies. 

From which sources do we get your personal information?

If we do not obtain your personal information directly from you, we may collect it from public sources and professional networking sites, such as LinkedIn. 

How long will we retain your personal information?

We keep your personal information only for as long as necessary to fulfill a specific business or legal purpose. We follow records management and information retention practices to ensure that your personal information is deleted, anonymized, or isolated, whichever is appropriate, after a specified term per the following retention criteria:

• We will keep your personal information for the duration of our relationship with you
• We will keep your personal information for as long as necessary to provide services to you
• We will keep your personal information for as long as required to comply with applicable laws, contractual requirements, and internal policies

What are your rights and choices concerning the processing of your personal information?

The CCPA entitles consumers who reside in California to exercise specific rights regarding the collection, storage, and processing of their personal information. This section outlines your rights under CCPA and describes how you can exercise them.

Disclose to you the specific information we collect about you and your data portability rights

CCPA gives you the right to request us to disclose to you the specific personal information we collected and processed about you over the preceding twelve (12) months. Following receipt and confirmation of your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you
• The categories of sources of personal information we collected about you
• Our business purpose for collecting or otherwise selling the personal information we collected about you
• The categories of third parties with whom we have shared the personal information we collected about you
• The specific pieces of personal information we collected about you (also referred to as a Data Portability Request)
• If we sold your personal information to fulfill a specific business or commercial purpose, we will disclose to you:

            -The categories of personal information that each category of third party purchased

• If we disclosed your personal information to fulfill a specific business, legal, or commercial purpose, we will disclose:

            -The categories of personal information that each category of third party obtained

We do not provide the access rights mentioned above concerning Business-to-Business (B2B) personal information collected by us to fulfill a specific business or commercial purpose. 

We are not required to search for personal information under certain conditions, in which case, in response to your request, we will describe the categories of records that may contain personal information that we did not search for because they meet such conditions.

Request us to delete the personal information we collected about you

Subject to certain exceptions, CCPA gives you the right to request us to delete any personal information we collected from you and retained. Following receipt and confirmation of your verifiable consumer request, and unless an exception applies, we will delete your personal information from our records and direct our service providers to delete your personal information from their records.

Based on our legal rights and obligations, we may deny your deletion request or partially fulfill to:

• Finalize the transaction for which we collected your personal information, provide the services you requested from us, or execute a contract with you
• Detect cybersecurity incidents and data breaches, prevent malicious, fraudulent, or illegal activity, and prosecute individuals responsible for conducting such activities 
• Exercise our right to free speech and ensure the right of other consumers to exercise their free speech rights or any other right provided by law
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)
• Make reasonable internal and lawful uses of your personal information, compatible with the purpose you provided it and based on our relationship with you
• Comply with laws and regulations

We do not provide the data deletion rights mentioned above concerning Business-to-Business (B2B) personal information collected by us to fulfill a specific business or commercial purpose. 

Exercise your data access, portability, and deletion rights

If you choose to exercise the data access, portability, and deletion rights described above and afforded to you under CCPA, please submit a verifiable consumer request via:

Electronic mail at:

info@s2wmedia.com. 

Postal Mail at:

Attn: Data Operations

S2W Media,

71-75 Shelton Street

Covent Garden, London, WC2H 9JQ

Only you or someone legally authorized to act on your behalf may submit a verifiable consumer request concerning your personal information. You may also submit a verifiable consumer request on behalf of a minor. Please, refer to the section titled “Authorized Agent” for more information.

You may make a verifiable consumer request for data access or portability twice within twelve (12) months. 

A verifiable consumer request must include sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information or an individual authorized to request your personal information on your behalf. Our verification steps will vary based on the sensitivity of the requested personal information. The verifiable consumer request must also include a detailed description of your request to enable us to understand, evaluate, respond appropriately, and, if applicable, fulfill it.

We cannot respond to unverifiable requests or provide any personal information unless we can verify your identity or ensure you are authorized to make the request and affirm that the personal information relates to you. 

You are not required to create an account on our website to make a verifiable consumer request. 

We will only use the personal information included in a verifiable consumer request to validate the requestor's identity or authority to make such a request. 

To exercise your right to opt-out of the sale of your personal information, please refer to the section within this Notice titled "Do not sell my personal information."

Our response timing and format

We will make every effort to respond to a verifiable consumer request within forty-five (45) days of receipt. If we determine that the request will require more time to fulfill, we will notify you of the reason and extension period in writing. 

We will deliver our response to your verifiable consumer request in writing electronically or by postal mail at your choice.

Any disclosures provided to you will only cover the twelve (12) months preceding the receipt of your verifiable consumer request. If we cannot comply with your request, our response will explain the reason. 

We will fulfill requests for data portability using readily useable formats to allow you to transmit the information to another entity without limitation. 

Unless excessive, repetitive, or unfounded, we will process and respond to your verifiable consumer requests at no charge. If we determine that your request warrants a cost, we will explain why we made that decision and provide you with a cost estimate before fulfilling the request. 

Authorized Agent

If you are making a verifiable consumer request under CCPA on behalf of a consumer, please submit an authorization letter signed by the consumer to privacypolicy@s2wmedia.com.

Do not sell my personal information

California residents age sixteen (16) or older may request us not to sell their personal information. We do not sell personal information about California consumers we know are under sixteen (16) years of age. 

You can exercise your opt-out rights by submitting a request to privacypolicy@s2wmedia.com  or calling 1-623-552-2721.

S2W Media's "Do Not Sell My Personal Information" link is located at:

https://www.s2wmedia.com/company/do-not-sell-my-personal-information

Exercising the right to opt out of the sale of your personal information does not require you to create an account with us. We will use the information included in your opt-out request to fulfill it. 

Non-Discrimination

We will not discriminate against you for exercising any rights afforded to you by CCPA, including:

• Deny you services
• Charge you different prices or rates for our services
• Imposing penalties
• Provide a different quality of service
• Suggest that you may receive a different price or quality for our services

We may, however, offer you specific financial incentives reasonably related to the value of your personal information, as permitted by CCPA, that may result in different prices, rates, or service levels. Any CCPA-permitted financial incentives will be included in written terms that describe the program's material aspects and will require your opt-in consent prior to receiving them.

California's "Shine the Light" law

California's "Shine the Light" law, Civil Code Section 1798.83, entitles California residents to request and obtain certain information about any personal information we disclose to third parties for direct marketing purposes. To make such a request, please send a written request to the contact details outlined in the section of this document titled "Exercise your data access, portability, and deletion rights"

Changes to our Privacy Notice

We will regularly review and update this Notice to reflect changes to applicable privacy laws and how we handle your personal information. We will notify you of any changes to this Notice by posting updates on our website and modifying the Notice's effective date. Your continued use of our website and services following updates to our Privacy Notice constitutes your acceptance of such changes. 

How to reach us for privacy concerns

For questions or concerns about our privacy practices concerning your personal information, you can contact our Data Operations team via email at info@s2wmedia.com or by mail to:

Data Operations,
S2W Media,
71-75 Shelton Street
Covent Garden, London, WC2H 9JQ

or by phone at:

USA         + 1-623-552-2721
UK            + 44 20 3991 2162
India        + 91 20 662 56 400
Sydney  + 61 2 8279 8638