BrightTALK™
PRIVACY POLICY

(date of last revision: 2 April 2012)

1. INTRODUCTION

BrightTALK™ recognises that privacy is important when using the Web for communications. This policy explains how BrightTALK collects, stores, uses and shares personal information and information about your visits to the network, including the pages you view, the links you click and other actions taken in connection with any Web site with the brighttalk.com domain (the "Site") which is owned by BrightTALK. For the purposes of this Privacy Policy, BrightTALK means collectively BrightTALK Inc and BrightTALK Ltd and from time to time any subsidiary corporations, successors and assigns. Personal information is information from which you can be personally identified, such as your name, address, email address, or telephone number, and demographic or other information about you when such information is tied to personally identifiable information. Personal information does not include "aggregate" information, which is data we collect about the use of the Site or about a group or category of products, services or users, from which individual identities or other personal information has been removed. It is important that you read and understand this Privacy Policy ("Policy"). You must accept all the terms and conditions of this Policy and the User Agreement before accessing any service provided on, through or by the Site ("Services"). If you do not accept the terms and conditions of this Policy, then you cannot access the Services.

BrightTALK may update this Policy at any time. In the event there are material changes in the way we treat your personal information, we will notify you by email. Unless stated otherwise, our current Policy applies to all personal information that we have about you and your account. This policy in no way restricts or limits our collection and use of aggregate information.

Minors under the age of eighteen years old are not eligible to use the Site and we therefore ask that minors do not submit any personal information to us or use any of the services provided on, through or by the Site (the "Services").

If you have questions or concerns regarding this Policy, please contact BrightTALK at the address below.

2. PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

Under California law, customers who are California residents are entitled to annually request and obtain information about the personal information we shared, if any, with other businesses for their own direct marketing. If applicable, the information would include the categories of personal information and the names and addresses of those businesses with which we shared personal information for the immediately prior calendar year. To make such a request, please send a written request to The Secretary, BrightTALK Inc., 501 Folsom Street, San Francisco, CA 94105, USA. Please note that not all information sharing is covered under the California law, and only information on covered sharing will be included in our response.

3. DATA PROTECTION FOR EUROPEAN RESIDENTS

For the purposes of the UK Data Protection Act 1998 (the "Act"), the data controller is BrightTALK Limited of Cedar House, Breckland, Linford Wood, Milton Keynes, Buckinghamshire, MK14 6EX.

4. INFORMATION COLLECTED

4.1 Personal Information

We may collect certain information you voluntarily provide to us which may contain personal information. For example, to set up a brighttalk.com account you are required to complete the registration process. This process requires you to provide certain personal information such as your name, email address, telephone number, company name and job title as well as information about your company such as country and industry sector. We may also collect user profile information such as age, gender, postcode, survey responses, voting choices and areas of special interest to you.

If you choose to become a Channel Owner (for the purposes of this Policy, "Channel Owner" means someone who sets up, manages, and populates a Channel, and "Channel" means an embeddable webinar player on which the Channel Owner can provide Subscribers with access to upcoming, live and recorded webinars), a Sponsor (for the purposes of this Policy, Sponsor has the meaning given in paragraph 4.2 below) or to subscribe to a paid for service, we will ask for additional information such as your credit card details and/or billing details.

4.2 Cookies

In common with standard industry practice, BrightTALK uses cookies to track site usage. A cookie is a small text file containing a unique identification number that is placed on the hard disk of your computer by a Web page server, enabling the Web server to identify your web browser and passively track its activities on that website. Cookies do not contain any executable code and cannot be used for infecting your computer with a virus. Most Web browsers automatically accept cookies but usually provide the option of configuring your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. You can change your settings in the preferences or options menu of your browser. If you choose to decline cookies, certain features of our Services may not be available to you.

The table below explains the cookies we use and their purpose.

BRIGHTTALK COOKIES

CookieCookie NamePurposeType
BT Session Cookie BTSESSION Persistent cookie. For users that do not log in, tracks anonymous webinar viewings and uses user IP address to estimate user time zone so event times can be shown in local times for that user. For users that do log in, enables Site to be personalised based on log-in information. Persistent cookie. Duration from 90 days, dependent on user activity on Site.
BT Login Info Cookie BTLOGININFO If a user attempts to view content when not logged in, this cookie is used to enable user to be automatically redirected back to the desired content following login. Persistent cookie. Expires after one hour.
Campaign Tracking Cookie BTREDIRECT Anonymously tracks visits to Site in direct response to email campaigns Persistent cookie. Expires after 14 days or upon user login if earlier.
Symfony Portal Session Cookie PHPSESSID Manages session for logged in user, enabling access according to authorisation level. Standard PHP Session cookie, deleted when browser closed.

THIRD PARTY COOKIES

CookieCookie NamePurposeDuration
Marketo Tracking _mkto_trk Anonymously tracks, creating anonymous tracking records. Persistent cookie. Variable duration set by Marketo, Inc.
Google Analytics _utma _utmb _utmc _utmz These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come from and the pages they visited. _ utmc is a session cookie The others are persistent cookies whose duration is set by Google. Further information can be found in the Google Analytics Overview within the privacy section on www.google.com .

4.3 Web Beacons

Web beacons, sometimes called single-pixel GIFs, are small electronic image files that we may place on the Site Web pages and within certain email. Combined with cookies, Web beacons allow us to count the number of unique users who have visited a specific page and the number of times those pages are displayed. We can also use Web beacons to let us know how many people opened certain types of email. Information we may collect using Web beacons will be in aggregate form only and will not contain your personal information. Third party advertisers may use Web beacons in their advertisements on BrightTALK Web sites. This enables us to compile aggregated statistics and determine the effectiveness of promotional campaigns. We do not allow Web beacons on our Web sites to be used by third parties to collect or access your personal information.

4.4 Log Information

When you use the Site, our servers record, in a server log, information that your browser sends whenever you visit a website. Server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

4.5 User Communications

When you send email or other communication to BrightTALK or another user, we may retain those communications in order to process your enquiries, respond to your requests and to improve our services.

4.6 Affiliated Sites

We may offer services in connection with other Web sites or suppliers. Personal information that you provide to those sites may be sent to us in order to deliver these services. We process such information in accordance with this Privacy Policy.

5. USE AND SHARING OF INFORMATION

5.1 BrightTALK’s Use of Information

BrightTALK collects and uses your personal, profile and activity information (together referred to as "Profile Information") as described in this Policy, to operate and improve its services, to carry out the transactions you request, to provide you with information you request or to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use, and our administration, of the Site, and for the purpose for which the information was provided. These uses may include making our services easier to use by eliminating the need for you to enter the same information repeatedly, for research and analysis to improve our services and technologies, to display customised content and advertising, to contact you in connection with your enquiries, surveys, your Account or to deliver promotional material, and to provide anonymous reporting to BrightTALK Content Owners.

BrightTALK may store and process personal information collected on the Site or other BrightTALK Web sites in locations in which BrightTALK or its affiliates, subsidiaries or agents maintain facilities, and by using a BrightTALK service, you consent to any such transfer, if necessary to provide our services, of your information outside your country and the European Economic Area.

5.2 Sharing of Information

BrightTALK does not share or sell your Profile Information with third parties or non-affiliated companies except to provide the products or services you have requested, when we have your permission, or under the following circumstances:

When you attend or view content in a Channel, you will automatically be subscribed to that Channel (a "Subscription").  When you attend or view a Channel, Summit, a webinar, a video or other content, BrightTALK may share your Profile Information including your email address and telephone number (as well as details and viewing times of the content you have viewed on that Channel, Summit, webinar, video or other content) with that Channel Owner or with the Sponsor of that Summit or webinar or owner of the content viewed (each a "Content Owner"). For the purposes of this Policy, "Summit" means a collection of various webinars on a particular topic that may include webinars from more than one Channel, and "Sponsor" means someone who sponsors a BrightTALK Summit or webinar or other content in exchange for brand promotion, thought leadership opportunities, and the leads generated from the Summit or webinar audience where applicable. In attending or viewing a Channel, Summit, webinar, video or other content, you consent to our sharing your Profile Information with the Content Owner who may use such information to provide you with marketing messages, and we encourage you to review the Content Owner"s own Privacy Policy to ensure you are satisfied with the provisions. BrightTALK does not control or limit, and we are not responsible for, the activities of Content Owners in the use, control and protection of personal information. We may provide your Profile Information including your email address and telephone number to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing Profile Information on our behalf. These parties are required to process such information based on our instructions and in accordance with this Policy. They do not have any independent right to share this information. We may share your personal information with a credit checking company or with a credit card processing company to bill users for our services. These third parties do not retain, share, or store any personally identifiable information except to provide these services and are bound by strict confidentiality requirements which limit their use of such information. We may disclose such personal information to satisfy any applicable law, regulation, legal process or enforceable government request, to enforce our User Agreement and investigate violations thereof, to prevent, detect and address fraud, security or technical issues, or to protect against harm to the rights and property of BrightTALK and its users as required or permitted by law. We may disclose or transfer your Profile Information if BrightTALK is acquired by or merged with another company or in the event of a sale of company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of BrightTALK. We will provide notice before this occurs and will post a new Privacy Policy if necessary. Sharing your Profile Information in the circumstances described above may involve your personal information being transferred outside your country and the EEA and in accepting this Policy and using the Services you consent to any such transfer.

6. ACCESSING AND AMENDING YOUR ACCOUNT INFORMATION

You can amend your account information and/or cancel your Subscription at any time by visiting your account page on the Site. If you cancel your Subscription we will remove your personal details from the subscriber base for that Channel, but if your personal information has been previously shared with a Content Owner, you will need to contact the Content Owner directly to request your information be removed from its database. You can close your account in accordance with our User Agreement. If you close your account, we may retain your personal information but only for the purposes of preventing fraud or future abuse, enforcing our User Agreement, protecting against harm to the rights and property of BrightTALK and its users, and if required or permitted by law. All retained information will continue to be subject to the terms of this Policy. You have a right under the Act to access information held about you, subject to an administrative fee to meet our reasonable costs. You may also ask us to stop processing your personal information at any time.

7. SECURITY

To secure your personal information, access to your data is password protected, and sensitive information is protected by encryption when it is exchanged between your Web browser and our Web site. It is your responsibility to keep your password confidential and not to share this information with anyone. To protect data stored on our servers, we regularly audit our system for possible vulnerabilities and attacks and we use only secured access tier 1 data centres.

Whilst we will implement the security measures detailed above, transmission of information via the Internet is not completely secure and therefore transmission via the Internet is at your own risk.