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CIO CROWD PRIVACY POLICY

Kingpin (“our”, “us” and “we”) has created this Privacy Notice in order to
demonstrate our commitment to your privacy. This Privacy Notice forms part of
our Website Conditions of Use and explains our data collection and use
practices. By using or accessing this Website (the “Website”), you signify your
assent to our Privacy Notice. If you do not agree to this Privacy Notice you may
not access or otherwise use the Website.


DATA CONTROLLER

For the purpose of the General Data Protection Regulation, the controller is
Kingpin Communications Limited, whose principal place of business is 3 Wenlock
Street, London N1 7NT.


PERSONAL AND NON-PERSONAL INFORMATION

When using the Website, you may be asked to provide, or you may choose to
provide us with or upload, certain personally identifiable information about
yourself (“Personal Information”), including but not limited to, your name,
company name, e-mail address, physical address and telephone number.

We may also collect non-personally identifiable information, such as IP host
address, pages viewed, browser type and other data, and may aggregate any
information collected in a manner which does not identify any individual
(“Aggregate Information”).


PURPOSES OF PROCESSING

 a. We may use Personal Information for marketing purposes and for the purposes
    of communicating with you about Kingpin and its offerings, events and
    services.
 b. We may use Aggregate Information to improve and enhance the Website, analyse
    trends, administer the Website and for our market research activities. For
    example, we may share Aggregate Information with unaffiliated third parties,
    such as business partners, in an aggregate, anonymous form, which means that
    the shared information will not contain nor be linked to any Personal
    Information.


LAWFUL BASIS OF PROCESSING

The lawful basis of processing is that the processing is necessary for the
purposes of the legitimate interests pursued by Kingpin, including the conduct
of direct marketing activities relating to our business activities, and the
efficient management of Kingpin’s relationships with its customers, prospective
customers, suppliers, shareholders, staff or other stakeholders.


RECIPIENTS OF THE PERSONAL DATA

 a. Unless disclosed otherwise at the time of collection, we do not share any
    Personal Information you submit through our Website with any unaffiliated
    third party, unless it is necessary to respond to your inquiry, or to comply
    with applicable law.
 b. We will never sell your Personal Information to any third party not
    affiliated with us without your consent except in connection with the sale
    or merger of our company or the division responsible for such services.
 c. Please note that we reserve the right to access and/or disclose Personal
    Information and non-personal information we gather as required by courts or
    administrative agencies and to the extent required to permit us to
    investigate suspected fraud, harassment or other violations of any law, rule
    or regulation, the Website rules or policies, or the rights of third parties
    or to investigate any suspected conduct which we deem improper.


LOCATION OF THE PERSONAL DATA

The personal information that we collect from you may be transferred to, and
stored at, a destination outside the European Economic Area (EEA). It may also
be processed by staff operating outside the EEA, who work for us or for one of
our service providers. Such staff may be engaged in, among other things, the
fulfilment of orders, the processing of payment details and the provision of
marketing services. Where such transfers are made, they will be subject either
to the EU Model Clauses that are applicable to Controller-Controller or
Controller-Processor transfers (as applicable) or to another form of contract
with the relevant controller or processor that provides for appropriate and
suitable safeguards. We will take all steps reasonably necessary to ensure that
your data is treated securely and in accordance with this Privacy Notice.


DURATION OF PROCESSING

We will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements. The appropriate retention period
for any given type of personal data depends on a range of factors, including the
nature and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure, the purposes for which it was collected, and the
applicable legal requirements.


DATA SUBJECT RIGHTS

You have the following rights as a data subject, by reason of the General Data
Protection Regulation:

 * The right to request access to the personal data that we hold about you (also
   known as a "data subject access request"). This enables you to receive a copy
   of the personal information we hold about you and to check that we are
   lawfully processing it.
 * The right to request rectification of the personal data that we hold about
   you. This enables you to have any incomplete or inaccurate information we
   hold about you corrected.
 * The right to request erasure of the personal data that we hold about you
   (also known as “the right to be forgotten”). This enables you to ask us to
   delete or remove personal information where there is no good reason for us
   continuing to process it. You also have the right to ask us to delete or
   remove your personal information where you have exercised your right to
   object to processing (see below).
 * The right to request restriction of processing about you. This enables you to
   ask us to suspend the processing of personal information about you, for
   example if you want us to establish its accuracy or the reason for processing
   it.
 * The right to object to processing. Where we are processing your personal data
   solely on the grounds that there is a legitimate interest to do so, and there
   is something about your particular situation which makes you want to object
   to processing on this ground, then this enables you to challenge the
   processing. You also have the right to object where we are processing your
   personal information for direct marketing purposes.
 * The right to data portability. This enables you to ask us to transfer your
   personal information to another party in certain circumstances.
 * Where our processing of personal data is based on your having given consent,
   you also have the right as a data subject to withdraw that consent at any
   time.
 * You have the right to lodge a complaint with a supervisory authority. In the
   United Kingdom, the supervisory authority is the Office of the Information
   Commissioner, full contact details for which can be found at
   https://ico.org.uk/global/contact-us/

If you wish to invoke any of the above rights, please contact us using the
details at the end of this Privacy Notice.


AUTOMATED DECISION-MAKING (INCLUDING PROFILING)

We do not undertake any automated decision-making in respect of personal data
obtained through the Website from data subjects.


PLANS FOR FURTHER PROCESSING

We have no plans to process personal data for reasons other than the reason for
which the data was originally collected.


COOKIES

The Website uses cookies for several reasons, including improving the user
experience. Please refer to our separate Cookies Policy for further information
about how we use cookies.


SECURITY

The security of your Personal Information is very important to us. We have put
in place reasonable physical, electronic, and managerial procedures to safeguard
the information we collect. However, due to the inherent open nature of the
Internet, we cannot guarantee that communications between you and us, or
information stored on the Website or our servers, will be free from unauthorized
access by third parties such as hackers and your use of the Website demonstrates
your assumption of this risk.


OTHER WEBSITES

Our Website may contain links to other Websites not maintained by us. Other
Websites may also reference or link to our Website. We recommend that when you
leave our Website you read the privacy statements of each Website that you
visit. We are not responsible for the privacy practices or the content of such
other Websites.


COMMUNICATIONS WITH US

We may use email to communicate with you, to send information that you have
requested or to send information about other products or services developed or
provided by us, provided that, we will not give your email address to another
party to promote their products or services directly to you.


CONTACT

If you have any questions about this Privacy Notice please contact:
dataprotection@kingpincomms.com

Updated: September 2020

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