Challenger Privacy Policy

Effective Date: January 20, 2023

 

Last Updated: January 20, 2023

Challenger and its Affiliates are committed to protecting your information. Please read this Privacy Notice (this “Notice”) carefully as it sets out important information relating to how we handle your personal information.

Challenger Companies Issuing This Notice

In this Notice, references to “we”, “us”, “our” or “Challenger” are references to Challenger Performance Optimization, Inc. “Affiliates” are companies or entities that are controlled by or under common control with Challenger.

How to Contact Us

Questions, comments and requests regarding this Notice should be addressed through the following means:

Chief Financial Officer
Challenger Performance Optimization, Inc.
1777 N Kent St STE 500
Arlington VA 22209
USA
Email Address: privacy@challengerInc.com

Introduction

This Notice sets out how we will collect and use personal information, and the choices and rights available to you in connection with our use of your personal information.

This Notice describes our practices when using your information when you:

  1. express an interest in or have signed up for our events or products including newsletters, apps, extensions, webinars and e-books;
  2. activate your Challenger user account and/or license;
  3. attend a Challenger event, such as an in-person training, presentation, assessment, or other educational program; or
  4. visit our websites (including our public website and client facing learning management systems) or social media websites; or 5. provide us your information through our Contact Us page, email, or in any other way.

This Notice also applies to information we collect from you via our survey or diagnostic tools, including but not limited to those used for assessments. You may be shown an additional confidentiality notice before participating in a survey or diagnostic. Please note that in cases where the terms of any such confidentiality notice that is specific to a survey, diagnostic or assessment conflicts with any terms in this Notice, the survey or diagnostic-specific confidentiality terms will take precedence over the terms in this Notice.

This Notice will apply whether you have provided the information directly to us or we have obtained it from a different source, such as a third party.

1. Information that we collect about you

1.1 Data collection and usage

Information we collect directly from you or from the following sources:

Third party referrals including from within the Challenger group;

Social media websites and other public internet websites, such as LinkedIn, Facebook, or Instagram;

Public resources such as telephone directories, newspapers, internet websites, commercially available marketing lists, registries or public records; and

Your employer or affiliate who purchases services from us.

Categories of information we collect about you include:

Personal information such as name and title, contact details, company name, business title and email address;
Communications with you; and
Information you provide when posting content on social media websites.

We use this information for certain activities, including:

Facilitating our business through communication with corporate clients and other business contacts, for example, to communicate about vendor briefings or details of events or webinars;
For internal analysis and research to help us improve our services;
To send marketing to business contacts regarding our services and products which may be of interest and to promote our business and brand;
Administering our website, investigating any complaints and providing customer service; and
Monitoring social media content to manage relations with our clients and promote our business and brand; and
For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”), the EU General Data Protection Regulation (the “GDPR”) or the United Kingdom General Data Protection Regulation (UK-GDPR).

We use this information because:

It is necessary for performing our obligations, or exercising our rights, under our contracts with clients;
It is necessary for compliance with any legal or regulatory obligations that we are subject to;
We have a legitimate business interest to:
Manage and promote our business and brand;
Provide and improve our services;
Operate our business; or
We have your consent (where required under applicable law) to use your information for marketing. Where we rely upon your consent, you have the right to withdraw your consent by contacting us at privacy@ChallengerInc.com.

Information we collect when you attend one of our events, including training, development and assessment programs

Categories of information we collect about you include:

Information you provide us when registering your attendance such as name, business email address, profile photograph, job title, professional interests and requested accommodation;
Information provided to us by your employer or an affiliate who purchases services from us;
Geo-location information at the event if you attend an event where we are using RFID-enabled badges and you do not opt-out of using an RFID-enabled badge;
Information collected when we record one of our events;
Information that you provide to us when you participate in classes, training, learning modules and similar programs, including responses to assessments and quizzes; and
Your responses to any surveys regarding our products or services.

We use this information for certain activities, including:

Enabling you to attend our events;
Delivering educational and skill building content to you;
Facilitating the smooth running of events;
Analyzing attendee interests in and interactions with the event through geo-location data (in certain cases);
Marketing our events;
Providing recordings of certain event sessions to interested business contacts, attendees and online through our website or Challenger social media websites; and
Assessing your suitability for a sales-related job, and providing this assessment to an employer or potential employer; or
For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”), the EU General Data Protection Regulation (the “GDPR”) or the United Kingdom General Data Protection Regulation (UK-GDPR).

We use this information because:

It is necessary for performing our obligations, or exercising our rights, under our contracts with clients;
We have your consent (where required under applicable law) to use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us at privacy@ChallengerInc.com;
It is necessary for compliance with any legal or regulatory obligations that we are subject to; or
We have a legitimate business interest to:
Manage and promote our business and brand;
Operate our events business;
Provide and improve our services; or
Collect relevant information for hospitality and health and safety purposes.

Information we collect from users of:

Our website (public and client-facing learning management systems, including but not limited to assessments of individuals’ sales potential and our learning management system);
Our apps; and
Challenger webpages on social media websites such as LinkedIn, Facebook or Instagram.

Categories of information we collect about you include:

Information you provide to us either on our website or in person, such as when you provide contact details, answer online questionnaires or feedback forms;
Information that you provide in response to surveys regarding our programs, products and services; · Information that you provide to us when you participate in classes, training, learning modules and similar programs, including responses to assessments and quizzes; · Information you provide when you subscribe to email newsletters such as name, email address, job title; · Information your organization provides to set-up your user account on Challenger learning management systems (Challenger Hub) including name, business email address and organization; · Optional information you provide when completing your profile in your account within a Challenger learning management system including location, country, time zone and language preference; · Where you have an account on a Challenger learning management system (Challenger Hub or Effortless Experience Learning Portal) account — log-in and similar credentials and information about use and preferences for these services; and · Information that a Challenger client (such as an employer or potential employer) chooses to collect. This can include categories such as name, address, phone number, and email address.

We use this information for certain activities, including:

Enabling you to access your online Challenger accounts across devices;
Delivering educational content to you;
Assessing your suitability for a sales-related job and providing this assessment to an employer or potential employer;
Understanding whether you have learned the material presented at our training and similar programs;
Personalizing the experience of our website, learning management systems and apps;
Administering our website, learning management systems and app;
Enabling peer networking opportunities based on your background and experience;
Providing better, more customized client service;
Investigating any complaints; and
Monitoring social media content to manage relations with our clients and promote our business and brand; or
For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”), the EU General Data Protection Regulation (the “GDPR”) or the United Kingdom General Data Protection Regulation (UK-GDPR).

We use this information because:

It is necessary for performing our obligations, or exercising our rights, under our contracts with clients;
It is necessary for compliance with any legal or regulatory obligations that we are subject to;
We have a legitimate business interest to:
Promote our brand and business through our website and through social media tools;
Monitor, investigate and report any attempts to breach the security of our website;
Provide and improve our services including, but not limited to, the Challenger learning management systems and our apps;
Provide our clients and their employees and potential employees with effective training; and
Operate our business; or
We have your consent (where required under applicable law) to use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us at privacy@ChallengerInc.com.

Information we collect about the use of our website and apps from users
Categories of information we collect about you include:

Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID) and browser information (e.g. URL, browser type, pages visited, date/time of access), geo-location and other device-specific information and Internet connection information;
Advertising information (such as size/type of ad, ad impressions, location/format of ad, data about interactions with ad);
Behavioral information (such as information on the behavior or presumed interests of individuals which are linked to those individuals and may be used to create a user profile); and
Information captured by our cookies.

We use this information for certain activities, including:

Personalizing the experience of our website;
Administering our website;
Performing statistical and trend analysis to improve the user experience and performance of our website;
Providing better, more customized client service; and
Investigating any complaints.

We use this information because:

It is necessary for compliance with any legal or regulatory obligations that we are subject to; and
We have a legitimate business interest to:
Monitor, investigate and report any attempts to breach the security of our websites;
Improve the performance and user experience of our websites; and
Customize the client experience.

1.2 Special categories of information

Certain types of personal information are more sensitive than others. This includes information about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometric information or religion. It is voluntary for you to disclose this information, but where we collect and receive these types of information about you, we have identified the type of special information, how we will use it and why we will use it.

Information we collect when you attend one of our events
Categories of information we collect about you include

Dietary requirements that may imply specific religious beliefs or medical conditions; and
Any physical or mental disability or impairment you may disclose to us.

We use this information for certain activities, including:

Providing hospitality that is suitable for attendees of our events.

We use this information because:

You have consented by providing us with the information. Where we rely on your consent, you have the right to withdraw consent by contacting us at privacy@ChallengerInc.com.

1.3 Further information

Where legitimate interests are mentioned above, a legitimate interest will only apply where we consider that your interests or rights which require protection of your personal information do not override our legitimate interests. If you require further information regarding our legitimate interests as applied to your personal information, you may contact us as noted above.

In certain circumstances, if you do not provide personal information which is required (for example, in relation to activating your account on a Challenger learning management system (Challenger Hub or Effortless Experience Learning Portal), we will not be able to perform our obligations under the contract with your employer or may not be able to provide you with products and services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be.

1.4 Personal Data of Children

Our websites and online services are for individuals who are at least 18 years of age. Our online services are not designed to be used by individuals under the age of 18. We do not knowingly collect or solicit Personal Data from individuals under 18. If you are under 18 years old, please do not attempt to register for or otherwise use the Service or send us any Personal Data. If we learn we have collected Personal Data from an individual under 18, we will delete that information as quickly as possible. If you believe that an individual under 18 may have provided us Personal Data, please contact us at privacy@challengerinc.com.

1.5 Communication with Colleagues

You may use the send-to-colleague functionality on some of our websites or apps to send your colleagues information from Challenger or its Affiliates. In order to fulfill this request, we will ask you for your and your colleagues’ names and email addresses. We do not retain this data after the email is sent. Please be aware that your name and email address may be included in the communications sent to your colleagues.

1.6 Restricted Areas

If you access the Restricted Areas of any of our websites (via browser or a Challenger app), we may collect information about your access to and use of the online and offline resources we offer.

2. When we disclose your information

We may disclose your personal information to third parties as follows

· To Affiliates and service providers in order to process the data for the above mentioned purposes;

· To Challenger strategic partners with whom Challenger offers or promotes products or services or whom promote Challenger products or services on our behalf;

· When we have your consent or authorization to do so, e.g., when you have allowed an event sponsor to scan your attendee badge;

· To third parties who work on our behalf to service or maintain business contact databases and other IT systems, such as suppliers of the IT systems which we use to process personal information or who provide other technical services, such as printing;

· To third parties providing services to us who have a need to access your information, such as our professional advisors (e.g. auditors and lawyers) or venues for our events;

· To comply with applicable laws, protect rights, safety and property and respond to lawful requests from public authorities (such as disclosing data in appropriate situations for national security or law enforcement purposes); and

· Subject to applicable law, in the event that Challenger is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such a transaction, or for pre-transaction review in relation to such transactions.

Your personal information may be shared if we anonymize and/or aggregate it, as in these circumstances the information will cease to be personal information.

Utilization Information

We may share information with our organizational clients about how their employees use the websites and the resources available to them through the websites (e.g. how employees used certain features of the websites, utilization trends, which features were most popular with the client’s employees).

3. International transfers

Challenger is a global company and, as such, we may transfer personal information to other Challenger group companies or suppliers outside your home jurisdiction. Challenger will take all reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.

Challenger may transfer and maintain the personal information of individuals covered by this Notice on servers or databases outside the European Economic Area (EEA). Some of these countries may not have the equivalent level of protection under their data protection laws as in the EEA.

The countries to which we transfer data outside of the EEA may include any of the countries in which Challenger does business. A list of Challenger office locations can be obtained by

contacting us. All Challenger entities have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, and the terms of our client and member contracts governing the collection and use of information.

Please see the GDPR Privacy Notice below for more information.

4. Retention periods

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information. We may also retain personal information for the period during which a claim may be made in relation to our dealings with you.

In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:

· the period required by tax and applicable laws and regulations; and

· as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims.

This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.

5. Choices about your information

We believe it is important to give you choices about the use of your information. We will use your information as described in this Notice (or any other event- or service-specific Privacy Policy). If we want to use your information for a purpose not described in this Notice, we will first get your consent to do so.

Marketing Communications

We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us at privacy@challengerinc.com. If you consented to receiving marketing communications by giving us your email address for that purpose, you can opt out at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we will continue to send you service-related communications regardless of any opt-out request.

We will not sell or share your information or information with third parties (other than our subsidiaries or Affiliates) for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.

Events

You may choose to share your contact details with our event sponsors. Our sponsors’ use of any information you choose to share with them in this way is governed by each sponsor’s Privacy Policy.

6. Security

We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot and do not guarantee or warrant the security of any information you transmit via our websites or apps. Please note that you are responsible for maintaining the security of your credentials used to access any Challenger service or account, and you must report suspected unauthorized activity to us.

We make efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve or deliver our programs, products and services.

7. Cookies and Similar Technologies

A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as “cookies”. For more information about how Challenger uses cookies, please see our Cookie Policy.

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Service. Disabling these Cookies may make certain features and services unavailable.

Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Service, maintain your preferences over time and recognize you when you return to our Service. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Service such as by collecting information about the number of visitors to the Service, what pages visitors view on our Service and how long visitors are viewing pages on the Service.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and this may cause some services and functionalities to not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

8. Links

To provide increased value to you, we provide links to other websites or resources that are not part of the products, programs or services run by Challenger. We do not control these websites or their privacy practices and any information you provide to these websites is subject to the Privacy Policies of those websites and not this Notice.

9. Changes to this Privacy Policy

Challenger may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our Service or business.  We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will do our best to alert you to changes by placing a notice on the Challenger website, by

sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Service, and you are still responsible for reading and understanding them.

If you use the Service after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

California Resident Rights

If you are a California resident, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@challengerinc.com.

Access

You have the right to request more information about the Personal Data we hold about you and request a copy of such Personal Data by emailing privacy@challengerinc.com.

Deletion

You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Service or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

Emailing us at: privacy@challengerinc.com.

Personal Data Sales Opt-Out and Opt-In

Challenger does not sell your data. If it does, Challenger will provide an opportunity for you to opt-out of such sale.

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. However, you may change your mind and opt back in to Personal Data sales at any time by creating a new profile for yourself.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may have different tiers of services as allowed by applicable data protection laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@challengerinc.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

GDPR Privacy Notice

Last Updated: January 20, 2023

European Union Data Subject Rights

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) or the United Kingdom General Data Protection Regulation (UK-GDPR) with respect to your Personal Data, as outlined below.

For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the European Privacy Laws, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.  Challenger will be the controller of your Personal Data processed in connection with the services described in this policy. For purposes of this GDPR Privacy Notice, “Personal Data” includes (but is not limited to) Profile data, as defined above.

Right to access and/or correct your personal information

You have the right to access personal information we hold about you, as well as to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate.

Right to restrict use of your personal information

You have the right to ask us to restrict processing of your personal information where one of the following applies:

  • The processing is unlawful but you want us to restrict use of the data instead of deleting it;
  • Where you contest the accuracy of your personal information, the restriction will apply until we have verified the accuracy or corrected your personal information;
  • We no longer require the personal information for the purposes of processing, but you still require us to keep it in connection with a legal claim; or
  • You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

Right to request deletion of your personal information

You have the right to ask us to delete your personal information in certain circumstances. Please note that if you want us to refrain from sending you marketing communications, the best way to ensure that is to allow us to retain your information with a “do not contact” tag so we know not to contact you in the future.
There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defense of legal claims.

Right to object to processing of your personal information

You may object to our use of your personal information for marketing purposes.
You may also object to processing of your personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your personal information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise or defense of legal claims.

Right to data portability

In most cases, you have the right to receive all personal information you have provided to us in a structured, commonly used and machine-readable format and to transmit this data to another data controller, where technically feasible.

Right to lodge a complaint with a supervisory authority

If you object to our processing of your personal information, you have the right to complain to the data protection authority (“DPA”) in the country where you reside, where you work or where an alleged infringement of data protection laws has taken place.
We agree that any disputes regarding our privacy policies and related actions regarding personal information from data subjects in the EU and Switzerland can be heard by a DPA and we will be subject to the determinations of those bodies (as further explained in the Privacy Shield Principles). Please contact us to be directed to the relevant DPA.

In certain circumstances after they have first tried to resolve the dispute directly with us and with the DPA, data subjects in the EU and Switzerland may be able to invoke binding arbitration of disputes by the Privacy Shield arbitration panel.

How and With Whom Do We Share Your Data?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us or you with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

· Payment processors

· Fraud prevention service providers

· Analytics service providers

· Staff augmentation and contract personnel

· Hosting service providers

· Marketing service providers

· Product development service providers

· Customer success providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested.  In addition to those set forth above, these parties also include:

· Third party business partners who you access through the Service

We also share Personal Data when we believe it is necessary to:

· Comply with applicable law or respond to valid legal process, including requests from law enforcement or other government agencies

· Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud

· Maintain the security of our products and services

We also share information with third parties when you give us consent to do so.

Last, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data? We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Service. In some cases we retain Personal Data for longer if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@challengerinc.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

· Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data by emailing privacy@challengerinc.com.

· Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by emailing privacy@challengerinc.com.

· Erasure: You can request that we erase some or all of your Personal Data from our systems.

· Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.

· Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

· Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

· Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

· Right to File Complaint: You have the right to lodge a complaint about Challenger’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data: The Service is hosted and operated in the United States (“U.S.”) through Challenger and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Challenger in the U.S. and will be hosted on U.S. servers, and you authorize Challenger to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S.

Contact Information:

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to contact your Challenger representative or email us at privacy@challengerinc.com.

Physical Address:

1777 N Kent Street,
Suite 500,
Attention: Legal Department
Arlington, VA 22209

Terms and Conditions of Use

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Terms and Conditions of Purchase (USA)

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Terms and Conditions of Purchase (Non-USA)

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Sub-Processors

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Data Processing Agreement

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Privacy Policy

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Cookie Policy

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