The 2112 Strategy Group, LLC, and the EU-US Privacy Shield Policy

Introduction

The 2112 Strategy Group, LLC (the “Company”) is a business strategy firm focused on improving the performance of technology companies’ direct and indirect channels through its portfolio of market-leading products and services comprised of qualitative research, market analysis, tools, and enablement programs. Protecting consumer privacy is important to the Company. The Company adheres to the EU Privacy Shield concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the EU-US Privacy Shield Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by the Company whether in electronic, paper or verbal format.

Definitions

“Personal Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. “Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

Principles

Notice

The only type of Personal Information collected will focus on general market trend, technology, business, and/or channel-related best practices, such as annual business performance metrics, sales revenue, product reviews, marketing intelligence and vendor/solution provider relationships. The purpose of collecting this data is strictly used in support of channel research studies, and will be detailed in each survey once open to participation. The 2112 Strategy Group, LLC does not collect or transmit Sensitive Personal Information on individuals. Company shall inform an individual of the purpose for which it collects and uses the Personal Information to which the Company discloses or may disclose that Information for the intention of performing a research study. Company shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Personal Information for a purpose other than for which it was originally collected. To opt-out of data collection, notify us by email.

Choice

The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. To remove yourself from the database, individuals can simply send an email to operations@the2112group.com with the subject line: “Opt Out” from the email address they used upon registration. For Sensitive Personal Information, the Company will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Company shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Onward Transfers

Prior to disclosing Personal Information to a third party, such as a business partner or vendor, for the purpose of joint-research programs, Company shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection. Please be aware that the Company may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.  The Company is liable for appropriate onward transfers of personal data to third parties.

Data Security

Company shall only process Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Company shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Data Integrity

Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Company shall take reasonable steps to ensure that Personal Information is accurate, com­plete, current and reliable for its intended use.

Access

Individuals have the right to access their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the rights of persons other than the individual would be violated. To do so, please send an email to operations@the2112group.com with the subject line: “Access to Information” and someone will contact you regarding fulfillment of your request.

Enforcement

Company uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Information in accordance with the Principles.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the EU-US Privacy Shield. We will post any revised policy on this website.

Information Subject to Other Policies

The Company is committed to following the Principles for all Personal Information within the scope of this Privacy Agreement. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy.

The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.

The 2112 Strategy Group complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. The 2112 Strategy Group has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.

Contact Information

In compliance with the EU-US Privacy Shield Principles, The 2112 Strategy Group commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact The 2112 Strategy Group at:

Attn: Operations and Compliance
51 Shadyside Avenue Port Washington, NY 11050
Email: operations@the2112group.com

The 2112 Strategy Group has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU Privacy Shield, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Finally, and as a last resort in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

Effective date: 08/17/2016