PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE WEBSITE OR SUBMITTING ANY PERSONAL DATA TO ENGAGE CLEVELAND

Introduction
Engage Cleveland and its affiliates (or “we,” “us,” “our”) respect your concerns about personal data protection and value our relationship with you. This Website Privacy Policy (the “Policy”) applies solely to personal data collected through Engage Cleveland web sites, web pages, portals, interactive features, applications, e-mail, blogs and their respective contents, event registration sites, in addition to our Twitter, Facebook, LinkedIn or other social networking sites, and their respective contents (collectively, the “Website”), whether accessed via computer, mobile device or other device (collectively, “Device”) .

Engage Cleveland agrees to comply with all applicable privacy laws in connection with its collection, storage and use of personal data. This Policy describes the types of personal data we collect through the Website and how that personal data may be used and/or with whom it may be shared. This Policy also describes how you can reach us to update your contact information, access and control the use of the personal data we collect in connection with our marketing communications and activities, or get answers to questions you may have about our privacy practices at the Website. Please read this Policy carefully, because by using the Website you are acknowledging that you understand and agree to the terms of this Policy. In addition, please review our Terms of Use, which governs your use of the Website and any content you submit to the Website.

Collection and Use of Personal Data
“Personal Data” or “personal data” means any information about an identified or identifiable natural person. The privacy and security of the personal data that Engage Cleveland collects from you is a priority for Engage Cleveland. Generally you can visit the Website without providing personal data, unless otherwise mentioned in the Website itself. However there may be circumstances when you may be asked or choose to provide personal data that could reasonably be used to contact you or to identify you personally such as your name, address, telephone number, credit card data, employer, education level or e-mail address through the Website. By submitting personal data to Engage Cleveland at this Website, you hereby consent to Engage Cleveland’s collection, use and disclosure of such personal data.

Engage Cleveland collects and uses personal data for the following purposes:
• Engage Cleveland may collect and use personal data that you submit at our Website to communicate with you, better understand your needs, and to provide you with better service. For example, when you visit our websites, or send e-mails to Engage Cleveland, you are communicating with us electronically and may be submitting personal data to Engage Cleveland. We may use this personal data to communicate with you either electronically, by e-mail, or using other means.

• By way of example, Engage Cleveland may collect and use personal data that you submit at our Website when you (1) register with Engage Cleveland for an event, (2) register to receive our newsletter, (3) submit a request, (4) enter sweepstakes or contests sponsored by us, (5) sign up for special offers from select third parties, (6) send e-mail messages or feedback, submit forms or transmit other information by e-mail, (7) submit your credit card or other payment information when registering for an event at our Website, or (8) complete a survey. If you elect to engage in such activities, we may ask that you provide us personal data, such as your first and last name, date of birth, age or date of birth, mailing address (including zip code), e-mail address, telephone number, credit card type and number, credit card security code, and other personal data. If you do not provide certain personal data with respect to a particular activity, you will not be able to engage in that activity.

• We may also use your personal data that you submit to provide you with a more efficient and customized experience, process your orders or event registration, improve our marketing and promotional efforts, statistically analyze Website use, improve our event and service offerings, and enhance our Website’s content, layout, and services. We may contact you regarding administrative notices and/or send you occasional e-mails or regular mail regarding our services, special offers and upcoming events that may be of interest to you. If you do not wish to receive this information, please click on the “Unsubscribe” link shown on all our e-mails and electronic newsletters to you or contact us at the address or telephone number listed herein and we will remove your name from our mailing lists.

• To help Engage Cleveland improve your experience on our Website Engage Cleveland may also track your use of our Website. We may collect certain non-personally identifiable information about you based upon how you search and interact with our Website, including which pages you view while visiting our Website. For system administration and statistical analysis purposes, this information is compiled and analyzed on both a personal and an aggregated basis. This information may include a website’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, general geographic location, device type, what browser you are using, Internet service provider, date/time of visit information, operating system, and your Internet Protocol (“IP”) address, which tells us the country and state you are searching our Website from. A URL is the global address of documents and other resources on the World Wide Web.

• We also collect, or enlist a third party service provider to collect, store, process and manage certain non-personally identifiable information to diagnose problems with our servers and software, administer our Website, connect you to the credit card payment platform and gather and analyze demographic and other statistical information. Our third party service providers may also provide us with summary, but not individual, reports that will tell us how our Website is being used. We may also share such aggregate statistical and demographic information with select third parties, such as our partners; however, these reports do not contain any personal data.

• Any information you give us through this Website may be transmitted to servers outside the country where the information is entered, and may be used, stored, and processed outside the country where it was entered. As you browse our Website, our servers may collect information about your visit. For example, to help us better serve you and improve our Website, we may monitor statistics such as how many people visit our Website, which pages people visit on our Website, and which browsers people use to visit our Website.

Engage Cleveland also may use and disclose your personal data: (1) to the extent required to respond to a legal or ethical obligation, (2) to the extent necessary to meet national security, public interest or law enforcement obligations, and (3) to the extent expressly permitted by an applicable law, rule or regulation.

Of course, you may choose not to provide Engage Cleveland with personal data. However, this choice may prevent Engage Cleveland from providing you with the product, service, event, or other information you requested or that could be offered to you.

Engage Cleveland may use your personal data as set forth in this Policy (or any other Engage Cleveland policy, as applicable), and for any other purposes for which your consent is required under applicable law so long as Engage Cleveland obtains your consent.

Additionally, where Engage Cleveland is permitted to do so under applicable law, Engage Cleveland may share your personal data with its affiliates, employees, contractors, volunteers, consultants and other parties who assist Engage Cleveland including, without limitation, parties that provide information technology and data processing services to Engage Cleveland with respect to the operation of its businesses.

Where Engage Cleveland is permitted to do so under applicable law, Engage Cleveland may transfer or provide your personal data to affiliates or third parties both in and outside of the nation where you reside.

Additionally, your personal data may be disclosed as required by applicable law, to comply with a court order, subpoena, warrant or other legal process, or where the personal data is publicly available (unless otherwise restricted by applicable law).

Cookies
Like many websites, Engage Cleveland uses “cookies” and similar tools on the Website to improve its performance and enhance your user experience.

What are Cookies?
A cookie is a small text file which is placed on your Device. Cookies help to analyze web traffic and allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Certain cookies may contain personal data – for example, if you click to “remember me” when logging into a website, a cookie may store your username. Most cookies won’t collect personal data that identifies you, and will instead collect more general information, such as how users arrive at and use our Website, or a user’s general location.

What kinds of Cookies do we use?
The Website only utilizes Session Cookies. These cookies are used ‘in-session’ each time you visit and then expire when you leave a Website or shortly thereafter: they are not stored on your Device permanently, do not contain any personal data and help by minimizing the need to transfer personal data across the internet. These cookies can be deleted or you can refuse to allow their use, but this will hamper the performance and your experience in using the Websites. These cookies also take time stamps that record when you access a Website and when you leave a Website.
Can the Cookies be blocked?
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features and services on our Website may not work properly because we may not be able to recognize and associate you with your Engage Cleveland account(s).

Opting-Out
Even after you have consented to Engage Cleveland’s collection and use of your personal data and submitted personal data to Engage Cleveland at this Website, you may opt-out of having your personal data collected or used by Engage Cleveland by contacting Engage Cleveland. Please note that in order to fulfill certain obligations, we may need to continue sending you notices or other important information concerning any events or services you request. You may contact Engage Cleveland by sending us a letter at:

Engage Cleveland
8200 Sweet Valley Drive, Suite 100
Cleveland, OH 44125
Attention: Privacy Officer

Or by e-mail to: info@engagecleveland.com
Or by telephone at: (216) 264-5647

General Principles for the Processing of Personal Data
Personal data will be collected, stored, processed and transmitted in accordance with Engage Cleveland’s established policies and applicable federal, state, local and foreign laws, rules and regulations.

The principles of Engage Cleveland with respect to the processing of personal data are as follows: (1) personal data will be processed fairly and lawfully, (2) personal data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal data collected by Engage Cleveland will be adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) personal data collected by Engage Cleveland will be accurate and, where necessary, kept up to date to the best of our ability, and (5) personal data collected by Engage Cleveland will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal data was collected.

If Engage Cleveland engages in the processing of personal data for purposes other than those specified in this Policy, Engage Cleveland will provide notice of these changes, the purposes for which the personal data will be used, and the recipients of personal data.

Transfers of Personal Data
Engage Cleveland may transfer your personal data in connection with a merger, consolidation, or reorganization of the assets of Engage Cleveland or affiliates, or other transaction, or by way of assignment (whether by operation of law or otherwise) in connection with any such or similar transaction or in connection with the administration of a bankruptcy estate. However, your personal data will continue to be protected by any pre-existing privacy policy of Engage Cleveland, unless you agree otherwise. Your personal data may become the property of the successor and, subject to your agreement, will be subject to the successor’s privacy policies.

We do not sell any of your personal data (including your name, mailing address, or e-mail address) to any companies or third parties. We do provide some of our services through contractual arrangements with affiliates, service providers, volunteers, and other third parties that require us to share your personal data with them in order to deliver those services. For example, we must release your credit card information to the card-issuing bank to confirm payment for events and services purchased on this Website. We require our service providers to adopt and post privacy policies consistent with this Policy.

Linking to and Privacy Policies of Third Party Sites
This Policy applies to information collected from this Website by Engage Cleveland. Once you click on a link to another website (the “Linked Site”), you are no longer on this Website. This Policy does not apply to the content or privacy practices of any Linked Site. We encourage you to read the privacy statements of each and every website or Linked Site that collects personal data. You should contact advertisers, other websites or Linked Sites directly if you have any questions about their privacy policies or their use of the information they collect.

Miscellaneous Privacy Issues
Engage Cleveland is committed to protecting the privacy of children. Our policy is that we do not knowingly collect, use or disclose personal data about visitors that we know are under 13 years of age. This Website is not directed in any respect to children under the age of 13.

You should be aware that when personal data is voluntarily disclosed (e.g., your name, e-mail address, etc.) in any public areas on this Website (such as our blog) – that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to public areas on this Website are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any public submissions.

Security
Engage Cleveland will take reasonable steps to protect the personal data in its possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction, and will take useful precautions with regard to the nature of the data and the risks of the processing, to preserve the security of the data and, in particular, prevent its alteration and damage or access by non-authorized third parties. Engage Cleveland has put in place appropriate technical, physical, and organizational procedures and security measures to safeguard and secure the personal data from destruction, loss, alteration, unauthorized access or disclosure, or other forms of unauthorized or unlawful processing commensurate with the risks posed by the particular type of processing, the nature of the personal data and in accordance with applicable law and applicable guidelines, and taking into consideration the cost of implementing such measures.

Accuracy
It is your responsibility to provide Engage Cleveland with accurate personal data. Except as otherwise set forth in this Policy, Engage Cleveland shall only use personal data in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, Engage Cleveland shall take reasonable steps to ensure that personal data is accurate, complete, current and relevant to its intended use.

Access
Upon request by you, Engage Cleveland will grant you reasonable access to your personal data. Except where your rights are limited by applicable law (e.g., where necessary to safeguard national security, defense, or public security, for the prevention and detection of crime, or to safeguard an important economic or financial interest of the nation in which you reside, the employee, or the rights and freedoms of others, for the purpose of scientific research or statistical purposes, provided that the data is not used for making decisions that relate to a particular individual), such access will include: (1) confirmation as to whether or not your personal data is being processed and, if so, information as to the purposes of the processing, the categories of personal data processed, and the recipients (or categories of recipients) of the personal data; (2) communication in intelligible form of the personal data undergoing processing and information as to its source; and (3) details of the logic involved in any automatic processing of the personal data. Engage Cleveland will permit you to correct, amend or delete inaccurate or incomplete personal data, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Subject to the above, you may change any of the personal data you have provided to us on this by writing us at: info@engagecleveland.com. Please include your name, address, and/or e-mail address when you contact us.

You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this Website. In addition, it may be impossible to completely delete your information without some residual information because of backups.

Compliance
Engage Cleveland will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

If you believe that your personal data has been processed or disclosed in violation of this Policy, Engage Cleveland encourages you to raise any concerns using the contact information provided in this Policy. Engage Cleveland will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal data.

Changes to this Policy
This Policy may be amended from time to time, consistent with the requirements of applicable law. A notice will be posted by Engage Cleveland on this Website when this Policy is changed.

Date of last update: August 27, 2015