Recursion Software

Effective date: November 2023

Introduction and Privacy Policy

This Privacy Policy governs the manner in which Headley Media Limited (company number 03183235) collects, uses, maintains and discloses information collected from users (each, a "User") of the www.itcorporate.asia website ("Site"). This privacy policy applies to the Site and all products and services offered by Headley Media Limited

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of personal information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.itcorporate.asia.

This document includes:

1. How we safeguard your data
2. The legal basis we have for processing your data
3. How and when we share your personal data with others
4. Types of Data we collect and how we collect it
5. How we use your data
6. Your Rights and Preferences Under General Data Protection Regulation (GDPR)

How we safeguard your data

Headley Media Limited are committed to protecting and safeguarding your personal information in accordance with current legislation and GDPR. Headley Media Limited will always process your personal data responsibly and securely at all times. Personal information that has been provided by our readers enables us to enhance our service and provide the most appropriate marketing, information and service for users. We will process this data under legitimate interest in accordance with GDPR. Readers may opt out of future communications through unsubscribing to email promotions or via email: dataprotection@headleymedia.com

Headley Media Technology Division are committed to protecting and safeguarding your personal information in accordance with current legislation of the California Consumer Privacy Act (CCPA) where applicable and General Data Protection Regulation (GDPR). Headley Media Limited adheres to the CCPA consumer rights of:

1. right to notice
2. right to access
3. right to opt out (or right to opt in)
4. right to request deletion
5. right to equal services and prices

Headley Media Technology Division adheres to the POPIA principles of:

• accountability
• transparency
• security
• data minimization
• purpose limitation
• rights of data subjects

In accordance with the latest consumer data privacy laws in the US, we are fully compliant with the 13 US states that have passed data privacy laws:

• California (CCPA)
• Virginia (VCDPA)
• Colorado (CPA)
• Connecticut (CTDPA)
• Utah (UCPA)
• Iowa (ICDPA)
• Indiana (Indiana Consumer Data Protection Act)
• Tennessee (Tennessee Information Protection Act)
• Texas (TDPSA)
• Florida (Florida Privacy Protection Act)
• Montana (Montana Consumer Data Privacy Act)
• Oregon (OCPA)
• Delaware (Delaware Personal Data Privacy Act)

While each state approaches data privacy regulation in different ways, the obligations imposed and rights created under the US Consumer Privacy Laws are similar in many respects, and Headley Media maintains the ability to adjust to new developments under these (and other) state privacy laws while implementing the requirements set forth.

The legal basis we have for processing your data

The legal basis for processing your personal data is your consent. In certain circumstances we may alternatively process your personal data if Headley Media Limited has a legitimate interest in doing so.

Headley Media Limited follow the principle of data minimisation, ensuring the personal data collected is kept to a minimum at all times (Art.5). The Personal Data we process is restricted to Business Card Information of corporate employees who are directly linked to technology implementations and decision making. An extensive assessment has been completed, ensuring the personal data we process does not disproportionally affect the privacy rights of our readers. We practice transparency by clearly informing all readers that we are processing their personal data, and for what purposes (Art. 13 and 14). We will endeavour to keep all reader data up to date at all times (Art.5).

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have tried to provide the links to third party privacy policies throughout our website where possible. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

How and when we share your personal data with others

Headley Media Limited may share your personal data to deliver content and services from our sites and third parties services that might interest you, including sponsored content.

Sponsored Content and Third Parties

Headley Media Limited partners with third party sponsors to make available a large library of content to our readers, such as white papers, videos, case studies and Webinars. In return for access to our library and to download content, we may ask you to provide us with your personal data as part of the registration and/or update your existing details.

As stated previously, Headley Media Limited follow the principle of data minimisation, ensuring the personal data collected is kept to a minimum at all times (Art.5). The Personal Data we process is restricted to Business Card Information of corporate employees who are directly linked to technology implementations and decision making.

We may also use your personal data to send you the offer you requested or to follow up a previously downloaded resource with additional content and/or other related resources of those in which you have chosen to request. In addition to this, your personal data may be shared with the sponsor and/or sponsors of the content to communicate with you regarding the offer, as well as additional products, content or services that may be of interest to you.

Please note that once your personal data is shared with the third party/ sponsor, their privacy policy, including information on how to opt-out in the future, will apply to your personal data. We have tried to provide the links to third party privacy policies throughout our website where possible. We do not accept any responsibility or liability for the privacy practices of such third parties of sponsors.

Furthermore, we will also ask for your consent to have your details passed to the third party sponsor and/or sponsors at the point of download, offering you the opportunity to opt out of having your details shared and protecting your privacy.

Types of Data we collect and how we collect it

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at dataprotection@headleymedia.com.

How we use your data

We may use the information you share with us and the information we collect through your use of our sites in the ways described below and as described at the time of capture. Headley Media Limited uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues

Newsletters

We will use the details you have shared to send you daily newsletters to which you have subscribed. We will repurpose your data or add them to any marketing lists, unless you have consented us to do so. We will provide a way for you to unsubscribe on every newsletter we send to you.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Data Purchases from Third Parties

Headley Media Limited occasionally purchase marketing lists from third party data suppliers. This data may include but not be limited to:

• First Name
• Last Name
• Business Email Address
• Business Postal Address
• Business Job Title / Job Function

If a data purchase is made, you may start receiving email and telephone communications from Headley Media Limited regarding your business sector / business interests without having provided us your details. If at any time you no longer wish to receive these updates / communications you can opt out / unsubscribe at any time or email dataprotection@headleymedia.com. We also keep clear records of all these data suppliers.

Transfer Of Data

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Headley Media Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

If Headley Media Limited is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Legal Requirements

Headley Media Limited may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Headley Media Limited
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability
• Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data.

Data Security

We have very strict data protection practices in place around the data that is operated and managed within the business. Furthermore, IT Security has always been a key area where we have looked to make sure data and systems are secure. We have firewalls, antivirus software, encryption and a no spreadsheet rule already in place on desktop PC's.

Headley Media Limited implement an encryption policy which is essential for reducing the risks to data subjects' rights. We use Pseudonymisation, encryption and minimisation, all of which are recognised techniques in data protection by design.

Retention of Data

Headley Media Limited will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Headley Media Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Your Rights and Preferences Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Headley Media Limited aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Headley Media Limited relied on your consent to process your personal information.
• Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Tracking and Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Website Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy and Terms web page: http://www.google.com/intl/en/policies/privacy/

Behavioral Remarketing

Headley Media Limited uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy and Terms web page: http://www.google.com/intl/en/policies/privacy/

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

AdRoll

AdRoll remarketing service is provided by Semantic Sugar, Inc.

You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false

For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

AppNexus

AppNexus remarketing service is provided by AppNexus Inc.

You can opt-out of AppNexus remarketing by visiting the Privacy and the AppNexus Platform web page: http://www.appnexus.com/platform-policy#choices

For more information on the privacy practices of AppNexus, please visit the AppNexus Platform Privacy Policy web page: http://www.appnexus.com/platform-policy/

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: dataprotection@headleymedia.com

By visiting this page on our website: www.itcorporate.asia/ContactUs

By phone number: +44 (0) 1932 564999

By mail: Headley Media Limited, Warwick House, 1 Claremont Lane, Esher, Surrey, KT10 9DP