PRIVACY POLICY

Effective Date: April 1, 2020

GREENWAY GLOBAL MARKETS LLC (collectively, "GREENWAY "us" or "we") understand that your privacy is important to you. We are committed to respecting your privacy and protecting your personal information, which means any information that you as an individual. This Privacy Policy describes how we use your personal information in connection with GREENWAY's business activities, such as conferences and events and customer services, and on websites, applications and communications that post a link to this Privacy Policy (collectively, "the Sites") , deal with and protect in our capacity as data controllers.

Information

We Collect GREENWAY collects personal data in the course of its business activities, including in connection with some customer services. We also collect personally identifiable information in certain areas of the websites. The Personal Data collected will vary and may include information you provide such as name, postal address, email address, phone number, fax number and background information necessary to apply for a job.

We may also automatically collect information about the devices you use to interact with our websites. The information we collect automatically may include IP address, device identifier, web browser and browsing information set by cookies, web beacons, pixels, clear gifs and other similar technologies (collectively, "Cookies and Other Tracking Technologies") on our sites are collected. We may also automatically collect information about how you use the websites, e.g. B. what you have searched for and viewed on the websites. The information collected automatically may be linked to a unique identifier and any other personally identifiable information you provide.

GREENWAY may also collect personal information about you from third parties, such as data brokers or aggregators, in the course of its business, including in connection with some customer services. This includes demographic, professional, and other information that is publicly available online, including information you choose to make public through social media platforms and other online public forums. We may combine this data with existing information we have about you, or use it independently for the purposes of our benchmarking and data analysis activities (e.g., analyzing recruitment practices in an industry, detecting fraud patterns associated with financial transactions, foot traffic in retail environments ). We will always try to confirm

Use of Information

In some situations, the collection of personal information may be necessary for the operation of the websites, or we may use it in the course of our business operations, including in connection with some customer services, e.g. B. to provide certain services or products such as our benchmarking products. We may combine and/or analyze personal information to evaluate and provide content and services that are most relevant to you. We may store and use your personal information to contact you. We may combine and/or analyze personal information to evaluate and provide content and services that are most relevant to you. We may store and use your personal information to contact you. We may combine and/or analyze personal information to evaluate and provide content and services that are most relevant to you. We may store and use your personal information to contact you.

GREENWAY and its service providers may use first- and third-party cookies and other tracking technologies, including web beacons, to administer our websites and our Services and to gather analytics about how you use them. McKinsey and its service providers may collect information about whether you open or click on links in the knowledge, research, or event communications that we send to you. The information about cookies provided in this Privacy Policy also applies to these other tracking technologies. For more information on how we use cookies and other tracking technologies, see our Cookie Policy.

Our websites do not track you by collecting personally identifiable information about your online activities over time and across third party websites or online services. Accordingly, we do not change our data collection and use practices in response to "do not track" signals transmitted by web browsers.

Use of Information Collected via Mobile Devices

In connection with our mobile applications, GREENWAY may use third parties to analyze user activity to troubleshoot, monitor usage and improve the performance of the mobile applications. For example, GREENWAY receives reports on some of the aggregate usage and browsing patterns of our mobile applications, including information about the type of device used, articles viewed and other events that occur on our apps. GREENWAY also receives reports about certain errors that occur in mobile applications.

In addition, our GREENWAY Insights app provides a personalized list of recommendations (called "Insights for you"), leading you to GREENWAY content that we think will be of interest to you. Recommendations are based solely on what you've viewed in the Insights app. A unique user identifier generated by the app helps personalize your app experience and track the articles you read in the app. We do not share your viewing history or trends via the Insights app with other users or external third parties (ie persons or organizations that are not GREENWAY affiliates or third party providers).

The legal basis on which we process your personal data

Our processing of your personal data for the above purposes is based on:

in part because of our legitimate interests in promoting and protecting GREENWAY, building and maintaining relationships. recruiting and providing our services;
partly based on your consent, e.g. B. when you create a user profile or register for our newsletters or alerts, or for business purposes that support the operation of the web, such as B. understanding and improving the quality of your experience on our websites;
in part to comply with the law when certain information is necessary to comply with our legal or regulatory obligations.

Sharing of personal data: data recipients and international data transfers

Personal information collected in the course of GREENWAY's business, including in connection with some customer services, as well as on the websites, may from time to time be shared with GREENWAY subsidiaries and affiliates and their employees in our global organization and with our third party service providers on the transferred around the world, including in countries where local law may give you fewer rights than you do in your own country. In addition, GREENWAY and our third party websites may be viewed and hosted anywhere in the world. To the extent required by law, we have put in place legal mechanisms to ensure an adequate level of privacy protection for your personal data held by GREENWAY affiliates, affiliated companies and third party service providers, including the transfer of your personal data to countries other than that in which you reside. If you would like more information on these legal mechanisms, which may include the EU's Standard Contractual Clauses, please contact us at the address below. By using any of the websites and providing information through any of them, you voluntarily consent to such cross-border transfer and hosting of that information. which may include the EU Standard Contractual Clauses, please contact us at the address below. By using any of the websites and providing information through any of them, you voluntarily consent to such cross-border transfer and hosting of that information. which may include the EU Standard Contractual Clauses, please contact us at the address below. By using any of the websites and providing information through any of them, you voluntarily consent to such cross-border transfer and hosting of that information.

GREENWAY will not intentionally share or transfer your personal information to any third party (and will take reasonable steps to prevent unauthorized or accidental disclosure), whether for those third parties' own marketing purposes or otherwise, without your consent or as otherwise permitted by law, except as follows . GREENWAY may provide third party service providers engaged by GREENWAY to provide services related to the websites and related to GREENWAY's business activities, including in connection with some customer services, access to your personal data in the manner agreed in our customer service agreements. We maintain processes designed to ensure

We may also share your personal information with third party service providers who perform services and functionality on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys or contests, or communicating with you.

In addition, we may disclose information about you:

If we are required to do so by law or a court of law;
To law enforcement 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;
When disclosure is necessary to protect an individual's vital interests;
To protect our property, our services and our legal rights;
To prevent fraud against GREENWAY, our subsidiaries, affiliates and/or business partners;
To support audit, compliance and corporate governance functions; or
To comply with all applicable laws.

In addition, we may disclose or transfer your Personal Information in the event of a reorganization, merger, sale, joint venture, assignment, or other transfer or sale of all or a portion of our business.

user forums

You should be aware that whenever you post information online, that information may be collected and used by others. GREENWAY is not responsible for the actions or policies of third parties who collect information that users make public in such forums on the Sites.

Link to Third Party Sites

GREENWAY may provide links to third party websites or information as a convenience to our users. If you use these links, you will leave the websites. Such links do not constitute or imply GREENWAY's endorsement, sponsorship or recommendation of the third party, the third party's website or the information contained therein, and GREENWAY shall not be responsible or liable for your use. Such use is subject to the terms of use and privacy policies applicable to those websites.

Social networks

The Sites may allow you to log into your social media accounts and associate them with GREENWAY, including but not limited to Twitter, LinkedIn, Facebook and YouTube. The Sites may also allow you to log into a GREENWAY account using certain social network account credentials.

By linking your social media account to GREENWAY, or signing in to a GREENWAY using your social media account credentials, you give us permission to access information you have stored in your public profile for that social media account network have made available. The information available on your public profile varies by social network and your preferences, but may include your email address, real name, profile picture, gender and location. We use the information we receive from your social network account in accordance with the social network's terms of service and this privacy policy.

If you wish to disconnect a social media account from us, refer to the settings of that social media account and its provider.

Security

GREENWAY has implemented generally accepted technology and operational security standards to protect personal data from loss, misuse, alteration or destruction. Only authorized GREENWAY employees and third-party service providers are granted access to personal data, and such employees and service providers are required to keep this information confidential. However, despite these precautionary measures, GREENWAY cannot guarantee that unauthorized persons will not gain access to your personal data.

Data retention

GREENWAY stores personal data, if necessary, for the duration of the respective business relationship.

We may also keep personal information longer than the length of the business relationship if we need to keep it to protect against legal claims, use it for analytics or historical records, or comply with our information management policies and timetables. If you request that we erase your personal information, GREENWAY will use reasonable efforts to erase all instances of the information in its entirety. Requests for access, rectification or erasure can be found in the "Your Rights" section of this Privacy Policy.

children

The Sites are not designed for or directed at children 16 years of age or younger, and GREENWAY does not intentionally collect or store personally identifiable information about anyone under that age.

Your rights

Where permitted by applicable law, you may have the right to request access to the personal information we have collected about you, to review, amend or delete the information. You may also have the right to request a copy of the personal information we have collected about you and to have any inaccuracies in that information corrected. In certain circumstances, you can also request that we stop processing your personal data.

If you would like to make a request to access, review or correct the personal information we have collected about you, or to discuss how we are processing your personal information, please contact us atdatasubjectrights@greenway-global-markets.com. To protect your privacy and security, we will take reasonable steps to verify your identity, e.g. B. request a password and user ID before we grant access to your personal data. We will use reasonable efforts to promptly investigate, fulfill, or otherwise respond to your requests as required by applicable law. Different laws may prevent us from providing access to your personal information or otherwise fully complying with your request, depending on the circumstances and the request, e.g. B. where the submission of your information may reveal the identity of another person. We reserve the right to charge a reasonable fee for fulfilling your request,

In addition, where permitted by local law, you have the right to lodge a complaint with a competent data protection authority.

Your New Jersey Privacy Rights

If you are a New Jersey resident under the age of 18 and a registered user of any of the websites on which this Privacy Policy is posted, you may, under the New Jersey Business and Professions Code, request the removal of content or information that you have posted publicly and obtain. To make such a request, please send an email to with a detailed description of the specific content or informationprivacy@greenway-global-markets.comPlease note that such a request does not ensure complete or comprehensive removal of any content or information you have posted, and there may be circumstances where the law does not require or permit removal, even if requested.

In accordance with the New Jersey Consumer Privacy Act (NJCPA), this Privacy Policy describes the categories of personal information that GREENWAY collects, processes and discloses, the categories of sources for that information, and the business or commercial purposes for which such information is collected, processed and be disclosed.

In addition, under New Jersey law, you may have the right (up to twice in any 12-month period) to request additional information about GREENWAY's collection, uses, disclosures and sales of Personal Information about you, including:

The categories of personal information about you that we have collected in the last 12 months and the categories of sources of that information,
The categories of sources from which we collected this information in the previous 12 months,
The commercial or business reasons why we collected, used, disclosed, or sold that information, and
The categories of third parties with whom we have shared or sold this information in the previous 12 months.
In addition, upon receipt of a verifiable request from you to verify your identity, you may have the right to be informed of specific personal data that we have collected about you and/or shared with third parties in the previous 12 months.

You may also have the right to request the deletion of personal information about you that we have collected or stored, which we will respect subject to certain limitations of New Jersey law.

If you are a New Jersey consumer and you or your authorized representative wish to exercise your data protection rights, please contact us at datasubjectrights@greenway-global-markets.com. When we process your request, we require that you provide certain personally identifiable information about you to verify your identity in accordance with the requirements of the NJCPA. This may include your first and last name, email address, physical address, phone number and information about your relationship with us or other information needed to verify your identity. GREENWAY will not discriminate against you based on your exercise of any of these rights.

Consent; Changes to the Privacy Policy

By using the Sites, you consent to our collection, use and storage of your personal information in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this privacy policy from time to time. We will notify you of any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to the use of personal information we previously collected about you, we will obtain your consent either by email to your registered email address or by posting information about the changes on our websites.

If you have any questions about our privacy policy or would like to communicate with our EU Data Protection Officer or Data Protection Team, please contact us at:

GREENWAY GLOBAL MARKETS LLC

Legal Department

301 Route 17 North, suite 800 #12-40

Rutherford, NJ 07070, USA

+1 201-804-0988

office@greenway-global-markets.com