Privacy Policy

PRIVATE POLICY

Introduction

Broadway National Group LLC (also referred to below as “BWN”, “we”, “us” and “our”) is a privacy conscious organization and is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, BWN is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected by or provided to us through our websites and other online and mobile services (collectively “Online Services”). This Privacy Statement explains how we protect your information gathered via (1) the Web pages of Broadwaynational.com, (2) downloadable applications accessed from mobile devices or (3) any other mode of interacting with you relating to BWN communications, such as online or offline newsletters and publications (“Communication”). By using the Online Services, or continuing to receive Communications, you agree to the use of such information in accordance with this Privacy Statement.

Information Collection

We may collect personal information when you interact with the Online Services, such as if you choose to register or create a user profile on the Online Services (e.g., to gain access to specific content, attend a hosted event, respond to a survey, or request communications about specific areas of interest), or otherwise provide it to us. Depending on the specific Communication you are receiving, or the Online Services you are using, such information may consist of your name, current job title, company address, email address, telephone and fax numbers, correspondence with you, which newsletters you subscribe to, and other information you provide to us. You may also provide us with certain personal and career information in connection with an application for employment with BWN. In some cases, you may have previously provided your information to BWN (if, for example, you are a former employee).

When using certain Online Services, in addition to contact information, we may also collect information relating to your device, including your device model, operating system, browser type, unique device identifier, IP address, mobile phone number, mobile network carrier, location, and the way you are using the Online Services. The information collected will depend on the functionality of the specific Online Services you are using. The collection of this information allows us to customize your online experience; improve the performance, usability, and effectiveness of BWN’s online presence; advertise and market our services; measure the effectiveness of our marketing activities; and generate and analyze statistics about your use of the Online Services. If any other information is collected relating to your use of Online Services, such information will be specified in the Online Service.

We may also collect personal information if you register for the Website using a third-party social network account (e.g., LinkedIn, Facebook, and Twitter). We may collect the username associated with that social media account and any information or content you have permitted the social media network to share with us, such as your profile picture, email address, and birthday. The information we collect may depend on the privacy settings you have with the social network site, so please review the privacy statement or policy of the applicable social network site. When you access the Website through your social network account, you are authorizing us to collect and use your information in accordance with this Privacy Statement.

We do not usually seek to collect sensitive personal information (i.e., data relating to race or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, medical or health conditions, or information specifying the sex life or sexual orientation of an individual) from users. We will, where necessary, obtain your explicit consent to collect and use such information.

Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit the Online Services. This allows the Online Services to remember your computer or device and serves several purposes.

On some of our Online Services, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked using this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.

Although most browsers automatically accept cookies, you may be able to choose whether to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu) or not. You may also be able to delete cookies from your device. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of the features of the Online Services.

Usage Analytics

BWN uses several third-party usage analytics tools including, but not limited to Google Analytics. More information about Google Analytics’ privacy policy can be found here: https://www.google.com/analytics/learn/privacy.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the Online Services or to other web analytics services.

Web Beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. BWN only uses web beacons in accordance with applicable laws.

BWN or its service providers may use web beacons to track the effectiveness of third-party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to maintain and improve the Online Services.

Social Media Widgets and Applications

The Online Services may include functionality to enable sharing via blogs, forums, wikis, and third-party social media applications (such as the Facebook Like button and Twitter widget) or allow you to use a social media identity to log into our Online Services where you have the option to do so. These social media applications may collect and use information regarding your use of the Online Services. Please be aware that certain of the personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

Information Use

We collect and use your personal information with your consent to provide you with access to the Online Services and Communications, or where we have a legitimate business interest in or other legal basis for, such collection and use. The personal information you submit to us may be used to manage our relationship with you, including any of your requests, or to customize or improve the Online Services and/or related services offered to you.

We may also use your personal information for marketing purposes, or to send you promotional materials or communications regarding services provided by us or other members of the BWN Team that we feel may be of interest to you. We may also contact you to seek feedback on services provided by members of the BWN Team or for market or other research purposes. Your personal information may also be used to protect our rights or property and that of our users.

You may, at any time, request that we discontinue sending you Communications, emails or other correspondence not directly connected to the services for which you have engaged the BWN Team. You can unsubscribe at any time by following the instructions included in each communication or contacting us at [email protected].

Disclosure of Information to Third Parties

We may provide your personal information to other members of the BWN Group in order to provide you with information that could be of interest to you and conduct market or other research. Your personal information may also be disclosed to members of the BWN Group and other third parties to respond to your requests or inquiries; as part of a corporate transaction (such as a sale, divestiture, reorganization, merger, or acquisition); or where those parties handle information on our behalf.

Personal information may also be disclosed to law enforcement, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.

• In relation to Online Services, we may share your usage and personal information with mobile carriers and platform providers, as well as any other entities described in any Online Service in connection with the operation of the Online Service.

• In relation to Communications, we may share your personal information with service providers in connection with the delivery of such Communications.

All these disclosures may involve the transfer of personal information to countries or regions without data protection rules like those in effect in your area of residence.

By providing information with respect to a Communication or through Online Services, you are consenting to the disclosures described above.

Privacy Practices of Third Parties

This Privacy Statement only addresses the use and disclosure of information collected by BWN through your interaction with the Online Services and through other interactions with BWN relating to a Communication. Other websites or mobile apps that may be accessible through links from the Communication or Online Services have their own privacy statements and personal information collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information.

Information Retention

We retain personal information as necessary for the duration of the purpose outlined in this Privacy Statement. Notwithstanding the duration of the purpose, we may retain your information if necessary to comply with our legal or professional obligations, enforce our agreements, or resolve disputes.

Rights to Access and Control your Personal Information

You have choices about how your personal information is collected, used, and shared.

If you have submitted personal information to BWN, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to review, update or remove information about you and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. To request access to or correction, updating, or removal of your personal information please click here.

Special Notices to California Residents

In response to California law, if you are a California resident, you are entitled to request information concerning whether your personal information has been disclosed to nonaffiliated third parties for their direct marketing purposes. We do not share your personal information with nonaffiliated third parties for such purposes.

Do Not Track

“Do Not Track” is a preference you can set in your Web browser to let the websites you visit know that you do not want them collecting information about you. The Website does not currently respond to a “Do Not Track” or similar signal. We do not engage in the collection of personal information about your online activities over time and across third-party websites or online services to provide targeted advertising and we do not allow third parties to collect such personal information when you use the Website.

Information Security and Integrity

We have in place reasonable commercial standards of technology and operational security to protect all personal information provided by users with respect to Communications, or via the Online Services, from unauthorized access, disclosure, alteration, or destruction.

BWN also has and requires its service providers to have security policies and procedures in place to help protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite our efforts, however, security cannot be guaranteed against all threats. We seek to limit access to your personal information to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

Children’s Privacy Protection

We understand the importance of protecting children’s online privacy. Communications, the Online Services are not designed for or intentionally targeted at children under the age of 13. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. If we obtain actual knowledge that we have received such information, we will take steps to delete it.

Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. BWN LLP aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data, we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Data.

• The right of restriction. You have the right to request that we restrict the processing of your personal information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where BWN relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Changes to our Privacy Statement

We may modify or amend this Privacy Statement from time to time at our discretion. When we make changes to this Privacy Statement, we will amend the revision date at the top of this page and such modified or amended Privacy Statement shall be effective as to you and your information as of that revision date. We encourage you to review this Privacy Statement periodically to view any updates.

Contact Information

If you have any questions or concerns regarding your privacy while using the Online Services, or upon receipt of a Communication, please contact us. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.