Privacy Policy

POSITIVE MOBILITY LTD PRIVACY POLICY 2021-08-05 v1.1

1. Introduction

This privacy policy (Privacy Policy) sets out the ways in which all members of POSITIVE MOBILITY LTD t/a Generation E may use your personal data.

In this Privacy Policy:

• ‘we’, ‘us’ or ‘our’ means the POSITIVE MOBILITY entity with which you are interacting as detailed above. For example, the POSITIVE MOBILITY entity organising the event you are attending, or managing the website you are using. We will make it clear to you which entity this is;
• ‘the site’ means the POSITIVE MOBILITY website you are visiting or engaging with; and
• ‘you’ and ‘your’ means you, the person engaging with us, registering for our events or services or visiting our site.
• ‘POPIA’ means the Protection of Personal Information Act, 2013, including any regulations and/or code of conduct made under that Act

By registering for one of our events, subscribing to our services, visiting our site, or otherwise interacting with us, we will process your personal data in accordance with this Privacy Policy and applicable data protection and privacy laws. 

2. How you can contact us:

The Information Officer, POSITIVE MOBILITY
Email address: [email protected]

(EU residents please see section 10.2)

(California residents please see section 10.3)

3. Information we may collect about you

Information you give us:

We collect any information you provide to us when you complete registration forms, or provide us with your details over the phone, for example when you register an account with us, register to attend one of our events (whether as a delegate, exhibitor, speaker or attendee) or subscribe to our mailing list. This information might include your name, address, email address, phone number, credit card information and other information relevant to the event or service that you’re registering for.

Information we collect about you:

Personal information refers to the types of personal information that may be collected and used, including: Collection of information contained in any correspondence between you and us via contact forms on websites, and emails or telephone calls.

• Through registration forms we may collect: contact details such as name, email address, postal address and telephone number; educational, nationality and professional information; interests and business information, such as roles and responsibilities; survey information, comments, feedback, posts and any other content submitted; and payment information, such as a credit or debit card number or bank account details where registering for paid events or services.
• We may collect identity verifying information such as passport details to comply with legal obligations in certain countries, as may be applicable, where requested, and other identifying information such as driver’s licenses or ID cards for verification purposes where applying for Press Passes or general entry to some of our events.
• Where we operate badged access in relation to any of our events, we may collect information about; your location in; and engagement, within the event. For example, for certain events access will be granted via a badge which holds your registration details including personal information. You will be required to use your badge to gain access to the event. In this situation we will collect information about when you enter the event and which exhibitors or sponsors you have engaged with.
• We collect information about you visiting our website and how you use it. This may include your IP address, geographical location, device information, browser type, referral source, length of visit, operating system, number of page views, which pages you viewed and similar information. This information may be collected by a third party website analytics service provider on our behalf and/or may be collected using cookies. We also use cookies and pixels in our emails to track delivery and open rates, the results of which are stored against your email address and profile. For more information on cookies please refer to section 6 below
• We may collect publicly available information including names, job title, employer, telephone, social media and business email address contact details to allow us to send you information about our goods and services using our legitimate interest to do so pursuant to relevant data protection legislation. You can request to stop receiving such communications at any moment by using the unsubscribe links in the footer of the email or by contacting us directly.

Information we receive from third parties:

We may collect information about you from third parties that we work closely with for the purposes of delivering to you the services that you request from us. For example, we may engage third parties to assist us with our online event registration systems or payment systems; these third parties will collect information directly from you on our behalf. We may also engage third parties to operate event websites on our behalf; these entities will collect information directly from you about your visits to the website on our behalf.

We may also receive information about you from third parties where you have consented to such third party sharing your information with us.

Sensitive personal data

If collecting or storing sensitive personal data such as information relating to health, beliefs or political affiliation, we typically ask for your explicit consent. However, there are some situations where it will not be possible to request consent, such as if you have an accident at one of our events. If this does occur, we will ensure your privacy rights are protected.

Children’s personal data

Our products and services are not intended for children under the age of 13 and we do not knowingly collect personal data from this age group. If any information is collected from a child under the age of 13 without verification of parental consent, it will be deleted.

4. How we use information about you

We may use your information for the following purposes, depending on the relationship we have with you.  Prior to submitting your personal data to us, we will provide you more specific information where necessary about how we will use your data, and link you to this Privacy Policy.

For sales and product/event enquiries

To provide you with information that you have requested from us, in relation to events and publications we run, or other services we provide (for example on-demand content online webinars and e-newsletters).

Legal Basis: By specifically requesting information from us, you are consenting to us using your personal data for the purposes of communicating such information to you.  

General administration and organisation of our events

As a Speaker, Exhibitor, Sponsor or Attendee to our events we may use your details for planning and logistics, to invoice you, to provide you customer service in relation to the event, and general administration of your attendance at the event.  We may also share your personal data with other entities in POSITIVE MOBILITY for the purpose of assisting in the delivery of the event and/or provision of the applicable service.

Legal Basis: Where you have registered to attend or exhibit at an event, we need to use your personal data in this way to perform our contractual obligations.

To assess the activity of our attendees at our events

We assess how people move around and engage with our events.  We do this using any apps you have activated or signed up to, and where you allow your badge to be scanned by exhibitors and staff at our events.  We use this information for analytics, and to improve and enhance our events. 

Legal Basis: It is our legitimate interest to monitor the location and engagement of our attendees at our events.  

Badge Scanning Policy

Where you allow your badge to be scanned by an Exhibitor or Sponsor at one of our events your contact details will be transferred to the Exhibitor or Sponsor.

Legal Basis: When you hand your badge to an exhibitor or sponsor for them to scan, you are consenting to your Personal Data being passed to the exhibitor or sponsor.  If you do not wish for your information to be passed on, please do not allow your badge to be scanned. The third party use of your details will be in accordance with its own privacy policy and is not covered by this Privacy Policy.

Live Event Feature Areas such as seminars and VIP areas

Where an event has a feature area such as a seminar or theatre, you may be asked to scan your badge on entry for the purpose of health and safety, analysing attendance to improve and enhance events and share your data in some cases with the feature area partner or sponsor.

Legal Basis: When we scan your badge for entry to feature areas we use legitimate interest for the purposes prescribed above.

If you wish your data to not be shared with a sponsor or partner of a feature area, advice will be given on how to notify us of your preference at the area entrance, dependent on the format of the feature area.

Enhance your Event experience

For exhibitors and sponsors, we engage logistic partners in order to enhance your experience at our events, such as engaging stand builders, electricity providers, carpeting, furniture, WIFI providers etc.

Legal Basis: We may share your details with logistic partners acting on our behalf: (i) as and when required in order to enable the performance of the contract we have with you; or (ii) so they may inform you of relevant services offered by such preferred partners as approved by the event organisers using legitimate interest or consent if and when required under applicable data protection laws.

For Marketing

To keep in contact with you about other similar events or services of ours that may be of interest to you, send you newsletters, offers or other marketing emails that keep you up to date with our news, events and products that may be of interest or for research purposes after an event you have attended to analyse the effectiveness of our products and offerings to you.

Depending on the nature of your interaction with us and applicable data protection laws, you may have actively given us your consent (i.e. opted in) or we may be entitled to rely on your implied consent or legitimate interests to market to you. The opportunity to opt out of future marketing will always be provided and you have the right to amend your marketing preferences at any time (see Your Rights in section 10). 

Legal Basis: It is our legitimate interest to keep you up to date on similar events of ours you have attended our exhibited at in the past.  Where we rely on legitimate interests in this way, we will always offer an unsubscribe option or a preference management tool on any marketing or research information we send you.

Online Event Content & Networking Platforms (including, without limitation, digital apps)

As part of your registration to fully Virtual (online) Events & to Live Events that offer online networking and content as an additional service, some of your registration data will be passed to our Networking Application Provider to create an account within the platform.

When entering an online event or content and networking platform you may engage in activities such as: visiting zones or rooms such as an online event space, exhibitor or sponsor booth; downloading content; attend/view live seminars.

As a result of such activities the platform, POSITIVE MOBILITY (and any event partner, as may be applicable) may collect, collate and share your personal information and data about your movements and interactions whilst in the virtual event space with the relevant sponsor or exhibitor to allow them to engage with you, subject to applicable data protection laws.

Legal Basis: In order to provide this service to you, your data will be given to the platform provider.  Your data will be protected by the platform provider and not commercialized by them. You have the right to access your data, as well as editing or deleting it through the tools provided within the mobile application or web platform.

Recordings

Photos and videos may be taken at our events, which may feature attendees, speakers, sponsors or exhibitors. Where we have taken photos and videos at our events that feature you as an attendee, sponsor or exhibitor, to the extent permitted by applicable data protection laws, those photos and videos may be used for promotional or, where applicable, commercial purposes. You have the right to withdraw the consent you have given at any time. This will not affect the lawfulness of any processing carried out by the Company before you withdraw your consent

You can find out more information on the privacy notice provided at the time you submit your data to us or in your contract with us (if applicable).

5. Who we might share your data with

In certain circumstances we may share your personal information with:

• Other entities in POSITIVE MOBILITY for specific purposes. For example, where they may assist in providing products and services to you, manage internal analysis of the usage of POSITIVE MOBILITY products and services, or offer relevant products and services which may be of interest.  Where the relevant POSITIVE MOBILITY entity is outside the EEA, we would only transfer data where an appropriate safeguard such as EU model clauses or such other methods as may be applicable under relevant data protection laws, exists between the entities.
• Selected third parties that we work with, where necessary for the purposes of delivering to you services that you request from us.  For example, when you register to attend an event that we host, we may need to share your information with third party sub-contractors, service providers or other POSITIVE MOBILITY entities. They may include: IT and marketing technology host suppliers, web and data hosting providers, mailing houses, ad servers, logistics and general service contractors, hotel/housing partners, freight forwarders, onsite health and safety partners, event registration partners, sales platform providers, communication tool providers, stand designers/builders/fitters, suppliers of sponsorship/marketing/PR collateral and other event collaboration partners. Where we use such third parties, we enter contracts which ensure that the third party is obligated to provide at least the same level of data protection as the POSITIVE MOBILITY entity entering into that contract, and we take reasonable, appropriate steps to ensure that the contractor effectively processes the personal data in a manner consistent with this Privacy Policy and our internal policies relating to the protection of Personal Data.
• Any other POSITIVE MOBILITY entity or selected third party for a specific purpose that you consent to our sharing your information with for marketing purposes (such consent will be sought prior to our sharing of this data).
• Any other third parties where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
• We may share your personal information with third parties outside POSITIVE MOBILITY including the Securities Exchange in the event of a sale, merger, acquisition, partnership, joint venture, collaboration, or negotiations related to the same with respect to all or part of our business.
• Some of our events and products are co-branded, co-hosted, co-delivered or sponsored by third party exhibitors or sponsors. We may share your details with these third party partners. Should we do so at live events, a clear notice will be provided that gives the opportunity to manage your preferences with regard to such sharing as required by applicable data protection laws. The third party partner’s use of your details will be in accordance with their notice provided and its privacy policy and is not covered by this Privacy Policy.

6. Cookies

We use cookies to ensure that you get the most out of our site. Cookies are small text files which we store on the device you use to access the site. Cookies allow us to monitor your use of the software and simplify your use of the site. For example, a temporary cookie is also used to keep track of your “session”. Without that temporary cookie (which is not stored after you quit your browser) you would have to log on every time you access a new page. 

If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of our websites. 

7. Third Party Content, Sites, and Contributions

Some of our websites may contain content and links to other websites or apps that are operated by third parties. We don’t control these third party websites or apps (including whether or not they store cookies) and this Privacy Policy does not apply to them. Please consult the terms and conditions and Privacy Policy of the relevant third party website or app to find out how that site/app collects and uses your information and to establish whether and for what purpose they use cookies.

8. How we look after your data and how long we keep it for

We use a variety of technological and operational security measures to protect your information against any unauthorised access to, unlawful use of, and modification and destruction of any personal data we store.

We will retain your information for as long as is necessary to provide you with the services that you have requested from us, or for as long as the law otherwise permits.  Where you have not participated, attended or registered to attend or participate in one of our events, or otherwise engaged with us in four years, we will delete your data, unless we have an obligation to retain it for longer (for example for taxation purposes).

Transmission of information over the internet can be insecure, and although we employ measures to protect your information from unauthorised access we cannot always guarantee the security of information sent over the internet.

9. Where we store your information

Some of our servers are situated outside the European Economic Area (EEA) and South Africa.

In certain circumstances EU Data Subjects information may be processed outside of the EEA.  In such circumstances, we will take all steps necessary to ensure that any EU Data is adequately protected and processed in accordance with this Privacy Policy, and where necessary, we put in place relevant safeguards to ensure the safe processing of EU data. 

Some POSITIVE MOBILITY Websites, products and services are operated out of the United States. If you are located in another jurisdiction, please be aware that information you provide to us, in relation to such websites, products and services, may be transferred to, stored and processed in the United States.

By using these Websites or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws are not as comprehensive as those in the country where you reside or are a citizen, such as the European Union. You understand that the U.S. government can obtain access to the Personal Data you submit if necessary for investigative purposes (e.g., terrorism investigation). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We use appropriate and suitable safeguards such as EU Standard Contractual Clauses (EU Model Clauses) for transferring your Personal Data to the U.S.

10. Your rights in relation to your Personal Data

POSITIVE MOBILITY operates in countries with data protection laws that may provide individuals with the right to be able to access and control their information. We will always enable you to exercise the rights provided by the appropriate data protection laws.

10.1 Your POPIA Rights

If you are a resident of the Republic of South Africa, we collect and process Personal Data about you only where we have a legal basis for doing so under applicable data protection law, including under the Protection of Personal Information Act (POPIA). The legal bases will depend on the purpose for which we process your Personal Data as generally described in section 4.

You have the right to:

• Request access to your personal data.
• Request correction of your personal data
• In certain circumstances, to request the erasure of your personal data
• Request restriction of processing your personal data on reasonable grounds
• Request transfer of your personal data
• Right to withdraw consent

10.2 Your EU Data Subject Rights

If you are a resident of the European Economic Area (EEA), we collect and process Personal Data about you only where we have a legal basis for doing so under applicable data protection law, including under the European General Data Protection Regulation (GDPR). The legal bases will depend on the purpose for which we process your Personal Data as generally described in section 4.

You have the right to:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact the Information Officer (details below).

If you believe we have not complied with any applicable data protection law you can lodge a complaint with the UK data protection authority.  In the UK, the relevant authority is the Information Commissioners Office, you can find their details at www.ico.org.uk. 

We note that we are a “controller” for those services where we make decisions on how personal information is used in connection with our services, and we are a “processor” for those services where we only use personal information as allowed by our customers.

10.3. California Privacy Rights

This section explains the rights of certain natural persons residing in the State of California (each, a “consumer”) may have under the California Consumer Privacy Act 2018 and such rules and regulations as may be adopted from time to time implementing and interpreting such Act (collectively, “CCPA”). The use of the term “personal information” does so as CCPA defines it, to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA). Also, the definition of “personal information” does not currently apply to the collection of personal information from job applicants, employees (whether you are our employee or any employee of our customers), business owners, directors, officers, medical staff or contractors.

Where we act as a “business” under CCPA (meaning we determine the manner and reasons for why we process your personal information), we may be required to disclose additional information regarding the categories of personal information we collect, the sources where we obtain that information, the purposes for why we collect that information, who we share that information with, as well as whether we sell that personal information – all of which depends on the specific service being provided.

Depending on your relationship with us, we may have collected each of the above categories of Personal Information about you. In addition, we may have shared one or more of these categories of Personal Information with third parties during the preceding 12 months for the business purposes described in this Privacy Policy.

California Residents - How to contact us:

If you are a resident of California and are not a job applicant, employee/contractor, or employee/contractor of another company interacting with us in your job role, you have the right to request what category of personal information we collect about you, how we use that personal information, and the categories of third parties we disclose that personal information.

You also have the right to request that we delete your information.

Please provide us enough information to verify your identity. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill.

California residents also have certain rights regarding the “sale” of “personal information” (as such terms may be defined by CCPA). California residents have the right to opt out of such “sale” of their “personal information” in accordance with CCPA by sending an email to our Information Officer.

We will not discriminate against you because you have exercised any of your privacy rights under the CCPA.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Updated privacy policies will be updated on the relevant event website and corporate websites, or provided to you at your request.