Privacy Policy

• Effective Date:         June 2018
  Last Updated:          October 2022

Overview
Protecting consumer privacy is important to Broadway Technology LLC (“Broadway” “we” or “us”). This privacy policy explains what personal information Broadway and its affiliates gather about you, for what purpose we use that information , and to whom we give that information  in our capacity as data controllers, how we secure your personal data, and when we may transfer your personal data outside of your home jurisdiction. This privacy policy also describes your rights regarding the personal data that we hold about you, including how you can access, correct, and request erasure of your personal data. It also sets out your rights in relation to your information and whom you can contact for more information or queries. We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

About Broadway
Broadway Technology is a global company. You acknowledge and consent that any information you provide or we may collect pursuant to this policy may be used, processed or transferred to the United States or other countries or territories and that those countries or territories may not offer the same level of protection as the country where you reside. In the privacy policy, the terms “Broadway”, “we” or “us” refers to Broadway Technology, LLC and its affiliates globally.

Terminology
In this privacy policy, your information is sometimes called “personal data,” “data” or “personal information.” Personal data does not include information that is encoded or anonymized or publicly available information that has not been combined with non¬public personal data. We also sometimes collectively refer to handling, collecting, protecting or storing your personal information as “processing” such personal information. And our “agents” are any third party that collects or uses personal information pursuant to our instructions or to which we disclose personal information for use on our behalf.

Scope of This Policy

This privacy policy applies to personal data that we may receive, collect or process about you when you visit the broadwaytechnology.com website and third party sites maintained by or on behalf of Broadway such as our support site, knowledge base or employment recruiting portals (“Site“).

• This policy also applies to the business contacts of Broadway’s third-party service providers, vendors, partners, agents or other similar such entities (where required to manage and administer Broadway’s business relationships with such entities) as well as the business contacts of Broadway’s current, former or prospective client of Broadway, except as provided for in a contractual arrangement.

How We Collect Personal Data
When you use the Site, we may collect information about you and your use of the Sites, such as your:

• Name
• Job title
• Company name
• Postal or other physical address
• Email address
• Telephone
• IP Addresses
• Login Date and Time
• Log data

Some examples of how you may provide your personal information to Broadway are as follows:

• Searching and browsing for content;
• Registering for newsletters and/or publications;
• Participating in “join our mailing list” initiatives;
• Registering for events and conferences;
• Submitting resumes or work history information;
• Contacting us for further information;
• Visiting our Site while logged into a social media platform;
• Providing us with business cards or other contact information.

Our Use of Personal Data
The personal data we collect may be used where we have your specific consent to do so, or where Broadway has a legitimate interest in or other legal basis for processing such information. We will disclose personal information if it’s necessary to comply with a legal obligation, prevent fraud, enforce our terms of use or customer agreements, or protect our users’ safety or security. In some situations, the collection of personal data may be required for the operation of the Sites or to provide certain services or products. In particular, Broadway may use your personal data to:

• Fulfill your requests for information or support
• Process your request to participate in events
• Personalize content that you view
• Evaluate and improve the Site or our products and services
• Store your interests and preferences in order to optimize your use of the Site;
• Communicate with you 
• Authenticate users
• Distribute newsletters and alerts to you, and for other marketing purposes
• Recruit and evaluate job applicants
• Analyze the Site’s performance and functioning
• Comply with all applicable laws and corporate reporting obligations
• Accomplish other purposes you may initiate or request

Broadway uses personal data only in ways that are compatible with and relevant to the purposes for which it was collected or authorized by you. We may keep any of your personal data on file and use it to contact you. We will take reasonable steps to ensure that personal data is accurate, complete, current and reliable for its intended use.

Consent
If you choose to provide sensitive data to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local law, for us to collect and use that information in the ways described in this privacy policy or as described at the point where you choose to disclose this information.

Opting-out of Marketing Emails
Broadway may transmit marketing emails. Broadway may require you to register. If you want to unsubscribe from mailing lists or any registrations, you should look for and follow the instructions we will provide within the appropriate area(s) of the Sites or in the relevant communications to you. If we send emails or marketing communications and you do not wish to receive emails or marketing communications from us, you can at any time contact us to request that such communications cease. If you wish to unsubscribe or no longer receive only certain communications, please identify such communications in your request. If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honor your request.

Transfers to Third Parties
International Transfers
Personal data collected in accordance with this privacy policy may be transferred to Broadway affiliates and their personnel across our global organization, as well as to our third-party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. As a result, your personal information may be transferred to and stored outside the country where you are located. This includes countries outside the European Economic Area (EEA) and countries that do not have laws that provide specific protection for personal information. Where we collect your personal information within the EEA, transfer outside the EEA will be only: (a) to a recipient located in a country which provides an adequate level of protection for your personal information; and/or (b) under an agreement which satisfies EU requirements for the transfer of personal data to data processors or data controllers outside the EEA. By using the Sites and providing information to use in accordance with this privacy policy, you voluntarily consent to such trans-border transfer and hosting of such information. Broadway’s U.S. entities adhere to the provisions of the UK GDPR and the GDPR, as further described below.

Our Agents
When we transfer personal data to our agents, we do so for the purposes for which the information has been submitted, for the purposes listed above under Our use of personal data, for the administration and maintenance of the Sites and associated systems, and/or other internal or administrative purposes. Our agents may include service providers that provide services such as IT and system administration and hosting, research and analytics, marketing, and recruiting. If we are made aware that an agent is using or sharing personal data in a way that is contrary to this policy, we will take reasonable steps to prevent or stop such processing. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this privacy policy and protects the confidentiality, availability, and integrity of your personal data.

Other Disclosures
In addition, we may disclose information about you:

• If we are required to do so by law or legal process
• To law enforcement authorities or other government officials
• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity
• If disclosure is necessary to protect the vital interests of a person
• To protect our property, services and legal rights
• To prevent fraud against Broadway, our subsidiaries, affiliates and/or business partners
• To support auditing, compliance, and corporate governance functions, or
• To comply with any and all applicable laws

We may also disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

Security
We care about your data and are committed to protecting the data you provide us. We use industry-standard security technologies, procedures and organizational safeguards to protect your personal data from unauthorized access, use and disclosure. We treat personal data as an asset that must be protected against loss and unauthorized access. We employ various security practices to protect your personal data from unauthorized users and recommend you take every precaution in protecting your Personal Data when you are on the Internet.

Gathering of Information
We may collect personal data from you automatically using methods such as cookies and similar technologies from your computer or mobile device while you navigate our Website or interact with emails we have sent you. Information collected may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, browser type, internet service provider and/or mobile carrier, the pages and files you viewed, your searches, actions taken on our Sites, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our Sites and to guarantee their security and continued proper functioning.

Cookies
Broadway may place a cookie on your browser of when you visit the Site, which can collect information, including personal data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine areas that you prefer, and make usage of the Sites easier by recognizing you so we can provide you with a personalized experience. We use both temporary and permanent cookies to identify users of our services and to enhance user experience. Cookies expire after a certain period of time, depending on the purpose. You can control the use of cookies at the individual browser level but disabling cookies may limit access to certain features or functions on the Sites or services. In addition, we have implemented certain Google Analytics features on our website. Visitors to our website may opt out of Google Analytics by either downloading the Google Analytics opt-out browser add-on or viewing its Customer Ads Help Center.

Web Beacons
We also use web beacons on our Sites. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Sites. Such tracking technologies are used to operate and improve our Sites and email communications and track the clicking of links or opening of emails.

Links, Third Party Applications, and Software
The Sites may contain links to other sites or may give you access to applications, software, or products provided by third parties (“Third Party Sites and Products”). Please understand that those Third-Party Sites and Products may have different terms of use and privacy policies. You should review those terms of use and privacy policies prior to using them. We are not responsible for the privacy practices of any Third-Party Sites and Products. We are also not responsible for the terms of use you may be required to agree to in order to use such Third-Party Sites and Products.

Social Media Plug-Ins
The Sites may also offer you the ability to interact with plugins from social media sites such as Facebook (facebook.com), LinkedIn (linkedin.com) and Twitter (twitter.com). Those social media sites may receive data when you visit a website that contains plugins. In some cases, we may know that you clicked on a social plugin such as a Facebook Like button or receive other information from the social media sites. Similarly, if you have previously provided personally identifiable information to a third-party operating a plug-in on a Broadway Site, then that third-party may recognize you on that website. Use of social network plugins is subject to each social media site’s privacy policy, which may be different from ours. As with linked sites, we have no control over the information that is collected, stored, or used by social network plugins. For further information please refer to the relevant social media site.

Legal Grounds for Processing Personal Information
Your local law may require us to set out in this privacy policy the legal grounds on which we rely in order to process your personal information. In such cases, we rely on one or more of the following processing conditions:

• our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (provided these do not interfere with your rights);
• to satisfy any legal and regulatory obligations to which we are subject; or
• where no other condition for processing is available if you have agreed to us processing your personal information for the relevant purpose.

Rights in Relation to Your Information
You may have certain rights under your local law in relation to the personal information we hold about you. In particular, if you are an individual whose personal data, and the processing of that personal data by Broadway, are subject to the application of the European General Data Protection Regulation, you have the following rights:

• Right of Access: This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it, and that it is accurate, complete and current.
• Right of Correction: This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Right of Erasure: This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to objection
• Right to Objection: Where we are relying on a legitimate interest as justification, or where it is used for direct marketing purposes, you have the right to object to the processing of your personal information.
• Right of Restriction: You have the right to request that we restrict the processing of your personal data in certain situations:
  
  • If you contest the accuracy of your personal data, you may request that its processing is restricted while we verify its accuracy.
  • If the processing of your personal data is considered unlawful, but you do not require the deletion of your personal data.
  • If we no longer need the data for the purposes of its processing, but you need it for the establishment, exercise or defense of legal claims.
  • If you object to our processing of your data based on our legitimate interests, or where the processing is based on Art. 6(1) (e) GDPR and UK GDPR.
• ­Right of Data Portability: When the processing takes place on the basis of your consent or contract, and is carried out by automated means, you have the right to request that we provide your personal data to you in a machine-readable format;
• Right to withdraw consent: If your personal data is processed on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, for example where producing your information may reveal the identity of someone else.

Retention of Personal Information
We will retain your personal information on our systems only for as long as we need it, given the purposes for which it was collected, in accordance with our internal recordkeeping policies, or as required to do so by law. The exact length of time will vary and may be subject to applicable contracts or agreements. We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honor your request. We dispose of resumes when they are no longer under consideration.

California Privacy Disclosures
Pursuant to California Civil Code Section 1798.83(c)(2), Broadway does not share your personal data with third parties for those third parties’ direct marketing use. This Section permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information, if any, for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. If you are a California resident and would like to request this information, please use our Contact Information is below. Broadway does not track website visitors over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.  We do not currently honor Do Not Track signals from internet browsers; when a universal standard for processing them emerges, we will follow it.

Contact Information
You may contact us regarding this privacy policy, our data collection and processing practices or to opt-out using the following information: 

Broadway Technology, LLC
99 Wall Street, #4950
New York, NY 10005
privacy@broadwaytechnology.com

Amendments
Broadway may update this Privacy Policy at any time by publishing an updated version here.