GDPR Policy

WHO PROCESSES YOUR PERSONAL DATA

This Policy applies to the processing of personal data by Global NFT Group Community (GNG) and to the extent any other non-European entities are subject to the GDPR.

For the purpose of this Policy and the GDPR, to the extent any of the above entities process your personal data in connection with use cases identified in this Policy, each will be considered a "data controller" of your personal data. Please note that in some cases we may carry out the activities referred to in this Policy in our capacity as a data processor acting on behalf of our clients. We have made this distinction clear in the Policy.

PURPOSE OF THIS POLICY

This Policy explains our approach to any personal data that we might collect from you using our website (the "Site") and any personal data about you we might collect/process in other situations or interactions with us, and the purposes for which we process your personal data.

This Policy also sets out your rights in respect of our processing of your personal data.

This Policy will inform you of the nature of the personal data about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it or otherwise object to our processing of it for a specific purpose.

TYPE OF PERSONAL DATA WE COLLECT/PROCESS

When we talk about personal data we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, or an online identifier (such as an IP address). Categories of personal data we may collect and process about you include:

• contact information (e.g. name, physical address, telephone number, email address)
• your date of birth
• your image
• your online identifier (e.g. cookie ID)
• any additional data that may identify you which you submit to us

For more information about the personal data we collect please refer to section HOW WE USE PERSONAL DATA below and the COOKIES section.

PERSONAL DATA OF CHILDREN

We do not intend to or knowingly collect personal data from children.

WAYS OF OBTAINING PERSONAL DATA

We may collect and receive your personal data using different methods:

• Personal data you provide to us You may give us your personal data directly. This will be the case when, for example, you contact us with enquiries, complete forms on our Site or in hard copy or participate in a survey, subscribe to receive our marketing communications or provide feedback to us, provide services to us or otherwise through your interactions with us.
• Personal data we collect from you automatically When you access and use our Site, we will automatically collect certain technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar tracking technologies.

HOW WE USE PERSONAL DATA

Our primary goals in collecting personal data from you are to:

• verify your identity;
• provide our services to clients;
• help us improve our Site, products and services and develop and market new products and services;
• carry out requests made by you to us;
• investigate or settle inquiries or disputes;
• comply with any applicable law, court order, other judicial process, or the requirements of a regulator;
• enforce our agreements with you;
• protect the rights, property or safety of us or third parties, including our other clients and users of the Site;
• provide support for the provision of our services;
• use as otherwise required or permitted by law.

Client administration

Our legal basis for processing We may collect personal data about our client and potential client contacts to enable us to respond to client requests, to administer client accounts with us and to verify and carry out financial transactions for payments made to us.

Who do we share personal data with for this purpose? We may share such personal data with our third-party vendors (such as our payment service providers or IT providers), financial institutions, group companies, affiliates, professional advisors, regulatory bodies or other law enforcers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Market research and focus groups

As part of our service to our clients, we may collect an individual's contact details, records of communications, opinion data, age range, nationality and image, for the purposes of carrying out market research through focus groups, interviews and user testing. We may do this on behalf of our clients or for our own purpose.

Our legal basis for processing: It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure that we provide the services requested by our clients in an effective and efficient way.

Please note where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose: We may share such personal data with our clients, group companies, affiliates, market research partners or agents, third party vendors (such as our IT provider) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Media monitoring

As part of our service to our clients, we may monitor media sites (including social media sites) and collect information about individuals from these sites directly or using a third-party social listening provider including their opinions on how a particular client campaign was received or a client offering or on a topic that is relevant to our client more generally.

Our legal basis for processing: It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the services requested by our clients in an effective and efficient way. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose? We may share such personal data with our clients, group companies, affiliates, or partners, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Campaign reporting

As part of our service to our clients, we may collect information about individuals through third party providers or directly from the individual or through social media or other media outlets such as their contact details and opinions on how a particular client campaign was received or other feedback they may have about a campaign or a client offering.

Our legal basis for processing It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the services requested by our clients in an effective and efficient way and provide our client's with insight into the performance of a campaign or client offering. Please note where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose? We may share such personal data with our clients, group companies, affiliates, partners or agents, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Promotions

We may conduct promotions, contests or giveaways on our own behalf (or on behalf of our clients), which may require that individuals register to enter. We collect personal data from individuals in order to conduct the promotion, contest or giveaway and to deliver prizes or notices. Participation in these events and providing us with personal data is voluntary.

Our legal basis for processing: It is in our legitimate interests (and those of our clients) to process personal data in this way in order to enable individuals to participate in the promotion, contest or giveaway or we may do so in order to perform an obligation owed to individual. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose?We may share such personal data with our clients, group companies, affiliates, third party vendors (such as our IT providers), competition partners or professional advisers or regulatory bodies or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Industry Information

We collect, and maintain data bases containing, information about journalists, talent, social media influencers, social media users and other professionals in the public relations, news or media industry collected by us or by our trusted third-party media analytics service providers. Such information may include an individual's name, business contact details, professional interests and affiliations. This information may be information that is voluntarily supplied to us by those individuals through our Site or in other situations (such as public speaking events), or information that is public or available in third party databases or via third party content platforms (including social media platforms).

Further we may collect and/or review other publicly available news stories and other journalistic content including content made available through public news sites and social media sites to understand what people are saying about us and our clients. We use this information to provide our services to our clients including ensuring we and our clients are fully up to speed on public opinion in any particular area and are fully briefed when it comes to dealing with the press. We may also use this information to contact those individuals to discuss our clients' goods and services. We may also use this information for our own internal administrative and promotional purposes.

Our legal basis for processing: It is in our legitimate interests (or those of our client) to process personal data in this way so that we can provide the services requested by our clients in an effective and efficient way. Where the personal data collected is considered special personal data, we rely on the fact that the personal data has been manifestly made public by individual in order to process their personal data. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.

Who do we share personal data with for this purpose? We may share such personal data with our clients, group companies, affiliates, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose..

Social media

We may collect or process individuals' personal data who engage with us through our social media channels (including by visiting our social media pages or otherwise communicating with us via social media). We may also operate our client's social media pages, accounts or channels acting on their behalf.

Our legal basis for processing: It is in our legitimate interests to process personal data in this way so that we can market ourselves and engage with the public. Where we carry out this activity on behalf of our clients as a data processor, we do not require a legal basis for such processing.

Who do we share personal data with for this purpose? We may share such personal data with our clients, group companies, affiliates, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Interactive areas and fan pages

We may provide interactive areas, such as message boards, fan pages, chat rooms or other forums or other closed communities. Participation in these areas by users is voluntary. We may provide these interactive areas (including fan pages) in conjunction with third parties such as Facebook or other social media platforms.

Although we discourage individuals from submitting any information that may identify them personally when participating in these areas, we may inevitably process their personal data in connection with these interactive areas.

Our legal basis for processing: To the extent we do process personal data in connection with this purpose, it is in our legitimate interests to do so to help us understand industry issues, share content and generally provide services to our client and users. Where we do this on behalf of our clients as a data processor we do not require a legal basis for such processing.

Who do we share personal data with for this purpose? We may share such personal data with our clients, group companies, affiliates, partners or agents (such as Facebook), third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Events

From time to time, we may organise and host road shows and other industry events to promote our services or on behalf of clients. For this purpose, we may process individuals' names and contact information (including email address, postal address and telephone number) to communicate with them about such events where they have specifically requested information about such events or where we have another lawful basis for sending that information to them.

If you attend one of our events, we may use your personal data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary or other requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications we send to our clients and/or publish on our Site, in print or other media.

Our legal basis for processing: It is necessary for us to use personal data in this way to perform our obligations in accordance with any contract that we may have with the individual, or it is in our or our client's legitimate interest to use personal data in such a way to ensure that we provide our services in an effective and efficient way. If we specifically ask your permission to use your photographs, quotes, testimonials or other content, then our processing of such personal data will be based on consent. Where we put on events solely at the specific request of our clients we do so in our capacity as our client's data processor and therefore do not require a legal basis to process personal data.

Our legal basis for processing: We may share such personal data with our clients, group companies, affiliates, event and ticketing partners or agents, third party vendors (such as our IT providers) or professional advisers or event organisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Insight and analysis

We may analyse individuals' contact details with other personal data that we observe about them from their interactions with our Site, our email communications and/or with our services. We may use cookies, log files and other tracking technologies to collect personal data from the computer hardware and software used to access the Sites, or from mobile devices.

• an IP address to monitor Site traffic and volume.
• a session ID to track usage statistics on our Sites.
• information regarding your personal or professional interests, demographics, experiences with our services and contact preferences.

Our web pages and emails may contain cookies, web beacons and pixel tags ("Tags"). Tags allow us to count users who have visited a web page or opened an email and collect other types of aggregated information. Once a recipient clicks on an email that contains a Tag, their contact information may subsequently be cross-referenced to the source email and/or the relevant Tag.

In some of our email messages, we use a "click-through URL" linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

This information is used to create insights about our visitors' browsing habits on our Site. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see.

We also use this information for marketing purposes (see the MARKETING COMMUNICATION section below for further details). We will only drop non-essential cookies and other similar tracking technologies on devices with user consent.

Our legal basis for processing: It is in our legitimate interest to process any personal data collected via the cookie or other similar tracking technology to ensure that we can improve our services and tailor our marketing.

Who do we share personal data with for this purpose? We may share such personal data with our group companies, affiliates, third party vendors (such as our analytics providers or other IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

Marketing communications

We may carry out marketing activities using an individual's personal data. In particular, we may use personal data to form a view on what we think the individual may want or need, or what may be of interest to the individual. We may use that information to provide individuals with marketing information about our events and services we feel may be of interest. We may also provide individuals with information about media and public relations events.

We rely on our legitimate interest to process personal data in this way for marketing purposes (except where consent is required by local law in which case we will obtain consent). Where the individual is a consumer, we will only send electronic marketing communications or event invitations to such individual with their consent.

We also provide individuals with opt out choices regarding personal data uses, particularly around marketing and advertising. To see how you can opt out of marketing communications, please see the section entitled OPT OUT AND UNWANTED COMMUNICATIONS.

Please note if a third party asks us to share personal data so that they can send electronic marketing communications to particular individuals, we will obtain the relevant individual's consent prior to sharing the personal data for such purpose.

Who do we share personal data with for this purpose: We may share your data with our group companies, affiliates, promotions agents, third party vendors (such as our IT providers) or professional advisers or such other third parties as indicated in DATA SHARING section below in connection with this purpose.

SHARING YOUR PERSONAL DATA

We may share your personal data with any of our group affiliates, or with our agents, partners, clients, contractors, professional advisors or government or regulatory bodies for the following purposes:

• provide our services to clients or otherwise receive assistance in processing transactions
• fulfilment of requests for information, receiving and sending communications, updating marketing lists, analysing data
• provision of IT and other support services
• to facilitate the operation and effective management of our group of businesses
• comply with a legal obligation or in connection with a legal claim or dispute or to otherwise protect our legal rights
• assistance in other ancillary to the operation of tasks, from time to time

Our agents, partners and contractors will use your personal data to the extent necessary to perform their functions.

We will not sell your personal data to other companies and we will not share it with other companies for them to use without your consent, except in the circumstances listed above or in connection with the sale or merger of GNG.

Please note, the types of third parties we share your personal data with set out above is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to operate our Site and to provide our services. We will notify you of any other circumstances where we would share your information on a case by case basis.

OBTAINING YOUR CONSENT

We may transmit personal data outside the EEA to certain categories of third parties (as listed above in HOW WE USE YOUR PERSONAL DATA) and more specifically to our headquarters in Curacao.

• at the time that we collect your personal data following the instructions provided
• by informing us by e-mail, post or phone using the contact details set out in this Policy

Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.

DATA TRANSFERS OUTSIDE THE EEA

In particular when transferring your personal data outside the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented:

We may transmit personal data outside the EEA to certain categories of third parties (as listed above in HOW WE USE YOUR PERSONAL DATA) and more specifically to our headquarters in Curacao.

1. we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
2. where we use certain service providers, we may use specific contracts approved by the European Commission referred to as the 'model clauses' which give personal data the same protection it has in Europe
3. where we have partners or suppliers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US

CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA

We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.

To safeguard against unauthorized access to personal data by third parties outside our organization, all electronic personal data held by us is maintained on systems that are protected by up-to-date secure network architectures that contain firewalls and intrusion detection devices. The data saved in servers is 'backed up' (i.e. the data are recorded on separate media) to avoid the consequences of any inadvertent erasure, destruction or loss otherwise. The servers are stored in facilities with high security, access protected from unauthorized personnel, fire detection and response systems. The location of these servers is known to a limited number of our employees.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:

• unauthorized access
• improper use or disclosure
• unauthorized modification
• unlawful destruction or accidental loss

All of our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of the personal data of all users of our services.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain personal data only for as long as is necessary for the purposes described in this Policy, after which it is deleted from our systems.

Regarding personal data we have processed in connection with the supply of our services to clients, we may retain personal data relevant to our services for up to six years from the date of supply and in compliance with our obligations under the GDPR (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal data we have processed, we typically retain relevant personal data for up to three years from the date of our last interaction with the relevant individual and in compliance with our obligations under the GDPR (or similar legislation around the world), although we may keep it for longer if we have a justifiable reason to do so.

If any personal data is only useful for a short period (e.g., for a specific event, marketing campaign, or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate, we may keep your information for a short period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list so that we know not to send you further marketing communications in the future.

MODIFICATIONS TO THE POLICY

We reserve the right to modify this Policy as needed, for example, to comply with changes in laws, regulations, or requirements introduced by Data Protection Authorities (DPAs). Changes must be approved by our privacy points of contact, the office of the corporate legal department, or their designees, who will seek input as they reasonably deem appropriate from corporate executives for the amended Policy to enter into force.

If we make changes to the Policy, this amended Policy will be submitted for renewed approval according to the relevant applicable provisions of the law. We will inform data subjects of any material changes in the Policy. We will post all changes to the Policy on relevant internal and external websites.

Effective with the implementation of this Policy, all existing and applicable EU company privacy guidelines relating to the collection and/or processing of personal data will, where in conflict, be superseded by the terms of this Policy. No other internal policy that conflicts with this Policy shall be applicable with respect to the protection of personal data handled by us in the EU. We encourage you to review this Policy periodically to be informed of how we use your personal data.