This CCPA NOTICE FOR CALIFORNIA RESIDENTS (“Notice”) supplements the information contained in the Privacy Policy of Broadsword Event House Americas Inc. and its affiliates (collectively, ​“Broadsword,” ​“Company,” ​“we,” ​“us,” or ​“our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or ​“you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.

 

Information We May Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we may have collected the following categories of Personal Information from consumers within the last twelve (12) months:

 

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, colour, ancestry, national origin, citisenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.	NO

 

Personal information does not include:

Publicly available information from government records.

De-identified or aggregated consumer information.

Information excluded from the CCPA’s scope, like:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from you from the information you provide to us. For example, from your communications and dealings with us.

Directly and indirectly from activity on our website (www.Broadsword.com). For example, from submissions through our website portal or website usage details collected automatically, or from employment applications submitted through our website.

Directly from you via sales. For example, processing and fulfilling orders or requests for customer support.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfil or meet the reason for which the information is provided. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry.

To provide you with information that you request from us.

To provide you with support and to respond to your inquiries.

To provide you with email alerts, event registrations and other notices concerning our products, events, or news, which may be of interest to you.

To review and process employment applications.

To improve our website and present its contents to you.

As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.

 

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.

Service providers, such as for sales, marketing, customer service, data storage, and employment applications.

Third parties to whom you or your agents authorise us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information. We do not share, sell, rent, or trade your personal information with third parties for their commercial purposes.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.

The categories of sources for the personal information we collected about you.

Our business or commercial purpose for collecting or selling that personal information.

The categories of third parties with whom we share that personal information.

The specific pieces of personal information we collected about you (also called a data portability request).

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

sales, identifying the personal information categories that each category of recipient purchased; and

disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Email using the links contained in this notice.

Calling our office: +1 917 672 8539

Only you or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12)-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12)-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the ​“right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorisation (the ​“right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorised representative) may submit a request to us by visiting the following Internet Web page link:

DO NOT SELL MY PERSONAL INFORMATION

privacy.americas@wearebroadsword.com

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorise personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting us at privacy.americas@wearebroadsword.com with the subject header: Opt-In to Personal Information Sales and providing your name and contact information.

Non-Discrimination

We will not discriminate against you (as provided in applicable law) for exercising any of your CCPA rights.

Other California Privacy Rights

The California ​“Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will notify you through a notice on our website homepage. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us via the options above or at:

Broadsword Event House Americas Inc

privacy.americas@wearebroadsword.com

99 Wall Street

Suite 1250

New York

NY 10005

 

United States of America – Privacy Notice

This notice provides and outlines the Broadsword Event House Americas Inc, (the Company) privacy policy regarding the nature, purpose, use, and sharing of any Personally Identifiable Information (PII) collected via this website. Our privacy policy explains our information practices when you provide PII to us, whether collected online or offline, or when you visit us online to browse, obtain information, or conduct a transaction. PII may include: your name, email, mailing and/​or home address, phone numbers, or other information that identifies you personally. We do not require you to register or provide personal information to visit our website.

The PII you provide on the Company website will be used only for its intended purpose. We will protect your information consistent with the principles of the Privacy Act of 1974.

Personally Identifiable Information

As a general rule, the Company does not collect PII about you when you visit our website, unless you choose to provide such information to us. Submitting PII through our website is voluntary. By doing so, you are giving the Company your permission to use the information for the stated purpose. However, not providing certain information may result in the Company’s inability to provide you with the service you desire.

If you choose to provide us with PII on a Company website, through such methods as completing a web form or sending us an email, we will use that information to help us provide you the information or service you have requested or to respond to your message. The information we may receive from you varies based on what you do when visiting our site.

Generally, the information requested by the Company will be used to respond to your inquiry or to provide you with the service you request. When this information is requested, the reasons for collecting it, a description of the Company’s intended use of the information, how to grant consent to use mandatorily provided information, and how to grant consent for other than statutorily mandated uses will be fully described in a separate customized ​“Privacy Notice.” This customized Privacy Notice will either appear on the web page collecting the information or be accessible through a hyperlink (link) prominently displayed immediately above or below the information request.

 

Email

Many of our programs and websites allow you to send us an email. We will use the information you provide to respond to your inquiry. We will only send you general information via email. You should be reminded that email may not necessarily be secure against interception. Therefore, we suggest that you do not send sensitive personal data (such as your Social Security number) to us via email. If your intended email communication is very sensitive, or includes information such as your bank account, credit card, or Social Security number, you should instead send it by U.S. mail. Another alternative may be submission of data through a secure web page, if available.

Categories of information the Company collects on its websites are further described below.

Automatically Collected Information

We collect and temporarily store certain information about your visit for use in site management and security purposes only. We collect and analyze this information because it helps us to better design our website to suit your needs. We may also automatically collect information about the web content you view in the event of a known security or virus threat. This information includes:

1. The Internet domain from which you access our website (for example, ​“xcompany.com” if you use a private Internet access account, or ​“yourschool.edu” if you connect from an educational domain);

2. The Internet Protocol (IP) address (a unique number for each computer connected to the Internet) from which you access our website;

3. The type of browser (e.g., Firefox, Internet Explorer, Chrome) used to access our site;

4. The operating system (e.g., Windows, Mac OS, Unix) used to access our site;

5. The date and time you access our site;

6. The Universal Resource Locators (URLs), or addresses, of the pages you visit;

7. Your username, if it was used to log in to the website; and

8. If you visited this website from another website, the URL of the forwarding site.

We may share the above information with our employees or representatives with a ​“need-to-know” in the performance of their official duties, other Federal agencies, or other named representatives as needed to quickly process your request or transaction. This information is only used to help us make our site more useful for you. Raw data logs are retained temporarily as required for security and site management purposes only. More information about how we share information can be found in our Privacy Act Systems of Records Notices.

 

Third-Party Websites and Applications

The Company uses social media websites and other kinds of third-party websites. The Company uses social media websites to interact with foreign constituencies and engage in public diplomacy worldwide. Social media websites are used to publicize embassy and Company events, and engage with members of the public in foreign countries. The Company also uses web measurement and customization technologies to measure the number of visitors to our websites and their various sections and to help make our websites more useful to visitors. In such cases, the third-party application may request an email address, username, password, and geographic location (e.g., State, region, or ZIP code) for account registration purposes. The Company of State does not use third-party websites to solicit and collect PII from individuals. Any PII passively collected (i.e., not solicited) by the third-party website will not be transmitted or stored by the Company; no PII will be disclosed, sold or transferred to any other entity outside the Company, unless required for law enforcement purposes or by statute.

The Company uses various types of online surveys to collect opinions and feedback from a random sample of visitors. Primarily, state.gov uses the ForeSee Results’ American Customer Satisfaction Index (ACSI) online survey on an ongoing basis to obtain feedback and data on visitors’ satisfaction with the state.gov website. This survey does not collect PII. Although the survey invitation pops up for a random sample of visitors, it is optional. If you decline the survey, you will still have access to the identical information and resources at the state.gov site as those who do take the survey. The survey reports are available only to state.gov managers and other designated staff who require this information to perform their duties. The Company may use other limited-time surveys for specific purposes, which are explained at the time they are posted.

The Company retains the data from the ACSI survey results as long as needed to support the mission of the state.gov website.

Information Collected for Tracking and Customization (Cookies)

A cookie is a small file that a website transfers to your computer to allow it to remember specific information about your session while you are connected. Your computer will only share the information in the cookie with the website that provided it, and no other website can request it. There are two types of cookies:

• Session: Session cookies last only as long as your web browser is open. Once you close your browser, the cookie is deleted. Websites may use session cookies for technical purposes such as to enable better navigation through the site, or to allow you to customize your preferences for interacting with the site.

• Persistent: Persistent cookies are saved on a user’s hard drive in order to determine which users are new to the site or are returning, and for repeat visitors, to block recurring invitations to take the ForeSee satisfaction survey.

If you do not wish to have session or persistent cookies stored on your machine, you can turn cookies off in your browser. You will still have access to all information and resources at Company websites. However, turning off cookies may affect the functioning of some Company websites. Be aware that disabling cookies in your browser will affect cookie usage at all other websites you visit as well.

 

Security

The Company takes the security of all PII very seriously. We take precautions to maintain the security, confidentiality, and integrity of the information we collect at this site. Such measures include access controls designed to limit access to the information to the extent necessary to accomplish our mission. We also employ various security technologies to protect the information stored on our systems. We routinely test our security measures to ensure that they remain operational and effective.

We take the following steps to secure the information we collect:

• Employ internal access controls to ensure that only personnel who have access to your information are those with a need to do so to perform their official duties.

• Train appropriate personnel on our privacy and security policies and compliance requirements.

• Secure the areas where we retain paper copies of the information we collect online.

• Perform regular backups of the information we collect online to ensure against loss.

• Use technical controls to secure the information we collect online including, but not limited to:

• Secure Socket Layer (SSL)

• Encryption

• Firewalls

• Password protections

• Employ external access safeguards to identify and prevent unauthorized access by outsiders that attempt to ​“hack” into, or cause harm to, the information contained in our systems.

We hold our contractors and other third-party providers to the same high standards that we use to ensure the security, confidentiality, and integrity of personal information they may have access to in the course of their work completed on behalf of the Company.

Interaction With Children Online

The Company is committed to the protection of children’s online privacy. The Children’s Online Privacy Protection Act (COPPA) governs information gathered online from or about children under the age of 13. Verifiable consent from a child’s parent or guardian is required before collecting, using, or disclosing personal information from a child under age 13. If a Company website intends to collect information about children under 13 years old, COPPA-required information and instructions will be provided by the specific web page that collects information about the child. The web page will specify exactly what the information will be used for, who will see it, and how long it will be kept.