Updated: January 4, 2024
This privacy policy (the "Privacy Policy") of Eurasia Group Ltd and those of each of its subsidiaries and controlled affiliates (collectively, the “Company” or “we” or “us”), applies to the websites including www.eurasiagroup.net, www.gzeromedia.com, www.gzerosummit.com (collectively, the “Web Site”) and internal client portals and any content, and any other mobile or other applications on which a link to this Privacy Policy appears (collectively with the Web Site, the “Services”). The Company understands and appreciates that you, a website visitor or consumer of the Services, are concerned about your privacy and about the confidentiality and security of personally identifiable information from or about an individual (“Personal Information”) that we may obtain about you online or through your interactions with us. We want you to understand the steps we have taken to safeguard the information we receive from visitors who access or interact with us and the Services.
Please read the Privacy Policy to understand how your Personal Information will be treated as you make full use of the Services. Your use of the Services is subject to your acceptance of this Privacy Policy and the Terms of Use. If you do not agree with this Privacy Policy, please do not use the Web Site or Services.
Scope of this Privacy Policy
This Privacy Policy describes the types of Personal Information the Company, as a data controller, may collect from you or about you or that you may provide. It also describes our practices for collecting, using, maintaining, protecting, and disclosing that information, including the following:
- Personal data we collect or process, including from the Web Site;
- Cookie policy;
- How we use data;
- Legal grounds for the processing of your data;
- With whom we may share the personal data;
- Your worldwide privacy rights, choices and disclosures;
- Retention periods and protection of your personal data;
- Children's privacy;
- Information about international transfers;
- Links to other sites;
- Privacy Policy updates;
- How you can contact us and
- Thought Leadership Privacy Policy Rider
Residents of certain other US states may have additional rights. Please see our US State Privacy Notice for each of these states following the main Privacy Policy.
Residents of Brazil may also have additional rights. Please see our LGPD Privacy Notice following the main Privacy Policy.
Consent
By using the Services, you unambiguously consent to the Company's collection, processing, use, and disclosure of your Personal Information in the United States and other jurisdictions within or outside your country of residence, consistent with the terms of this Privacy Policy and applicable law.
What personal data do we collect or process?
The Company collects information in several ways from different parts of the Services:
Information you provide:
Some personal information is gathered from corporate clients of the Company (“Clients”) when they sign up for our Services and make the Services available to employees and other individuals within their organizations.
During Client registration, the Company asks for the name, email address, business title and other optional information on the preferences of the Client. The more information volunteered (and the more accurate it is), the better we are able to customize the Client experience and the experience of the Client's employees who are provided with access to the Services.
Some personal information is gathered directly from you, as an individual user of the Services, when you register directly to use the Web Site and Services. This information may include your name, email address and business title and other information relevant to the Services which you are requesting.
The Company may at other times ask for a user's personal information for reasons specified at the time, which you may choose to provide at or in your sole discretion. It is always your choice whether or not to provide information but if you do not, you may not be able to access any, some or all of the Services.
If you contact the Company or the Company contacts you, we may keep a record of that correspondence. The Company also occasionally asks users of the Services to complete surveys that we use for research purposes that you may choose to complete at or in your sole discretion. Wherever the Company collects personal information, we will make an effort to include a link to this Privacy Policy.
The Company may also collect information from you through third party mailing lists and service emails and links. Please be aware that the Company are not responsible for the privacy practices of other sites to which you may have linked to or through the Web Site.
We operate social media pages on third party networks and have social media icons on our Web Site. When you visit or link to our social media pages, your Personal Information is processed both by us and the applicable social media provider. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms. These third parties may retain any information used or provided in any such communications or activities and these third parties' practices are not subject to our Privacy Policy. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices.
Information collected automatically when you visit our Web Site
In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Web Site (“Usage Information”).
This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Web Site. Usage Information may include:
- Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier.
- Your Device functionality (including browser, browser language, time zone, operating system, hardware, mobile network information).
- Referring and exit web pages and URLs;
- The areas within our Website that you visit and your activities there, including remembering you and your preferences;
- Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
- Your Device characteristics; and
- Certain other Device data, including the time of day you visit our Website.
Cookies Policy
As is true of most websites, Eurasia Group and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking mechanisms (web beacons, device identifiers and similar technologies) to recognize you across websites and provide certain functionality. We use cookies and similar technologies to administer our websites, to improve our content and Services, and protect the security of our Services. Please refer to our Cookie Policy for further information on the types of cookies collected from visitors to the Services.
Generally, we use cookies to remind us who you are and to access your account information (stored on our computers) to deliver to you a better and more personalized service. This cookie is set when you "Log In" and is modified when you "Log Out" of the Client portal. In addition (even if you have not registered with the Web Site), we use cookies to help us measure certain traffic patterns, which areas of the Web Site you have visited, and your visiting patterns in the aggregate. We use this research to understand how our users' habits are similar or different from one another so that we can make each new experience on the Web Site a better one. For example, we may use this information to better personalize the content and Services that you and other users will see and use on the Web Site.
How your information is used
The Company's primary goal in collecting personal information is to provide you, the user, with a customized experience on the Web Site and Services. By knowing a little about you, the Company is able to deliver more relevant Services and content and hence a better experience to you.
The Company uses the personal data we collect to (i) respond to your inquiries, (ii) provide or enhance our Services,(iii) perform our contractual obligations, (iv) inform you of new Services or changes in Services, (v) administer the Web Site, (vi) to enter into contracts with others to help us fulfill the Services, such as payment processors, (vii) to fulfill legal obligations we have to governmental authorities or other third parties, and (viii) for other legitimate business purposes.
You may also receive updates from the Company by email regarding your transactions with the Company and promotional material about the Company's Services and features if you have indicated in your preferences that you would like to receive them. You can change your account preferences at any time. However, if you choose not to receive marketing and promotional materials, you may still receive emails of a transactional nature. (Please see “Your privacy rights, choices and disclosures" and “Thought Leadership Rider” for more information.)
You may be invited from time to time to participate in events sponsored by third parties with whom the Company has relationships, to receive sponsored content, or to participate in third party-sponsored promotions, in which case your registration information may be provided to those third parties.
The Company does research on Web Site users' demographics, interests, and behavior based on the information provided to us at registration, from our server log files, or from surveys or third-party analytics tools. We do this to better understand and serve our users. This research is compiled and analyzed on an aggregated basis. The Company may share this aggregated data with advertisers or business partners. (Please see “With whom does the Company share my information?" for more information on how the Company discloses aggregate data.)
We use your IP address to help diagnose problems with our server and to administer the Web Site. We also use your IP Address to identify you when reentering the Web Site, as described above with respect to our use of cookies. Your IP address is also used to gather broad demographic information.
Legal grounds for processing your personal data
We rely on the following legal grounds to process your personal information:
Consent. We may use your Personal Information as described in this Privacy Policy subject to your consent. To withdraw your consent, please contact us at [email protected].
Performance of a contract. We may need to collect and use your Personal Information to enter into an agreement with you or to perform under an agreement that you have with us. When we process personal data on behalf of third parties, we do so in performance of agreements with such third parties.
Legitimate interests. We may use your personal information for our legitimate interests to provide our Services and to improve our Services and the content on the Web Site. We may use technical information as described in this Privacy Policy and use Personal Information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.
Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.
With whom your information may be shared
The Company is a global provider of Services headquartered in the United States, and as such may need to share information with internal personnel located in different geographic locations in order to fulfill our contractual and legal obligations. We may also share, as controller or as processor performing at the direction of our clients, your Personal Information with third parties (within or outside your country of residence) who perform services on our behalf, including without limitation our technology providers, payment processors, administrative and support personnel, and providers and professional advisers.
The Company may disclose within or outside your country of residence aggregated user statistics to describe our Services to current and prospective partners, advertisers, and other third parties, and for other lawful purposes. As set forth in our privacy policy, some of our third-party advertising partners may, with your consent, distribute cookies to you in advertisements that are provided to the Company. The Company has no access or control over these cookies.
We reserve the right to release current or past Personal Information: (i) in the event that we believe that the Services are being or have been used to commit unlawful acts; or (ii) if the information is subpoenaed or requested pursuant to any court order or lawful request by public authorities, including to meet national security or law enforcement requirements; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena.
We may also disclose within or outside your country of residence account information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating the Company's Terms of Use or may be causing injury to or interference with (either intentionally or unintentionally) the Company's rights or property, other users of the Web Site, or anyone else who could be harmed by such activities. The Company may disclose information within or outside your country of residence or access this information when we believe in good faith that the law requires it, or for administrative and other purposes that we deem necessary to maintain, service, and improve our products and Services.
The Company may disclose and transfer the Company's database of user and account information to third parties in connection with a merger, acquisition, or sale of all or substantially all of its assets.
We use analytics tools and other third-party technologies, such as Google Analytics, to collect information in the form of various usage and user metrics when you use our site. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and demographics, and other similar information. You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout. Please note the Google Analytics is disabled for EU residents.
The Company may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgments on the Web Site, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.
Your privacy rights, choices and disclosures
General. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at [email protected] or make changes to any user profile information connected to your account.You may also opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
You may edit your Web Site preferences by contacting us by email at [email protected]. We may not be able to honor all preferences with respect to some information you provide to the Company, such as survey responses and clickstream data.
Your Web Site profile can be deleted or deactivated but doing so will result in not being able to access any Services of the Web Site that are for registered or client users only. Please contact us by email at [email protected] for further instructions about deleting or deactivating your account. Residual information will remain within our archive records and may be used by the Company in accordance with this Privacy Policy.
Retention Periods
We retain the Personal Information we collect for as long as reasonably necessary to fulfill the purposes for which the data was collected; to perform our contractual, legal, and ethical obligations; and for any applicable statute of limitations periods.
As for cookies, “session” cookies last until you close your browser, and “persistent” cookies last until you or your browser delete them
Protection of your Personal Information
We take reasonable administrative, physical, and technical precautions to protect your personal data and communications with us. This includes, when required or as we deem appropriate and feasible under the circumstances, obtaining written commitments from third parties that may have access to your data that they will protect the data with safeguards that are substantially equivalent to those used by the Company.
A client's Web Site preferences are password-protected. You are responsible for maintaining the confidentiality of your account and are fully responsible for all activities that occur under your account. You agree to (a) immediately notify the Company of any unauthorized use of your account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. The Company cannot and will not be liable for any loss or damage arising from your failure to comply with these provisions. Remember to sign out of your Web Site account and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, though we strive to protect your Personal Information, the Company cannot ensure or warrant the security of any information you transmit to us or from our Web Site or Services, and you do so at your own risk.
Once we receive your transmission, we endeavor to maintain its security on our systems. By using the Web Site and the Internet in general, you may be subject to various risks, including among others eavesdropping, sniffing, spoofing, forgery, spamming, "imposturing," tampering, breaking passwords, harassment, fraud, electronic trespassing, hacking. You may be subject to system contamination including without limitation, viruses, worms, and Trojan horses, causing unauthorized, damaging, or harmful access and/or retrieval of information and data on your computer and other forms of activity that may be considered unlawful. Information (including registration information, passwords and content) received or delivered or intended to be made available on and through the Web Site may be subject to these and other security or privacy hazards; or it may not reach its destination or reach an erroneous address or recipient. The Web Site is not different than other applications in this respect. Without limitation of the foregoing, although we take seriously the security of all client accounts and other personal and non-personal information associated with our visitors and participants, because of the open communication nature of the Internet, we cannot guarantee that your account will be free from unauthorized access by third parties.
Children's privacy
Our Services are NOT directed at persons under 18 and we do not knowingly collect Personal Information from children under 18. If you become aware that your child has provided us with Personal Information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us. We encourage you to monitor the online activities of your children.
Information about international transfers
Eurasia Group, Ltd is a corporation organized and headquartered in New York, New York. If you are visiting the Web Site from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By visiting the Web Site or using the Company's Services, you understand that your information will be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.
Links and affiliates
The Web Site may include links to third party sites. The inclusion of any link does not imply that we endorse the products and services offered at such linked site. We cannot control or be responsible for the actions of such other web site operators and the existence of an affiliation with, or a link from, the Web Site does not mean the affiliated or linked website has a privacy policy similar to this Privacy Policy. You should read the privacy policy of any website linked to or from the Web Site.
Do Not Track Disclosures
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above, and in our Cookies Notice. Some web browsers offer users a “Do Not Track” privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals. Learn more about Do Not Track.
Global Privacy Control
We recognize and honor Global Privacy Control (“GPC”) for U.S.- based users; if GPC is enabled, we recognize this as an “opt out of the sale or sharing of personal information” or as an “opt out of targeted advertising and the sale of personal data” request (non-California U.S. residents). For further details, see the US State Privacy Notice below.
Privacy Policy updates
We may update this Privacy Policy from time to time at our sole discretion to reflect changes in our information practices. If we modify or update this Privacy Policy, we will post changes and updates on the Web Site so that you will always be aware of what information we collect, use, and disclose. Your continued use of the Web Site after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically and especially before you provide personal data to us. The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.
How to contact us
To make a request, ask us a question about our data practices, or if you believe that we have not adhered to the terms of this Privacy Policy, please notify us by email at [email protected], and we will do our best to address your concerns and promptly confirm and correct any problems. Please use the words Privacy Policy in the subject line of the email.
In addition, you may contact us at:
149 Fifth Avenue, 15th Floor
New York, NY 10010
Attention: Cassandra Spratt
Thought Leadership Privacy Policy Rider ("Rider") applies solely to any Thought Leadership Download Page.
Except as specifically provided in this Rider, the Eurasia Group Privacy Policy (the "General Policy") shall apply.
The third paragraph in the General Policy section titled "How your information is used" is nonapplicable for Thought Leadership downloads; there is no account set-up and no option to indicate preferences regarding receipt of promotional materials. The provision of Personal Information in order to receive the download remains at your sole discretion, but the download is available only to those that provide the information indicated as mandatory.
With respect to the section "Legal grounds for processing your personal data," Eurasia Group's legal basis for processing your personal data for Thought Leadership Downloads is the pursuit of marketing opportunities consistent with its legitimate business interests.
To the extent of any conflict with this Rider and the Privacy Policy, this Rider shall control.
The third paragraph in the General Policy section titled "How your information is used" is nonapplicable for Thought Leadership downloads; there is no account set-up and no option to indicate preferences regarding receipt of promotional materials. The provision of Personal Information in order to receive the download remains at your sole discretion, but the download is available only to those that provide the information indicated as mandatory.
With respect to the section "Legal grounds for processing your personal data," Eurasia Group's legal basis for processing your personal data for Thought Leadership Downloads is the pursuit of marketing opportunities consistent with its legitimate business interests.
To the extent of any conflict with this Rider and the Privacy Policy, this Rider shall control.
Your European Rights and Choices.
If you reside or otherwise find yourself in the territory of the EU, EEA, UK or Switzerland, we are committed to facilitate the exercise of your rights granted by the EU General Data Protection Regulation and the UK Data Protection Act 2018 or the revised Swiss Federal Act on Data Protection (collectively “GDPR”).
Generally your Privacy rights under GDPR include:
- Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us at any time.
- Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification, or deletion of such personal information, requests we will do our best to honor subject to any legal and contractual obligations. To make a request or ask us a question about our data practices, please contact us by email to [email protected].
- Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
- Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial emails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt out, such as communications about transactions and disclosures to comply with legal requirements.
- Right to data portability. In certain circumstances, you have the right to data portability of your own personal data by contacting us.
- Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively affect you.
- Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes on your privacy rights according to GDPR, although we would hope that you would contact us first to try to resolve any issues, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.