Global AI and Data Strategy: Strategic Legal Compliance and Governance

Privacy Policy
This statement (“Privacy Notice” or “Privacy Policy”) provides information on how ICTLC, as better defined below, processes your personal data collected when you register and participate to the ICTLC Webinar Series (hereinafter, the “Service”).
ICTLC considers the protection of personal data as one of the main objectives of its activity. The processing of your personal data will be carried out in accordance with the principles of lawfulness, fairness, transparency, accuracy, purpose and storage limitations, data minimisation, integrity and confidentiality.

DATA CONTROLLER
The Data Controller of the processing activities described in this Privacy Policy is ICT Legal Consulting International B.V., with registered office in Piet Heinkade 55 – 1019 GM – Amsterdam – The Netherlands (hereinafter, “Data Controller”, “We” or “ICTLC”).

DATA PROTECTION OFFICER
We have appointed a Data Protection Officer (“DPO”) that you can reach out to for any information related to the processing of your personal data. You can contact at any time our DPO by writing to dpo@ictlc.com.

PERSONAL DATA SUBJECT TO PROCESSING
When you register for the ICTLC Webinar Series and join one of our webinars, we may collect the following personal data (“Personal Data”):

Personal Data you provide to us
When you fill out the form to register to our ICTLC Webinar Series, we ask you to provide personal information, such as your full name, e-mail address, job title, company you work for, etc.

Personal Data we collect through your use of the Service
We collect your Personal Data when you use the platform on which our webinars are hosted. This Personal Data may include:
- Details about your participation to our webinars
When you join our webinars, we automatically collect certain Personal Data related to you such as your viewing time of the webinar, whether you attended live or watched the replay, etc.
- Browsing data
The computer systems and software procedures used to operate the platform hosting our webinars collect some Personal Data, the transmission of which is an integral part of Internet communication protocols. While this information is not collected to be linked to you, it is still possible to identify you either directly via this information or using other information. This includes several parameters related to your operating system and IT environment, including IP addresses or domain names of the devices used, the URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as a reply, the numeric code indicating the status of the reply given by the server (successful, error, etc.).
This data is used for the purposes of obtaining anonymous statistics on the use and proper functioning of the website to control its correct functioning, to enable us to correctly provide the various functionalities to you, as well as for security reasons.
- Cookies and similar technologies
You may find further information on the use of cookies and similar technologies at the bottom of this Privacy Policy.

PURPOSES AND LEGAL BASIS OF THE PROCESSING
Personal Data that that we collect from you will be processed for the purposes and the legal basis indicated below.
a. Provision of the Service
We may process your Personal Data to provide you with our webinars and related services and to respond to your requests, where appropriate.
The legal basis for this processing is the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
b. Compliance
We may process your Personal Data to comply with a legal obligation, a regulatory provision or an order of the competent authorities to which we are subjected.
The processing for this purpose is necessary for us in order to fulfil any legal obligations applicable to us.
c. Analysis
We may process your Personal Data to do analysis regarding the company or organisation you are a part of, to understand its business needs.
The legal basis for this processing is our legitimate interest in understanding the companies to which participants in our webinars belong and improve our services accordingly.
Please be informed that you may object at any time to processing for such purposes by writing to privacy@ictlc.com.
d. Offering similar services
We may process your Personal Data to promote via e-mail webinars and services similar to the Service you have already requested.
Such processing is based on our legitimate interest to send you our communications regarding services similar to those you have already requested since we consider your company or organisation might be interested in, unless you objected to such processing initially or in subsequent communications. Please be informed that you may interrupt the receipt of our promotional communications, without any consequence for you, using the link at the bottom of each of these communications or writing to privacy@ictlc.com.

VOLUNTARY OR OBLIGATORY NATURE OF PROVIDING THE DATA
Notwithstanding the need to comply with legal obligations, the provision of your Personal Data for the purposes related to the Provision of our services is optional. However, failure to provide it may result in the inability of providing our webinars and related services and responding to your requests.
Providing your Personal Data for the purpose of Analysis and Offering similar services is optional and, should you object to such processing, you will still be able to use our Service.

RECIPIENTS
Your Personal Data may be shared with the subjects mentioned below (collectively “Recipients”):
• subjects typically acting as data processors such as third parties we engaged to provide our services (for instance hosting providers or e-mail providers) or persons, companies or professional firms providing ICTLC with advice and consulting in accounting, administrative, legal and tax matters;
• persons authorised by ICTLC to process Personal Data, that are committed to/ or under an appropriate statutory obligation of confidentiality (e.g., employees and collaborators of ICTLC);
• public entities, bodies, or authorities to disclose your Personal Data to in accordance with Compliance purpose or under the orders of the authorities.

TRANSFERS
Your personal data are processed within the European Economic Area and are not subject to transfer. In any case, should there be a transfer of your Personal Data to Recipients located outside the European Economic Area, we ensure that your Personal Data will be transferred to these Recipients in accordance with the applicable rules on data protection. Indeed, any possible transfer of your Person Data will be performed based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission.

DATA RETENTION
Personal Data processed for the purpose of Provision of the Service will be kept by ICTLC for the period deemed strictly necessary to fulfil such purpose. In any case, as these Personal Data are processed for the provision of our services, the Company will retain them for a longer period of time, particularly as may be necessary under applicable law to protect ICTLC’s rights and interests against possible claims.

Personal Data processed for the purpose of Compliance will be retained by ICTLC for the period provided for by specific legal obligations or applicable law.

Personal Data processed for the purposes of Analysis and/or Offering similar services will be kept by ICTLC until you object to such processing.

YOUR RIGHTS
You are entitled to request at any time the access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing, in the cases set out in Article 21 of the GDPR. You are also entitled to request the restriction of the processing of your Personal Data in the cases set out in Article 18 of the GDPR, as well as to obtain the Personal Data you have provided in a structured, commonly used, and machine-readable format, in the cases set out in Article 20 of the GDPR (portability).
Requests should be made in writing and addressed to privacy@ictlc.com.
You may also interrupt at any time the reception of our communication for purposes related to Offering similar services, by using the relevant link you may find at the bottom of each communication you receive.

COMPLAINT WITH THE SUPERVISORY AUTHORITY
Please note that you entitled to file a complaint with the competent Supervisory Authority (Autoriteit Persoonsgegevens) if you believe that the processing of your Personal Data infringes your rights and the applicable law.

AMENDMENTS
This Privacy Policy came into force on 31 May 2023. We reserve ourselves the right to amend or simply update the content of the Privacy Policy, whether in part or in its entirety, also considering any changes in the applicable law. We therefore invite you to visit this section of the website regularly to become aware of the most recent and updated version of the Privacy Policy so that you are always updated on the processing activities that we carry out.

Cookie Policy

Definitions, characteristics, and application of standards
Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.
Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.
When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).
On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law. To the extent applicable to the webpage made available by the third-party on which our webinars will be hosted, no profiling cookies are installed.

Types of cookies used
The webpage which allows you to join our webinars is hosted on a third-party website. With specific regard to this webpage, the following types of cookies may be used:
• Browsing or session cookies, which are strictly necessary for the webpage’s operation, and/or to allow you to use the webpage’s content and services.
• Analytics cookies, which allow us to understand how users make use of the webpage, and to track traffic to and from the webpage.
• Function cookies, which are used to activate specific webpage functions and, where appropriate, to configure the webpage according to your choices (e.g., language), in order to improve your experience.

Cookie settings
You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform=Desktop&hl=en-GB
• Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
You may also provide set your preferences on third-party cookies by using online platforms such as AdChoice (http://optout.aboutads.info/#!/).

CAUTION: If you block or delete technical and/or function cookies used by the website, the website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.