PRIVACY STATEMENT
Last updated: 1 October 2023

1 Introduction

Valsoft Corporation Inc. (“Valsoft”) and each of its affiliates (collectively, the “Valsoft Group”) is committed to safeguarding your privacy and personal data. This privacy statement describes why and how we collect, use and share your personal data, our legal bases for processing your personal data, how long we keep your personal data, how we protect your personal data, the countries to which we may transfer your personal data and your rights regarding your personal data. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
If you provide personal data to us relating to other individuals, you must first provide those individuals with information about your disclosure to us and establish a lawful basis for such disclosure, to the extent required by applicable law. You are also responsible for communicating the terms of this privacy statement to them.

2 About us

Valsoft Group is an international corporate group that acquires and develops vertical market software companies, enabling each business to deliver the best mission-critical solutions for customers in their respective industries or niche. Valsoft Group has operations in the UK, EU/EEA, Canada, North and South America, Australia and Asia and offers products and services globally. Each Valsoft affiliate is a separate legal entity and a separate controller for personal data. This privacy notice is issued on behalf of the Valsoft Group so when we mention “Valsoft” (or “we”, “us”, or “our”), “in this privacy statement, we are referring to the Valsoft Group corporate entity which is responsible for processing your personal data.
Sometimes, we are the processor of personal data collected by/on behalf of our customers and/or their clients, which we process as part of our products and services provision – this privacy statement does not apply to such processing.

To find out more about our specific processing activities, please see “Details of our Data Processing” section below.

3 How to contact us/exercise your rights

Irrespective of your location, if you have any questions about our processing of your personal data, or if you would like to exercise your rights , please contact us at privacy@valsoftcorp.com . We will then ensure that your request is directed to the appropriate office and department. You may also contact our Valsoft Group DPO, David Felicissimo, General Counsel at privacy@valsoftcorp.com.

4 What personal data we collect

Our products and services (“Services”) are made available by various companies in Valsoft Group. In providing our websites (“Sites”) and our Services (whether through the Sites or otherwise), we may collect and process different types of personal data about you for different processing purposes and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
Personal data is any information relating to an identified or identifiable living person. When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data.
We may, in the course of and in relation to the provision of our Services or Sites, process the following non-exhaustive list of personal information about you:
We only collect Special Requests Data to ensure that you have the best experience at our events. This information may allow inferences regarding your religion or health but is not shared with any third parties in a specifically identifiable way, unless it is absolutely necessary to do so.

For more information on the specific personal data collected by us, please see the “What Data” column of the “Details of our Processing Activities ” section below.

5 Who we collect personal data about

We collect and process personal data from the following people:

6 How we collect and receive personal data

We use different methods to collect data from and about you including through:

7 How we use your personal data

We will only use your personal data when applicable data protection laws allows us to. We only use your personal data for the purposes set out in this section or for a compatible purpose, if we reasonably consider that we need to use it for that purpose and that reason is compatible with the original purpose. If you would like an explanation of our analysis, please contact us at privacy@valsoftcorp.com . If we wish to make any changes to the purposes set out in this section or use your personal data for any purpose which is not listed in this section, we will notify you. The main purposes for which we use your data are to:

Please see the “Details of our Processing Activities ” section below for more details on the purposes for which we use your data and the legal bases on which we rely.

8 If you fail to provide personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform that contract or one we are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us. In these circumstances, we may have to cease out interactions with or the provision of the relevant Services to you, in which case we will notify you.

9 Sharing your data

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with data protection, confidentiality and security requirements under applicable data protection laws.
When processing your personal data, we may need to share it with third parties, as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

10 International Transfers

As an international business and in common with other international software businesses, we use third parties located in other countries to help us run our business and we may share personal data with other companies within the Valsoft Group who may be located in other countries. As a result, personal data may be transferred outside the United Kingdom (UK) and/or European Economic Area (“EEA”). If this happens, we remain responsible to you for the transfer, processing and storage of your personal data.
Non-EEA/UK countries may not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data.
When transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.
When transferring your personal data outside the UK or the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented: (1) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data or have a system of certification pursuant to which transfers of personal data to participating organisations are deemed adequate by the European Commission and/or the UK Government (as applicable). Such systems of certification may include the EU-US Data Privacy Framework adopted pursuant to European Commission Implementing Decision of 10 July 2023, the UK Extension to the EU-US Data Privacy Framework adopted pursuant to The Data Protection (Adequacy) (United States of America) Regulations 2023, and any analogous frameworks or certification schemes adopted by the applicable governmental or regulatory body under applicable law; or (2) where we use certain service providers, we may use specific contracts approved by the UK Government or the European Commission referred to as the “Standard Contractual Clauses” or “SSCs” which give personal data the same protection it has in the UK and EU. For certain ad hoc transfers we may rely on other exemptions such as the transfer is necessary for the performance of a contract with you.
To find out more about the SCCs we use, please see: Standard contractual clauses for international transfers | European Commission (europa.eu) or please contact us at privacy@valsoftcorp.com if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.

11 How long we keep your personal data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years. Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights. If any personal data is only useful for a short period (e.g. for a recruitment activity or marketing campaign), we will not retain it for longer than the period for which it is used by us. If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

12 Security

We are committed to keeping the personal data you provide to us secure and we have put in place appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need. They will only process your personal data on our written instructions, and they are also subject to a duty of confidentiality and contractual obligations to implement appropriate security measures in relation to the protection of your personal data. We have also implemented procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are required to do so.

13 Children’s data

Valsoft does not collect children’s data except as part of engagements in which it provides professional advice relating to children. Our Sites are not designed to be used by children under the age of 18. Children under the age of 18 are discouraged from entering any personal data on our Sites. Please contact us at privacy@valsoftcorp.com if you have reason to believe that a minor may have submitted personal data to us unintentionally.

14 Your rights

Depending on where you are based, you may have the following rights in relation to the personal data we process about you:
If you wish to exercise any of the rights set out above, please contact us at privacy@valsoftcorp.com . Please note if you are located in other jurisdictions, additional/alternative rights may apply.
Furthermore, you have the right to have us remove you from our marketing distribution lists at any time. If you currently receive marketing information from us that you would prefer not to receive in the future, please e-mail us at privacy@valsoftcorp.com.

When contacting us in connection with any of your rights (describe above), you may need to provide sufficient identifying information to us before your request can be processed. This information may include your name, address, birth date or other means of identification as appropriate in each case. We may limit or deny access to personal data where permitted by applicable law.

You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Contact details for the UK’s ICO can be found on its website at https://ico.org.uk

15 Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we keep this privacy statement under regular review and may need to make changes to it from time to time, including to reflect any changes to our use of your personal data. Please check this statement regularly to ensure that you are familiar with its content.

16 Details of our Processing Activities

Processing Activity

To provide you with our Services and Sites

Activity

What Data

Why?

Lawful Basis

Provision of our Services

Services Data

Identity Data

Contact Data

Financial and Transaction Data

To enable us to engage you as a new customer or to consider engaging you as a new customer.

To process and deliver our Services including:

a) manage payments, fees and disbursements; and

b) collect and recover money owed to us.

To enable you to receive our Services.

To maintain our user databases.

To keep a record of how our Services are being used.
Necessary to perform our obligations in accordance with any contract that we may have with you.

Necessary for our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we:

(a) provide our Services in an effective, safe and efficient way; and

(b) recover debts due to us.

Site browsing

Behavioural Data
Technical and Usage Data

To help us understand how you are using and navigating our Sites. We do this so that we can better understand which parts of our Sites are more or less popular and to improve the structure and navigation of our Sites.

This data is sometimes automatically collected and transmitted to us.

Necessary for our legitimate interest to enable us to provide our Sites in secure and effective way and make improvements to the Sites.

Social media interaction

Behavioural Data
Technical and Usage Data

To gain insight into your interaction with our social media pages such as on LinkedIn, Facebook, Twitter/X, Threads or Instagram or similar social media platforms (“Social Media Platforms”) (including interacting with any ‘like’ or similar embedded features on our Sites and/or our Social Media Platform accounts).

Necessary for our legitimate interest to ensure that we provide the Sites in an effective way and to promote our Sites and Services via Social Media Sites.

Manage our relationship with you

Services Data

Identity Data

Contact Data

Profile Data

Marketing and Communications Data

Target Data
To manage our relationship with you, for example in order to:

a) notify you about changes to our terms or privacy notice;

b) notify you about changes to event dates, locations or related services;

c) communicate with our customers and potential customers on administrative matters; and

d) communicate with you re transactions we are contemplating and/or undertaking.
Performance of a contract with you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services).

Visiting our offices

Identity Data

Image Data

Special Requests Data

Incident Data
To keep our premises secure and provide a healthy and safe environment for and to provide appropriate access to our premises for personnel and visitors and where applicable, to report or log a health and safety incident you may have suffered or assisted us with or to report an occupational disease.

We have security measures in place at our premises, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need-to-know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).

We may require visitors to our premises to sign in on arrival and we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).
Necessary for our legitimate interest so that we can keep our premises secure and provide a safe environment for our personnel and visitors to our premises and where applicable, manage an incident, for analysis purposes and to help us improve our event/incident management processes.

Necessary to comply with a legal obligation.

Explicit consent (in respect of any special category data collected (e.g. health data).

Event management/ promotion

Identity Data

Contact Data

Special Requests Data

Image Data
To register you as a visitor or exhibitor at one of our events. If you are a speaker at our event, we will publish your name in association with the event.

To enable you to travel abroad to attend certain events if you are a speaker or exhibitor.

To make other logistical arrangements with you in connection with your attendance at the event (e.g., in respect of your exhibitor space).

Photographs and video material at our events may be taken and published for promotional and advertising material.

We may send you SMS for operational purposes and the smooth running of an event, e.g., to inform of a travel update.
Performance of a contract with you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interest to provide information about speakers at an event.

Necessary for our legitimate interest to promote our events. You can opt out of your image being used at any time.

Necessary for our legitimate interest to provide you with necessary information about shows you are attending.

Explicit consent (in respect of any special category data).

Event health and safety

Identity Data

Contact Data

Special Requests Data

To report or log a health and safety incident you may have suffered or assisted with.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to manage an incident, for analysis purposes and to help us improve our event/incident management processes).

Explicit consent (in respect of any special category data).

To provide customer service, deal with customer queries, carry out research or surveys and obtain feedback to improve our Services

Customer service and enquiries

Services Data

Identity Data

Contact Data

Profile Data

Financial and Transaction Data

Behavioural Data

Technical and Usage Data
To manage and respond to your enquiry.

If you have a technical issue concerning our Sites, we may also collect and process Behavioural Data and Technical and Usage Data to help us diagnose the issues and resolve them in an efficient way.

Necessary for our legitimate interest so that we can help you with your enquiry, provide a good standard of service and improve our Services and customer service.

Research, surveys and feedback

Identity Data

Contact Data

Marketing and Communications Data

Profile Data
To undertake research to help us to monitor and improve our Sites and Services.

To assist with the selection of future Service lines and to train our personnel.
Necessary for our legitimate interest:

(a) so that we can improve our Services and provide them in an effective way; and

(b) to research and study how customers use our Services, to develop them and grow our business.

To carry out insights and analysis

Insight & analysis through cookies and other similar tracking technologies

Behavioural Data

Technical and Usage Data

Profile Data
To analyse how you use or interact with, and the effectiveness of, our Sites and our Services and other communications which helps us to improve our Sites and Services and the effectiveness of our communications, as well as to remember your preferences.

In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Where your data is collected through the use of non-essential cookies, we rely on your consent to collect your personal data and for the onward processing purpose. Please see our Cookie Settings for further details.

In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Sites, it is in our legitimate interest to use your personal data in such a way to improve our Sites and our Services.

To carry out our promotional and marketing activities

Marketing

Identity Data

Contact Data

Marketing and Communications Data

Profile Data

Behavioural Data

To send you marketing communications via email about our Services where we have a lawful basis to do so.

To make suggestions and recommendations to you about services that may be of interest to you.

Where we are sending you personalised marketing, we may also use Profile Data, and Behavioural Data to help us decide what sort of personalised marketing to send you.
Consent

Necessary for our legitimate interest to decide what marketing content we think may appeal to you and ensure our marketing is most effective.

Social media advertising

Contact Data

Behavioural Data

Technical and Usage Data
We may share your data with third party providers of Social Media Platforms to “match” your data with the data of their registered users on their Social Media Platforms in order to serve relevant advertising to you.

Please note that the Social Media Platforms may also collect information about your interaction with our Platforms directly through their own tags or tracking technology. Please see our Cookie Settings for more information.

Necessary for our legitimate interest in order to promote our Services, events and brand. Please note you can opt out of this sharing at any time by contacting us at privacy@valsoftcorp.com. You may also opt out of receiving relevant advertising by amending your preferences on the relevant Social Media Platform.

Where Social Media Platforms collect your data directly, they will rely on your consent to do so.

For business administration (including recruitment), legal/regulatory compliance and to consider and/or undertake transactions that benefit our business

Business administration and legal and regulatory compliance

Services Data

Identity Data

Contact Data

Profile Data

Financial and Transaction Data

Behavioural Data

Technical and Usage Data

Image Data

Public Data

Recruitment Data

Special Requests Data

Marketing and Communications Data

Target Data

To comply with our legal obligations.

To enforce our legal rights or defend potential legal claims.

To protect the rights of third parties.

To facilitate a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Necessary for our legitimate interests (in order to operate our business in an effective manner).

Necessary to comply with a legal obligation.

Receipt of products and services from our suppliers

Identity Data

Contact Data

Recruitment Data

Public Data

Special Requests Data
To assess your suitability for any of our positions that you apply for whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf.

To communicate with you about the recruitment process.

To keep records about our recruitment process.

To comply with our legal and regulatory obligations in relation to recruitment.

To review our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by applicable laws. All employment-related decisions are made entirely on merit.
Performance (or entering into) of a contract with you.

Necessary for our legitimate interest to ensure that we can make the best recruitment decisions.

Contemplation /completion of transactions

Target Data

Identity Data

Contact Data

Public Data
To assess the viability of any transaction.

To undertake due diligence on a potential target company.

To complete the transaction and documentation processes.

To communicate with the target company and its professional advisers about the due diligence and/or transaction process.

To keep records about our transaction related activities and investigations.

To comply with our legal and regulatory obligations in relation to any potential transaction/completed transaction.
Performance of (or entering into) a contract with you.

Necessary for our legitimate interest to ensure that we can make the best acquisition-related decisions and grow and develop our business.

Necessary to comply with a legal obligation.

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