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PRIVACY POLICY

Last Updated: [May 17, 2022]

We at Dialectica Limited, along with our affiliates (collectively, “Dialectica”
or “we” or “us”) value your privacy. This Privacy Policy sets out how we
collect, use, share and protect personal information obtained from Clients,
Specialists and visitors to our website www.dialecticanet.com, and applies to
said Clients, Specialists and visitors.

By visiting our website or by becoming a Specialist or a Client, you consent to
the collection, use and transfer of your information pursuant to the terms of
this Privacy Policy. If you do not agree to this Privacy Policy, please do not
register with us or use the Dialectica website or the services provided over it.
Dialectica is the controller of personal information collected from European
Economic Area (“EEA”) and United Kingdom (“UK”) residents. For the purposes of
this Privacy Policy, “personal information” means any information relating to an
identified or identifiable individual.

Beyond this Privacy Policy, your use of our services is also subject to our
Terms & Conditions.

Scope

This notice applies to users of Dialectica’s services anywhere in the world,
including Clients, Specialists and visitors to our website
www.dialecticanet.com. In addition, this Privacy Policy is in accordance with
the General Data Protection Regulation (GDPR) (2018), the Data Protection Act
(2018), the Personal Information Protection and Electronic Documents Act
(PIPEDA) (2004) and any other data protection regulations applicable to states
in which the Company operates.

Information We Obtain

Dialectica may obtain personal information in connection with various business
activities and for the purpose of providing its services. We may collect
personal information that you choose to provide us on our website, through
email, over the phone and other communication channels or from public available
sources. We may also gather personal data regarding your interactions with us
and our clients, such as records of your interactions. Dialectica also keeps
records of personal data of its employees, as well as of prospective employees,
who have applied for a position or have been referred from another Dialectica
employee. In addition, Dialectica’s website may automatically record information
when you visit our website, such as your Internet Protocol address. We may also
receive personal information about you from third parties such as data or
marketing partners and combine it with other personal information we have about
you. Information may also be collected through small files called “cookies”,
further information on which you can find in our Cookie Policy. We will clearly
indicate where collecting such personal information is required to offer a
specific service. Where it is not, it is your choice whether you will provide it
to us.

Special Category Data

Generally Dialectica does not collect any special category data about you (this
includes details about your religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, and information
concerning your health and genetic and biometric data) we only do so with your
explicit consent.

Kindly abstain from sharing any Special Categories of Personal Data with us
unless we ask for such personal data, and you consent.

Further, we may collect the following information for:

 Specialists

 Specialists registering with Dialectica are required to provide personal
information including name, address, and other contact information, as well as
detailed information in respect of their academic and professional background
and employment history. Specialists will also be required to provide their
payment information so that they can be compensated following a consultation.

Clients

 When a client wishes to enquire or register with us, we will collect their
contact details (e.g. name, address, title and position) as well as a brief
description of the client’s business.

How We Use The Information We Obtain

 We may use the information we obtain for the following purposes:

To Provide Our Services

 * Operate, maintain and improve our website;
 * Communicate with you, provide you with updates and other information relating
   to our services, provide information that you request, respond to comments
   and questions, and otherwise provide support;
 * Use Specialists’ information to facilitate their participation in projects;
 * Identify Projects which may be within the field of expertise and of interest
   to a Specialist;
 * Identify the most suitable Specialists for a Client’s project;
 * Disclose information to Clients who may wish to consult with a Specialist;
 * Process payments;
 * Perform necessary operations to maintain our services, including software
   maintenance and fixing operational problems.

To Market, Improve our Services, and other Legitimate Business Interests

 * Provide Specialists’ biographical information to prospective clients to
   demonstrate the quality and coverage of our specialist network;
 * Identify events, actual and potential projects of interest to Clients;
 * Understand and analyze how you use our services, improve and develop new
   products and services;
 * Communicate about new services or other information which we think you may
   find interesting;
 * Operate, evaluate and improve our business;
 * Anonymize information collected through our services and use it for our
   business purposes;
 * For other purposes for which we provide specific notice at the time the
   personal information is collected.

To Comply with Applicable Law

 * Protect against any prohibited or illegal activity, claims and other
   liabilities;
 * Enforce our legal rights;
 * Comply with applicable legal requirements and internal policies;
 * Establish, exercise and defend a legal claim.

Legal Bases For Processing European Personal Information

If you are located in the EEA or the UK, we only process your personal
information under certain legal bases:

 * Contractual necessity. We need your personal information to provide you with
   the services you have requested, engage you as a Specialist or a Client, or
   to respond to your inquiries;
 * Consent. You have consented to the use of your personal information, for
   example to use cookies;
 * Compliance with law. We have a legal obligation to use your personal
   information, for example to comply with our tax and accounting obligations;
 * Legitimate interests. We or a third party have a legitimate interest in using
   your personal information. In particular, we have a legitimate interest in
   using your personal information for product development and internal
   analytics purposes, and otherwise to improve the safety, security and
   performance of our services. We only rely on our or a third party’s
   legitimate interests to process your personal information when these
   interests are not overridden by your rights and interests.

Kindly note that we may process your personal data for more than one legal
grounds, depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are
relying on to process your personal data.

Data Disclosures

Employees. We may share your personal information with any member of our
organization who reasonably needs access to user data to achieve the purposes
set out in this Privacy Policy.


Affiliates. We may share your personal information with our affiliates for any
of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may share any personal information we receive
by our service providers and share within Dialectica for any of the purposes
described in this Privacy Policy.

Clients. Dialectica may share your information with our Clients, typically in
connection with consulting opportunities.

Analytics Partners. We use analytics services such as Google Analytics to
collect and process certain analytics data. You can learn about Google’s
practices by going to https://www.google.com/policies/privacy/partners/ and
opt-out of them by downloading the Google Analytics opt-out browser add-on,
available at https://tools.google.com/dlpage/gaoptout.

Compliance with law. Dialectica may disclose the fact that you are a Specialist
and information collected about you in response to a valid order or request by a
court or other governmental body, to enforce an agreement between you and
Dialectica or one of Dialectica’s Clients, to protect Dialectica’s rights, or as
otherwise required or permitted by law, legal process or for the prevention or
detection of a crime.

Merger, Sale, or Other Asset Transfers. Dialectica may disclose personal
information to service providers, advisors, potential transactional partners, or
other third parties in connection with the consideration, negotiation, or
completion of a corporate transaction in which we are acquired by or merged with
another company or we sell, liquidate, or transfer all or a portion of our
business or assets.

Consent. Dialectica may disclose personal information from or about you with
your consent.

Data Transfers

Dialectica operates and processes personal data globally. Personal information
provided to Dialectica will be held by us inside the EEA or the UK and will be
accessed by our staff and third parties working for us for the purposes set
forth in this policy or for other purposes subject to your approval. Your
personal information may also be held, processed and accessed outside the EEA or
the UK to countries that have not been determined by the European Commission or
the UK government to provide an adequate level of data protection. In any such
transfer, Dialectica will ensure that appropriate data protection safeguards
(e.g. European Commission’s Standard Contractual Clauses or UK addendum to the
Standard Contractual Clauses) are in place. To obtain a copy of the relevant
transfer mechanism or additional information on the transfers, please contact us
using the contact information below. Please note that when personal information
is transferred to certain countries, law enforcement and regulatory agencies,
including national security authorities, of these countries may be able to
access such information in accordance with the laws of those countries.

Your Options And Rights

You may elect to opt-out of our services at any time by providing Dialectica
with written or electronic notice. Upon receipt of such notice, we will cease
contacting you and sharing information concerning you. Please note that if you
withdraw your consent, we will be unable to provide you with our services.

Dialectica takes every reasonable step to ensure that your personal data is kept
accurate and up-to-date and that the personal data that is processed is limited
to the reasonably necessary in connection with the purposes set out in this
Privacy Policy. If you are a Specialist, it is your responsibility to regularly
update us on any biographical and/or employment changes. You may reasonably
access the personal information that Dialectica has on file for you and you may
ask that we revise your personal information to ensure that it is current and
correct. We may also revise your information using data obtained from third
parties or public sources.

You may exercise these rights free of charge:

 * Request access to your personal information.
 * Request that your personal information is corrected or updated or deleted or
   transmitted or restricted where you have successfully exercised your right to
   object to processing, where we may have processed your information unlawfully
   or where we are required to erase your personal data, in order to comply with
   local law. Note, however, that we may not always be able to comply with your
   request of deletion for specific legal reasons for which you will receive a
   notification, if applicable, at the time of your request.
 * Withdraw any consent you have provided to our processing of your personal
   information.
 * Object to our processing of your personal information for any purpose,
   including direct marketing.

Please contact us at compliance@dialecticanet.com*protected email* if you wish
to exercise any of these rights. Before processing your requests, we will ask
you to provide reasonable information to verify your identity. In certain
situations, and subject to applicable law, we may not be able or obliged to
grant part or all of your individual requests.

Please note that any changes made in user databases will be reflected instantly
or within a reasonable period of time. We may retain some information for
backups, archiving, prevention of fraud and abuse, analytics, satisfaction of
legal obligations, or where we otherwise reasonably believe that we have a
legitimate reason to do so. We also have the right to refuse and/or charge a
monetary fee for requests which are manifestly unfounded or excessive, for
example because of their repetitive character. Dialectica tries to respond to
all legitimate requests as soon as possible (within 1 month upon its receipt).
If we require more time (for a maximum total of 1 month), we will inform you of
the reason and extension period in writing. In the event of a dispute regarding
your rights hereunder, you may have the right to lodge a complaint with a
Supervisory Authority, such as the Information Commissioner’s Office (ICO) for
the UK.

Information Security

In order to prevent unauthorized access, disclosure or other unlawful
processing, we have put in place suitable physical, electronic and managerial
procedures designed to safeguard and secure the information we collect online.
We cannot, however, guarantee the security of our servers or transmissions
between our servers and your computer. Accordingly, all information which you
provide to us is supplied at your own risk. Please help us keep your information
secure by keeping your password and other account details confidential.

Retention Policy

We will retain your information for so long as necessary for the purposes for
which they were collected. We will also retain your information as required
under applicable retention policies or as permitted by applicable law. When
determining the specific retention period, we take into account various
criteria, such as the type of service provided to you, the nature and length of
our relationship with you, and mandatory retention periods.

Third Parties

Our services may contain links to other websites, products, or services that we
do not own or operate. We are not responsible for the privacy practices of these
third parties. Please be aware that this Privacy Policy does not apply to your
activities on these third-party services or any personal information you
disclose to these third parties. We encourage you to read their privacy policies
before providing any personal information to them. Also, when we disclose
personal information of an industry specialist to a client, the client becomes
responsible for such personal information in its care and will treat such
personal information in accordance with its own policies.

Children’s Privacy

We do not knowingly collect, maintain or use personal information from children
under 18 years old (“minors”), and no part of our services is directed to
children. If you learn that a child has provided us with personal information in
violation of this Privacy Policy, please contact us immediately.

 Updates To Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you
to reflect changes in our personal information practices. We will post a
prominent notice on our website to notify you of any significant changes to our
Privacy Policy and indicate when it was most recently updated. You should also
check this page from time to time to ensure that you are happy with any changes.

How To Contact Us

We welcome all requests, suggestions and questions concerning our use of your
information. All such communication should be directed to
compliance@dialecticanet.com*protected email*, or call us at +44 203 637 2934,
or write to us at: 28 Margaret St, London, W1W 8RZ, United Kingdom.


Dialectica is an information services company that brings unique, real-time
insights to the world’s top business professionals with the vision to shape
better decision making worldwide.
2023 Sustainability Report
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