Effective Date: June 2018
Last Updated: October 2021
Scope of This Policy
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 Sites, we may collect information about you and your use of the Sites, such as your:
Postal or other physical address
User ID and password if you establish an account with us
Login Date and Time
Client relationship management systems or identification and access management systems
Social media or other third-party sites.
Some examples of how you may provide your personal information to Broadway are as follows:
Searching and browsing for content;
Content or information included in or attached to your email in connection to raised support tickets;
Registering for newsletters and/or publications;
Participating in “join our mailing list” initiatives;
Participating in bulletin boards, online survey, discussion or message forums;
Registering for events and conferences;
Submitting resumes or work history information;
Contacting us for further information;
Visiting our Sites while logged into a social media platform;
Providing us with business cards or other contact information.
Our Use of Personal Data
Fulfill your requests for information or support
Process your request to participate in events
Personalize content that you view
Evaluate and improve the Sites or our products and services
Store your interests and preferences in order to optimize your use of the Sites or Broadway’s products and services,
Communicate with you (including for product support or billing issues)
Verify compliance with and enforce the terms of Broadway’s licenses and other agreement governing the use of our products and services
Carry out transactions with you
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.
Opting-out of Marketing Emails
If you want to unsubscribe from mailing lists or any registrations, you should look for and follow the instructions we have provided within the appropriate area(s) of the Sites or in the relevant communications to you. If 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
Broadway’s U.S. entities adhere to the EU-US Privacy Shield, as further described below.
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.
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.
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 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
Social Media Plug-Ins
Legal Grounds for Processing Personal Information
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.
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 record-keeping 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.
Our Commitment to the EU-US Privacy Shield Principles
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.
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. However, some third party sites do keep track of visitors’ browsing activities when they serve the visitors’ content, which enables them to tailor what they present to you. If you are visiting such sites, your web browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
We do not currently honor Do Not Track signals from internet browsers; when a universal standard for processing them emerges, we will follow it.
Broadway Technology, LLC
28 Liberty Street, 50th Floor
New York, NY 10005
Attention: General Counsel