We may disclose your personal information to a third party for a business purpose. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers.
• California Customer Records personal information categories.
• Commercial Information.
• Professional or employment-related information.

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.

We do not provide these access and data portability rights for B2B personal information.

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 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 provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
• Debug products to identify and repair errors that impair existing intended functionality.
• 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 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us, such as future field campaigns or product safety issues.
• 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.

We do not provide these deletion rights for B2B personal information.

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:

• Calling us at toll free at 866-230-4843
• Emailing us at privacy@glg.it

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 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 authorized representative, which may include:
  • Your name
  • Email Address
  • Additional information depending upon the type of request and the sensitivity of the information.
• 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.

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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Under PIPL, “personal data” is all kinds of information, whether recorded in electronic or another format, that relates to an identified or identifiable natural person, excluding anonymized information; “sensitive personal data” refers to personal data that, if leaked or if used illegally, is likely to cause harm to a natural person’s personal dignity or endanger their personal safety or the safety of their property, as well as the personal data of minors under the age of 14.

We collect and process personal data, including sensitive personal data (but only that of our employees and Network Members) only for specified, explicit and reasonable purposes and to the extent directly relevant to the purposes of processing. We will process your personal data (including sensitive personal data) in a way that has the least impact on your personal rights and interests (for example, grant access to personal data to necessary personnel only, use encryption technologies during transmission and storage of sensitive personal data when necessary). Our collection of personal data is described in Section B (Collection of Personal Data) and Section O (Cookies and Similar Technologies) of the Privacy Policy.

The personal data collected and processed by us is outlined in the below paragraphs, and the personal data that might constitute sensitive personal data is underlined in the following paragraphs. We will process sensitive personal data only if strict protection measures are put in place and there is sufficient necessity to justify the processing. It is necessary for us to process your sensitive personal data in order to perform the specific Services you request from us and for other specific purposes described in this China Privacy Notice.

• Personal details: given name(s); preferred name; and photograph (if provided).
• Demographic information: date of birth; salutation; title; and language preferences.
• Network Member data: With respect to Network Members (in addition to any other applicable category set out in this Notice), we also collect wireless device addresses (including text message addresses), payment information, professional biography, and other profiling information pertaining to your experience and expertise.
• Contact details: address; telephone number; email address; and details of your public business networking profile(s) or online biographies.
• Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Payment details: invoice records; payment records; billing address; payment method; bank account number; BACS details; SWIFT details; IBAN details; payment amount; and payment date.
• Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; aggregate statistical information; internet service provider (ISP) details; referring and exit pages; and clickstream data.
• Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant.

Pursuant to PIPL, we may process personal data if one of the following options applies:

• Relevant data subject has given prior consent to processing of their personal data for one or more specific purposes;
• Processing of personal data is necessary to conclude or perform a contract to which the data subject is party;
• Processing is necessary for compliance with any statutory duties or legal obligations;
• Processing is necessary in order to, in an emergency, protect the lives, health or property of natural persons;
• The personal data has been made public by the data subject concerned or has otherwise been lawfully made public, the processing is done pursuant to the PIPL and the extent of the processing is reasonable; or
• Processing is done in other circumstances provided for in applicable laws or administrative regulations.

GLG’s information systems are owned and maintained by Gerson Lehrman Group, Inc. in the United States, and are utilized by all of its subsidiaries and affiliates, including Gerson Lehrman Group (Shanghai) Co., Ltd.   A full list of GLG Inc.’s subsidiaries and affiliates can be found here:  glg.com/about/contact-locations.

We will take necessary measures required by laws including obtaining your separate consent, entering into standard contractual clauses with the overseas recipient to stipulate the rights and obligations between us, and will ensure that the foreign receiving party provides adequate protection for your personal information under applicable laws.

To the extent required by applicable law, we will, before sharing your personal data with such recipient, notify you of the name and contact details of the recipients, the purposes and means of processing and provision of your personal data, and the types of personal data to be provided and shared, and obtain your consent to the sharing of your personal data.

In any case, we will only share and transfer your personal data for specific and definite purposes pursuant to the principles of lawfulness, fairness, necessity and good faith, and only share and transfer the personal data to the extent necessary for the specific purposes you are informed of. If we share your personal data with the foregoing recipients, we may use encryption, anonymization and other means as necessary and appropriate to ensure your personal data security. Before sharing or transferring your personal data, we will follow and adopt the applicable process and requirements required by the applicable law in respect of transfer of your personal data.

The foregoing data recipients will use the personal data to the extent necessary for the specific purposes you are informed of and store the personal data for the minimum length of time required to fulfil the purposes, or as prescribed by the applicable law.

The PIPL provides certain rights to China data subjects. These include rights of: knowing about and deciding on the processing of your personal data; access to and making copy of your personal data; correction and supplement of inaccurate or incomplete personal data; portability; withdrawal of consent with future effect; deletion; and requesting explanations of the rules governing the processing of your personal data. This section provides more information about those rights and how a China data subject can exercise these rights under the PIPL.

For GLG to fulfill any request related to your personal data, you must provide sufficient information for us to reasonably verify that you are the data subject from whom we collected the personal data. The information you send for us to verify your identity will be used for this purpose only. If we are unable to verify your identity or if we suspect fraudulent activity, we may decline to comply with your request.

We will make commercially reasonable efforts to identify your personal data that we collect, process, store, disclose and otherwise use and to respond to your requests. In addition, we will not honor your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law. If we deny your request, we will explain the reasons in our response.

RIGHT TO ACCESS

• China data subjects have a right to access and obtain a copy of their personal data.
• You can exercise your right to access your personal data by contacting GLG via the means provided in Section R (Contact Details) of the Privacy Policy.

RIGHT TO DELETION

• Subject to the following conditions, China data subjects have the right to request deletion of their personal data when:
  • the processing purpose has been achieved or is unachievable or the personal data is no longer necessary to achieve the processing purpose;
  • we have ceased to offer the products or services or the retention period has expired;
  • the data subject has withdrawn their consent;
  • we have processed personal data in violation of a law or administrative regulation or in breach of the Privacy Policy and this China Privacy Notice; and
  • other circumstances provided for in laws or administrative regulations.
• If the retention period provided for in laws or administrative regulations has not yet expired or the personal data would be technically difficult to delete, we will cease the processing except for storage and the taking of necessary security protection measures.
• You can exercise your right to deletion of your personal data by contacting GLG via the means provided in Section R (Contact Details) of the Privacy Policy.

OTHER RIGHTS

• You can exercise your other privacy rights, including your right of knowing about and deciding on the processing of your personal data, correction and supplement of inaccurate or incomplete personal data, portability, withdrawal of consent with future effect and requesting explanations of the rules governing the processing of your personal data by contacting GLG at the information provided in Section R (Contact Details) of the Privacy Policy.