You should read this Policy before you submit any personal information to us. By using our Sites or registering your interest in Procurement Leaders online, you consent to the collection and use of your personal information as outlined in this Policy. If you do not agree with the content of this Policy, you should not use our Sites. If you have any questions or concerns relating to Sigaria’s site and/or data protection, please e-mail firstname.lastname@example.org.
1.Who we are:
Sigaria, which owns and operates the Sites, has its principal place of business at Third Floor Prospero House, 241 Borough High Street, London, SE1 1GA, UK. We also have a business presence in Denver, USA. More information about Sigaria and its network of Programs can be found at www.sigaria.com.
2. Personal information we collect
In General. We may collect and store any personal information you enter on our website or provide to us in some other manner. Personal information is data that identifies you, or that can be combined with other information to identify or contact you, and includes (but is not limited to) your name, business or personal email address, job title, organization, organization’s address, direct telephone number, photograph, and biographical details. You are not obligated to provide us with any personal information, although you may need to provide some information to register as a member, or engage in other transactions on our Site. We aim to limit the type of personal information that we collect to information that helps us provide first-class services for the benefit of our existing and prospective Members.
Members. If you are a member of Procurement Leaders Network and access the restricted, Members only areas of our Sites, Sigaria may collect additional information relating to your participation in Procurement Leaders Network products/ programs. We also may obtain information about your access and use of Procurement Leaders research materials, decision-support tools, and other online and offline products and services.
Information from other sources. We also may periodically obtain both personal and non-personal information about you from other sources. Examples of information we may receive includes updated contact information and additional demographic information. Please note that Sigaria may have previously collected personal information relating to you at the time you or your organization enrolled in a Procurement Leaders product/ program, as well as in the course of allocating and issuing to you your unique ID and password to access the Members-only areas of our Sites.
- Cookies. When you visit our Sites, we may assign your computer one or more "cookies." A cookie is a small text file that contains information that can later be read by us to facilitate your access to our Sites and personalize your online experience. For example, whenever you sign into our Sites, we will record your user ID in a cookie file on your computer. If applicable, we may also record your password in this cookie file, if you checked the box entitled "Save this password for automatic sign-in." Also, through the use of a cookie, we may automatically collect information about your online activity on our Sites, such as the web pages you visit, the links you click, and the searches you conduct. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our Sites.
- Other Technologies. We may use standard Internet technology, such as Web beacons (also called clear GIFs or pixel tags) and other similar technologies, to deliver or communicate with cookies and track your use of our Sites. We also may include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer and measure the overall effectiveness of our online content, advertising campaigns, and the products and services we offer through the Sites.
3. How we use the information we collect In General. Sigaria uses the information we collect about you for the following purposes:
- to respond to inquiries that you submit to us about Procurement Leaders membership via the online "contact us" feature and determine which Programs and services will help you achieve your business goals;
- to send you membership details and information about Procurement Leaders Products and services that you have requested from us;
- to administer your membership and facilitate your access to and provide you with Procurement Leaders resources, decision-support tools, and other materials available to you through your Program subscription;
- to attribute content that you make available through the Sites;
- to communicate with you about surveys, marketing, promotions, executive-oriented events, educational forums, and other exclusive opportunities offered by Sigaria and its partners and affiliates, including information about other Procurement Leaders products in which you may be interested;
- for the purposes for which you provided the information;
- to customize the advertising and content you see, including the display of targeted advertisements;
- to engage in research and analysis in order to maintain, protect and improve our Programs and services, as well as develop new services;
- to generate anonymous and/or aggregated reporting;
- to enforce the legal terms that govern your use of the Sites;
- to enhance the Procurement Leaders network and Procurement Leaders products and services; and to ensure the technical functioning of the Sites.
Disclosing your Information to Sponsors
We may disclose your data and sensitive data to third party Sponsors where you have downloaded a whitepaper from that Sponsor or you have subscribed to attend an event where Sponsors are present. Please note whilst our Sponsors agree only to use your data for marketing purposes in respect of the event or whitepaper, we have no direct control over the third party Sponsors and shall not be liable for how they process your data. By downloading a white paper or purchasing a subscription to attend an event you hereby consent and agree to the processing of your data in accordance with this clause.
Community Areas. In certain Community Areas on the Procurement Leaders Sites, Members can tap into our membership directory and locate other Members able to help them deal with specific questions and challenges. To participate in these Community Areas, Members are asked to create an online profile, which includes information about their job and title. This profile enables other Members participating in the same Community Areas to determine whether the Member’s background and expertise might make him or her a useful contact on a particular issue. When you participate in Community Areas by creating an online profile, you are making information about you (including contact and institutional information) available to other Members. Based on this determination, one Member might use another Member’s information to contact that Member to obtain the benefit of their expertise. By providing personal information for publishing to a profile in Community Areas, you acknowledge and agree that Members can see and use that information, and that their use (and any use by third parties to whom they disclose the information) is not subject to the terms of this Policy.
Discussion Forums. In the event that you post personal information in discussion forums or other areas of the Sigaira Ltd Sites allowing users to upload or post content, that information can be viewed by any user with access to those areas. We discourage users from posting personal information in this fashion, and any personal information you post to these public or Member areas is not covered by this Policy.
4. Choices about the uses of your information
Sigaria believes that it is important that individuals are given the opportunity to exercise choice with respect to how their personal information is collected and used. If we propose to use your personal information for any purposes other than those described in this Policy or any service-specific privacy notices, we will allow you a convenient way to opt-out of such further uses. Marketing Communications: We hope you find value in the communications we provide, and we will respect your wishes not to receive marketing communications. Please note that we will continue to send you member services emails and other service-related communications regardless of any such request. These service-related communications are an integral part of the Procurement Leaders Products to which you subscribe. Sigaria will not share your information and personal details with third parties for their own promotional or marketing purposes, without giving you a choice about such sharing.
5. Disclosures of personal information Sigaria may share your personal information with other companies or individuals in the following instances:
- When we engage service providers and third-party agents to process personal information on our behalf. When we do so, Sigaria requires that these service providers implement adequate technological and organizational security measures before they can receive any persona information from us.
- For legitimate business purposes connected with the provision of Sigaria goods, services, and benefits for executive customers. Where information is shared with a third party for a
legitimate business purpose, Sigaria will seek reasonable assurances from that third party that the personal information will be processed for legitimate reasons and appropriately protected.
- In response to court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
- When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Sigaria, our customers, or others; and in connection with our Terms of Service and other agreements.
- In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
We also may share aggregate or anonymous information with third parties, including advertisers, investors, and partners. Aggregate or anonymous information does not contain any personal information, and its use and disclosure is not subject to the terms of this Policy.
6. International transfers of personal information
Sigaria operates the Sites in the United Kingdom and, depending on your country of residence, the submission of personal information to our Sites may involve some transfer of personal information to the United Kingdom. In addition, we may transfer personal information to our affiliate company in the United States for certain processing operations. You should be aware that privacy laws in the United Kingdom and the United States may not provide protections equivalent to those of your country of residence. Sigaria has taken steps to ensure that appropriate levels of protection necessary to maintain the security and quality of your personal information are in place and that any transferred data is processed only in accordance with this Policy.
7. Access and correction of personal information
You can request access to any personal information that we hold about you and ask us to correct any personal information which may be inaccurate, except where the law requires otherwise. To access, correct or raise inquiries concerning your personal information in our possession, please contact: Chief Compliance Officer, Sigaria, Third Floor Prospero House, 241 Borough High street, London, SE1 1GA email@example.com. In some cases, Procurement Leaders Members can directly access their online profiles and other personal details, enabling them to amend, update or add information by themselves at any time by logging into the relevant Program webpage.
8. Information security
Sigaria has implemented reasonable technical and organizational security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information. Unfortunately, no data transmission over the Internet can be guaranteed to be entirely secure, and Sigaria assumes no liability for any damage suffered by you caused by the interception, alteration, or misuse of information during transmission. Within Sigaria, we make reasonable efforts to restrict access to personal information to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Programs and services. We subject our third-party agents to contractual controls to ensure that they apply suitable protections to any personal information they access or receive from us. Please note that the effective security with respect to our Sites depends, in part, on our Members ensuring that any IDs and passwords that they have been issued by us are kept confidential and secure and that Members adhere to the restrictions on password and ID-sharing set forth in our Terms of Service.
9. Other websites
To provide increased value to users of our Sites, we may provide links to other websites or resources that are not part of the Procurement Leaders network of Programs. Sigaria does not exercise control over these websites or their privacy practices, and any information you provide to those sites is subject to the Privacy Policies of those sites, and not this Policy.
Our Sites contain business-related content and are specifically aimed at and designed for use by adults. Sigaria does not knowingly solicit or collect personal information from or about individuals under the age of 18 years.
11. Changes to this policy
This Policy may change from time to time. If we make material changes to this Policy, we will post any Policy changes on this page. If we feel it appropriate, we will provide a more prominent notice (including, for certain services, email notification). Your continued use of our Sites following such posts or notices will signal your acceptance of such changes.