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The following discloses our information gathering and dissemination practices for this Website.

Competition Policy International, Inc. (“CPI”) and the company or individual (“Customer”) agree that CPI shall make available to Customer the services identified in the Order (“Services”), subject to this Subscription Agreement (“Agreement”). Services may include, but are not limited to, online access to current and past issues of the CPI Journal and the Antitrust Chronicle (formerly “GCP Magazine”) and full access to the Resource Library (“Content”).

1. Licenses

1.1. CPI grants to Customer a non-exclusive, non-transferable license (“License”) subject to the limitations contained in this Agreement and in the Customer’s Order. CPI retains all ownership rights (including copyrights and other intellectual property rights) of the Services, in any form, and Customer obtains only such rights as are explicitly granted in this Agreement and such Order.

1.2. Each license is for a term of 12 months, beginning on the effective date of the Order, unless another term is specified in the Order. The Service is available only for the number of users or benefiting audience members identified and described in the Order (“Authorized Users”) and may not be shared with other persons or entities. An Authorized User is authorized by Customer to access the Services during the term of this Agreement and according to the terms of the Order, either online via www.competitionpolicyinternational.com, or after the Content has been downloaded in accordance with the terms of this Agreement. CPI reserves the right to deny access to any and all users in excess of the number of Authorized Users specified in the Order.

2. Restrictions on Use

2.1. The Services are licensed for Customer’s internal use only and subject to any restrictions set forth in the Order. Customer will not provide Content, or other Services to others, whether directly in any media or indirectly through incorporation in a database, marketing list, report or otherwise, to third parties.

2.2. Customer will not copy, reprint or distribute Content except for in ways in accordance with this Agreement and as set forth in the Order.

2.3. Republication of Content by someone other than the author requires written permission from CPI. Customer is authorized to excerpt or cite Content as source material provided reference is given to CPI.

2.4. CPI reserves the right to monitor Customer’s use of the Service to ensure compliance with this Agreement and prevent fraudulent use. Such monitoring of use may include but will not be limited to determining whether or not the Service is accessed under the account from multiple computers, as well as noting downloads beyond the limit of a single-user or a disproportionate number of users. All download limitations will be enforced at CPI’s discretion. Customer may not make a user name and password available to a party that is not an Authorized User. If monitoring indicates Customer is not in compliance with this Agreement or if fraudulent activity is suspected, CPI reserves the right to take such action as it deems necessary, including, but not limited to, suspension or termination of the account.

3. Copyrights and Other Proprietary Rights

3.1. Content is proprietary, copyrighted works of CPI and its authors and comprises: (i) works of original authorship, including compiled Content containing CPI’s selection, arrangement and coordination, and expression of such Content or pre-existing material as it has created, gathered or assembled; and (ii) Content that has been created, developed and maintained by CPI or its authors at great expense, such that misappropriation or unauthorized use by others for commercial gain would unfairly and/or irreparably harm CPI and its authors or reduce CPI or its authors’ incentive to create, develop and maintain such content. Customer will not commit or permit any act or omission that would contest or impair CPI’s or any author’s proprietary and intellectual property rights to Content or that would cause the Content to infringe the proprietary or intellectual property rights of a third party. Customer will reproduce CPI’s or its authors’ copyright and proprietary rights legend on all copies of Content.

3.2. Customer will not use any trademark, service mark or trade name of CPI or any of CPI’s affiliated companies or publish any press releases regarding this Agreement or any order. Customer shall not disclose the negotiated pricing or terms of this Agreement, or any order, to any third party.

3.3. CPI represents and warrants to Customer that, to CPI’s knowledge, the Content, when used in accordance with this Agreement, does not violate any existing, U.S. copyrights, patents, trademarks, or other intellectual property rights of any third party, as of the effective date of the applicable Order.

3.4. Registration data and other information about Customer are subject to CPI’s Privacy Policy.

4. Disclaimers

4.1. All Services and Content are provided on an “as is”, “as available” basis. CPI disclaims all warranties, express or implied, including any warranties of accuracy, completeness, or correctness for a particular purpose. CPI does not guarantee that the services will be uninterrupted or error-free and disclaims any warranty or representation regarding availability of a service, service levels or performance. CPI will not be liable for any loss or injury arising out of, in whole, or in part, CPI’s conduct in procuring, preparing, and delivering Services or Content.

5. Payment

5.1. Customer will pay CPI in accordance with the Order and accompanying Invoice. Prices and product descriptions are those set forth in the Order. Subscriptions will be cancelled if payment is not received within 30 days of the order.

6. Termination and Cancellations

6.1. In the event of material breach of any of the above, the non-breaching party may immediately terminate, or CPI may suspend Services under, the applicable Orders without prior notice. In the event of material breach of any other part of this Agreement by Customer or CPI, the non-breaching party may terminate this Agreement or particular Orders if such breach is not remedied within 30 days of written notice of breach.

6.2. CPI subscriptions are non-cancelable/non-refundable after 48 hours of activation or with the execution of any download function. Cancellations must be in writing, sent to subscription@competitionpolicyinternational.com.

Privacy

This is the website of Competition Policy International (CPI).

Our postal address is: 140 South Dearborn, Suite 1000, Chicago, IL 60603

We can be reached by telephone at: +1.312.533.4602

1. CPI’s Privacy Statement

1.1 The purpose of this Privacy Policy is to inform you of the procedures regarding the collection, use, and disclosure of information on the CPI website, including any mobile versions or related mobile applications, collectively called CPI Sites, accessible on www.competitionpolicyinternational.com. CPI encourages you to carefully read this Privacy Policy.

1.2 The CPI website (hereinafter, the “Site”) is provided by CPI. By visiting the CPI Sites and providing information to CPI, you acknowledge that you have been informed and you consent to the Privacy Policy, including with regard to CPI’s use and disclosure of personal information which may be collected when you contact CPI, subscribe to CPI email alerts and newsletters, when you register for events or training, or when you request any other products and services provided by CPI in accordance with the purposes detailed in section 4. If you do not wish your personal information to be used by CPI in the manner set out in this Privacy Policy, please do not provide us this information.

2. Nature of information Collected

2.1 In order to receive CPI newsletters or information about CPI products and services, to contact CPI for any questions or comments, to request CPI products and services, or to register for CPI events and trainings, you may choose to provide some personal information. The categories of personal information that CPI may collect for the processing purposes described hereto are: family name, first name, organization, job title, activity, main area of interest, country of residence, and email address.

3. Purposes of Data Processing

3.1 CPI may use the personal information that you provide:

1. 1. To process and respond to your questions and/or inquiries;
   2. To send newsletters, emails, or other communications relating to products and services that may be of interest;
   3. To recommend other CPI services and products;
   4. To manage your membership to CPI;
   5. CPI, or third parties on its behalf, may also use information provided in an aggregate and anonymous form for internal business and planning purposes, including to analyze trends and statistics.

4. Data Retention

4.1 Your data will be used solely for the purpose of sending relevant communications. CPI will retain your personal data only for as long as it is necessary to complete the operations for which data has been collected or until you request to no longer receive communications from us, in accordance with applicable laws and regulations.

5. Security

5.1 Protecting your privacy and your personal information is a priority for CPI. CPI has taken reasonable measures to protect your personal information from loss, misuse and alteration. However, please be aware that no data transmission over the Internet or storage technology can be guaranteed to be 100% secure. CPI can only take steps to help reduce the risks of unauthorized access to information/data. Each individual using the Internet user can also take steps to help protect his/her personal information and is encouraged to do so to further minimize the likelihood that a security incident may occur

6. Your Rights

> Right to request access, rectification, erasure, restriction processing, object to the processing, portability

6.1 The collected information is necessary for your registration and, more generally, for the purposes described in the section 4. It is subject to data processing at CPI. In application of the European Regulation on the protection of natural persons with regard to the processing of personal data and of the free movement of such data (General Data Protection Regulation “GDPR”) you will benefit from the right to access, rectification, erasure, restriction processing, object to the processing, portability.

6.2 In which circumstances can you exercise your rights with CPI?

• Right of access

1. The data subject shall have the right to obtain from the controller, confirmation as to whether or not their personal data is being processed, and, where that is the case, access to the personal data and the following information:
   1. The purposes of the processing;
   2. The categories of personal data concerned;
   3. The recipients or categories of recipient to whom the personal data has been or will be disclosed;
   4. Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
   5. The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
   6. The right to lodge a complaint with a supervisory authority;
   7. where the personal data is not collected from the data subject, any available information as to their source;
   8. The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
   9. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
   10. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

• Right to rectification

1. The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

• Right to erasure (‘right to be forgotten’)

1. The data subject shall have the right to obtain from the controller the erasure of personal data without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
   1. The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
   2. The data subject withdraws consent;
   3. The data subject objects to the processing on grounds relating to his or her particular situation including profiling and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for direct marketing;
   4. The personal data has been unlawfully processed;
   5. The personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of the personal data.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
   1. For exercising the right of freedom of expression and information;
   2. For compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
   3. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing;
   4. for the establishment, exercise or defense of legal claims.

• Right to restriction of processing

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
   1. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
   2. The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of its use instead;
   3. The controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defense of legal claims;
   4. The data subject has objected to processing on grounds relating to his or her particular situation including profiling pending the verification of whether the legitimate grounds of the controller override those of the data subject.
   5. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
   6. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

• Notification obligation regarding rectification or erasure of personal data or restriction of processing

1. The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

• Right to data portability

1. The data subject shall have the right to receive personal data which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from the controller to which the personal data has been provided, where:
   1. The processing is based on consent; and
   2. The processing is carried out by automated means.
   3. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
   4. The exercise of the right referred to in paragraph 1 shall be without prejudice to the right of erasure. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
   5. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

• Right to object

1. The data subject shall have the right to object, on grounds relating to his/her particular situation, at any time to processing which is based on legitimate interests pursued by the controller or by third party, except where such interests are overridden by the interests or fundamental rights and freedom of the data subject. The controller shall no longer process the personal data, unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data is processed for scientific or historical research purposes or statistical purposes, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

• Right to object to automated individual decision-making, including profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or similarly significantly affects him/her.
2. Paragraph 1 shall not apply if the decision:

(a) Is necessary for entering into, or performance of, a contract between the data subject and a data controller;

(b) Is authorized by Union or Member State law to which the controller is subject, and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or

(c) Is based on the data subject’s explicit consent.

(d) in the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his/her point of view and to contest the decision.

• Right to unsubscribe

1. If you no longer wish to receive communications from CPI, you may opt out by sending a direct request to CPI at contact@competitionpolicyinternational.com.

7. Cookies Policy

> General

7.1 Subject to your prior explicit consent where such consent is required by the applicable law in your jurisdiction, CPI Sites use “cookies” (i.e., small text files which are downloaded to a user’s device when visiting the CPI Sites) in order to improve navigation around the CPI Sites for the user and improve the quality of the CPI Sites.

7.2 By using www.competitionpolicyinternational.com, you consent to the use of cookies. If you do not consent to such use, you may disable these cookies through your browser.

> Which cookies are we using?

7.3 CPI uses cookies to save your logged in status and track that you have visited the site. This is useful for you and means that you do not have to login to access your preferences each time you visit the CPI website. This is also useful for us as it helps us gauge how many users have visited our site.

7.4 The Site also uses Google Analytics, a web analytics service provided by Google. Google Analytics cookies, which are text files on your computers, help the website analyze how users use the site. The information generated by cookies about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity on the number of users and type of use pertaining to the CPI Site. More information on Google Analytics is available under: https://support.google.com/analytics/answer/6004245

> Managing Cookies

7.5 Parameters of web browsers by default are generally set up in such a manner to accept cookies but you can easily change those parameters by modifying your preferences. If you choose to deactivate cookies, some functionalities, pages or parts of the CPI Site may not be accessible. CPI is not responsible in such cases.

8. Links to Other Sites

8.1 The www.competitionpolicyinternational.com site may contain links to or from a number of third party websites (hereinafter, the “Third Party Sites”). CPI does not, in any way, control or operate the Third Party Sites. CPI is not responsible for the privacy practices, content, policies or actions of the Third Party Sites. This Privacy Policy is only applicable to general information processed by the CPI Sites, pursuant to information collected on CPI Sites. The use of any information you may provide to third parties on the Third Party Sites, or which such parties may otherwise collect on other websites, is not governed by this Privacy Policy.

9. Social Networks

9.1 Social media plug-ins of social networks such as Facebook, Twitter and LinkedIn or services with user-generated content features are integrated into the CPI Sites. Where the CPI Sites contain a plug-in to a social network site, these are clearly marked (e.g., with a Twitter button). If you choose to click on one of these buttons or links, your browser connects directly to the servers of the relevant social network. The other website’s privacy policy applies to any personal information you provide to that website. If you do not want the social network to collect the information about you, please review the privacy policy of the relevant social network and/or log out of the relevant social network before you visit the CPI Site.

10. Intellectual Property (IP) / Content

10.1 All content displayed on the CPI Sites, including but not limited to, text, graphics, logos, buttons, icons, images, sounds, audio clips, digital downloads, data compilations and software, is the property of CPI or its content suppliers and is protected by the United States and/or foreign applicable laws.

10.2 Registered trademarks of CPI are marks indicated on the CPI Sites and include licensors, in the United States and other countries. All other trademarks that appear on the CPI Sites are the property of their respective owners.

10. 3 You are prohibited from using, without permission, any of the marks, trademarks, trade names, service names, logos or other proprietary graphic appearing throughout the CPI Sites.

11. Updates to Privacy Policy

11.1 To the extent permitted by applicable law in your jurisdiction, CPI may, from time to time, revise or update this Privacy Policy. You agree to be bound by such modifications or updates. If we make material revisions to the way we collect or use your personal information such that we are using it for purposes that you have not consented to, we will notify you of the changes and, as the case may be, ask for your explicit consent.

11.2 Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the Internet, accessible through the CPI Sites. By continuing to use the CPI Sites following such changes, you will be deemed to have agreed to such changes.

12. Contacting Us 

12.1 If there are any questions regarding this Privacy policy you may contact us at:

contact@competitionpolicyinternational.com

Last updated 25/05/2018