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Camelot Privacy Policy

INTRODUCTION

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Camelot is a trading name of Merlin Digital Consulting Ltd, a private company limited by shares, registered in England and Wales under company number 10429034  and whose registered address is 2 Adelaide Street, St. Albans, England, AL3 5BH (Camelot, we, us or our).  Registered VAT number for Merlin DC is 254571791.

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This policy explains how Camelot uses the personal data we collect from you when you use our website at https://www.camelotmarketplace.com/ (our Website) to find out more about our services, events, or whitepapers, to request us to make contact with you about an inquiry you have or a request for services or events or to sign up for a newsletter. Please note that our Website may contain links to third party websites/digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of our Website. We recommend that you check the privacy and security policies and procedures of each and every other website/digital platform that you visit.

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This policy applies where we are acting as a data controller with respect to personal data we collect, where we determine the purposes for which we collect and store personal data, and means of the processing of personal data.

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The type of personal data we store about you is under your control, and you can specify your preferences for receiving direct marketing communications, and limit the collection, sharing, and internal publication[1] of your personal data. You can specify your privacy preferences by emailing info@camelotmarketplace.com.

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CONTENTS

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  1. Important information and who we are

  2. What data do we collect?

  3. How do we collect your data?

  4. How will we use your data?

  5. How do we store your data?

  6. Information about the Data Processors we use

  7. Marketing

  8. Third Party Marketing

  9. Opting Out

  10. Your Rights

  11. How do we use Cookies?

  12. Evidencing our Data Protection Process

  13. Changes to our Privacy Policy

  14. Contact us

  15. How to contact the appropriate Authority

1. IMPORTANT INFORMATION AND WHO WE ARE Merlin Digital Consulting Ltd, trading as Camelot, is the data controller and responsible for your personal data. We have appointed a data privacy manager (DPM). If you have any questions about this Privacy Notice or our data protection practices, please contact the DPM. CONTACT DETAILS Name of DPM: David Clamp Email address: david.clamp@camelotmarketplace.com Postal address: 2 Adelaide Street, St. Albans, England, AL3 5BH You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO); see Section 15 below. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

2. WHAT DATA DO WE COLLECT? In this Privacy Policy personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (this is referred to as anonymous data). Camelot collects the following data: 1. Identity Data including first name, maiden name, last name, , marital status, title, date of birth and gender, company name and job title); 2. Contact Data including billing address, delivery address, email address and telephone numbers; 3. Transaction Data including details about payments to and from you, and other details of products, digital content, events and/or services you have purchased from us; 4. Marketing and Communications Data including your preferences in receiving marketing communications from us and any third parties (such as sponsors) and your communication preferences; 5. Profile Data including your username and password, purchases, orders, event bookings made by you, your interests, preferences, feedback and survey responses. We may also store information from cookies placed on our Website, such as your IP address and location: the vast majority of this data is recorded anonymously, and this information cannot be associated with you individually. On some occasions, like when we need to record your preferences, this information may be related to you, for example, through your IP address. This information is stored in a way that ensures it cannot be attributed to you and can’t be linked to additional information we store about you separately and securely on Camelot’s systems. This is called pseudonymous data, as it identifies your user in order to recognise your preferences; however, it does not relate to any personal information beyond the unique reference number it applies to you as you enter our site.

3. HOW DO WE COLLECT YOUR DATA? Generally, you directly provide Camelot with the personal data we collect. We collect and process data when you: 1. Register interest in any of our digital content, downloads and services or marketing materials through our Website, for example, by submitting your contact details to access our whitepapers, and/or by subscribe to our emails; 2. Register for one of our Camelot events, where we will store any information you have provided as well as whether or not you attended the event; 3. Register your information entirely voluntarily with any other method. For example, registering interest in our services at a conference or event, where you may sign a physical form; and/or 4. Use or view our Website via your browser’s cookies. Camelot may also hold additional data that is available in the public domain (for example on Linkedin), if you have voluntary submitted of your own details via one of the methods above. We also collect, use and share aggregated data such as statistical or demographic data for any purpose relevant to our Website and services. Aggregated Data could be derived from your personal data but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as “personal data” which will be used in accordance with this Privacy Policy. Where we need to collect personal data to follow up an enquiry from our Website, by law, or under the terms of a contract we have with you, and you fail to provide that personal data when requested, we may not be able to follow up on your enquiry or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service or event booking you have with us, but we will notify you if this is the case at the time.

4. HOW WILL WE USE YOUR DATA? Under the Data Protection Legislation (that is the Data Protection Act 2018, the General Data Protection Regulations (Regulation (EU) 2016/679), and all applicable laws and regulations relating to processing of personal data and privacy, in each case as amended or substituted from time to time), we must always have a lawful basis for using personal data. Most commonly, we will use your personal data in the following circumstances: Where we need to use your personal data for Performance of a Contract we are about to enter into or have entered into with you. Where it is necessary because we or a third party has a Legitimate Interest in doing so and your interests and fundamental rights do not override those interests. Where we need to Comply with a Legal Obligation. Where we have obtained your prior Consent. For these purposes, the following phrases have the following meanings: Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or take steps at your request before entering into such a contract. Legitimate Interest means the interests of our business in conducting and managing our business to enable us to give you the best service/content and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. Consent means that you have given your consent by agreeing that we can use your information or send you information by taking some action to affirm this, such as opting in or ticking a box to confirm you agree. Generally, we do not rely on Consent as a legal basis for processing your personal data except where you sign up to our newsletter or register for events, although we will get your Consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Where events, a series of events or other activities are sponsored by a third party, that third party sponsor may ask us to share your details with them. However, we will only do this if you have given your Consent when you register for the relevant event, series of events or other activities. Camelot collects your data so that we can: Register you as a new member of Camelot. Supply our services or information to you. Manage our relationship with you including notifying you about changes to our membership terms or Privacy Policy and asking you to leave a review or take a survey. Administer and protect Camelot , services and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Manage payment for our services including managing payments, fees, charges and for collecting and recovering money owed to us. Use data analytics to improve our Website, services, marketing, membership relationship and experiences. Supplying you with information by email and post that you have opted-in to (you may opt-out at any time by contacting us at info@camelotmarketplace.com) Inform you of any security breaches that may have affected your data. When signing up to receive our newsletter, we use this data to: Send you our newsletter, no more than weekly Notify you about upcoming Camelot events We collect this data using the lawful basis: Legitimate Interest and Consent and complying with our legal obligations. When you submit your details in order to download content from our website, we use this data to: Send you further information regarding the services you registered your interest in Process your future requests for discussion or performance of a contract We collect this data using the lawful basis: Performance of Contract, Legitimate Interest and complying with our legal obligations. When registering for any Camelot event, we will use this data to: Process your registration through our online event host site (specified in Section 6), where the event is hosted virtually. Send you communications regarding your registration through our chosen online event host site (specified in Section 6), including your unique join link, as well as outputs from the event through our email marketing platform (specified in Section 6). We reserve the right to send you additional information both before and after the event, relating solely to the specific event you registered for, such as resources discussed during the event. Where you have attended a physical event, we may also record or photograph the event for use in our marketing materials. If you wish not to be photographed or filmed, you can notify us at any time. Where this is taking place, we will inform you how to request not to be filmed or photographed, where it is not practical to obtain signed consent from all attendees. We collect this data using the lawful basis: Performance of Contract, Legitimate Interest and Complying with Legal Obligations. We may also send you invitations to future events we host, within the industry you have previously registered your interest in. We collect this data using the lawful basis: Legitimate Interest.

5. HOW DO WE STORE YOUR DATA? Camelot acts as data controller, securely storing your data through our online email marketing platform (see below for further details of the persons with whom we share your personal data), with whom we have a contractual relationship in order to assist in carrying out our services and marketing, specifying they may never sell or share your information. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know or where you have given your consent to this. Details of the third parties we may share personal data with are set out below. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Camelot will keep your personal data for no longer than necessary to fulfil the purposes we collected it for; this timescale is dependent on the nature of your relationship with us. We may retain your personal data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Details of retention periods for different aspects of your personal data are available in our Data Retention Policy, which you can request by contacting us. If you subscribe to receive newsletters, information about our events or other materials from us, you will continue to receive updates via our email marketing platform until: You unsubscribe, therefore revoking consent to continue to send you marketing communications You are an active subscriber and fail to re-consent within 6 months of being informed of the requirement to re-consent, You fail to re-verify your subscription when prompted after being an inactive subscriber for 6 months, meaning you aren’t opening any of our emails. Once you are removed from our mailing list, we will not send you any marketing communications; however, where you have shown interest in a particular service, we reserve the right to continue to send you related information about our services under the lawful basis of Legitimate Interest. You may revoke this authorisation at any time by contacting info@camelotmarketplace.com, or otherwise invoking one of your rights, stated in Section 6 of this Privacy Policy.

6. INFORMATION ABOUT DATA PROCESSORS WE USE We share personal data with the following third parties, who may act as data processors as set out below: Hubspot Data is transferred outside of the European Economic Area to the United States in order to utilise Hubspot’s services. Following the CJEU invalidation of the Privacy Shield on 16th July 2020, Hubspot assured its customers that their Data Processing Agreement already covers SSCs. Data transferred from the EU has, therefore, been continually protected under validated security and data privacy laws. This replaces the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Stripe, Inc. Data is transferred outside of the European Economic Area to the United States in order to utilise Stripes’s services. Following the CJEU invalidation of the Privacy Shield on 16th July 2020, Strip, Inc. assured its customers that their Data Processing Agreement already covers SSCs, therefore data transferred from the EU has been continually protected under validated security and data privacy laws. Stripe also applies technical and organisational measures to strengthen their security measures, of which details are accessible through the Stripe Privacy Centre. This replaces the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Google Analytics Data is not transferred outside of the European Economic Area. We reserve the right to interact with additional third-parties, who may have access to, or process, personal data in order to provide services for us. We will limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them will require maintained confidentiality of such information. Where any such situation occurs we will update this Privacy Policy and we will inform you of any significant changes. There are certain situations in which we may share access to your personal data without your explicit consent; for example, if we are required to do so by the law, to protect the life of an individual, or to comply with any valid legal process, government request, rule or regulation. If any such situation occurs, this privacy policy will be updated and made accessible; however, we will only inform data subjects in case of significant changes to this policy. Zoom Data is transferred outside of the European Economic Area to the United States in order to utilise Zoom’s services. Following the CJEU invalidation of the Privacy Shield on 16th July 2020, Zoom assured its customers that their Data Processing Agreement already covers SSCs, therefore data transferred from the EU has been continually protected under validated security and data privacy laws. Details are accessible here https://zoom.us/gdpr This replaces the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. In some instances, we share your personal data with data processors outside the UK as detailed above. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it as if it were processed within the UK.

7. MARKETING Camelot will send you marketing materials only if you have consented to receive marketing communications from us, or in the case of a recorded previous Legitimate Interest, as specified in Section 4 of this Privacy Policy. You have the right to stop receiving marketing communications or otherwise alter your marketing preferences at any time, using the link at the bottom of all marketing emails, or by contacting info@camelotmarketplace.com.

8. THIRD-PARTY MARKETING We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. In some cases, we are asked to share your data personal data with organisers, speakers, and sponsors of events, series of events or other activities which you have signed up for; however, we will only do this if you have given your Consent when you register for the event events, series of events or other activities. We may share anonymised and aggregate data with them without obtaining specific consent from you provided that you cannot be personally identified from that data.

9. OPTING OUT You can ask us or third parties to stop sending you marketing messages at any time by contacting us at info@camelotmarketplace.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in connection with subscription or booking of an event or other transactions between us.

10. YOUR RIGHTS Camelot would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following: The right to access You have the right to request Camelot for copies of your personal data, commonly known as “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. The right to rectification You have the right to request Camelot corrects any information you believe is inaccurate. You also have the right to request Camelot to complete information that you believe is incomplete, though we may need to verify the accuracy of the new data you provide to us. The right to erasure You have the right to request that Camelot erase your personal data (sometimes known as the right to be forgotten). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. The right to restrict processing You have the right to request that Camelot restrict the processing of your personal data, under certain conditions. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. The right to object to processing You have the right to object to Camelot’s processing of your personal data, where we are relying on a Legitimate Interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. The right to data portability You have the right to request that Camelot transfer what we have collected to another organisation, or directly to you, under certain conditions. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you. The right to withdraw consent You have the right to withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please email us at info@camelotmarketplace.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. If you make a request, we have one month to respond to your request. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. HOW DO WE USE COOKIES? Camelot uses cookies in a range of ways to improve your experience on our website, including: Keeping you signed in, where you have an online account on our site. Understanding how you use our website. To provide aggregated website analytics via Google Analytics to improve the performance of our website. To create an anonymised profile of your browser’s activity on our site, for the purposes of targeting advertisements. Cookies are not strictly necessary for the provision of our website and services, therefore we will ask you to consent when you first visit our site. All information collected through this is entirely anonymous and cannot be connected with any personal details. What types of cookies do we use? There are a number of different types of cookies, however, our website uses: Advertising cookies – Camelot uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed, and information about your browser, device, and IP address. We may share some limited aspects of this data with third parties for advertising purposes, and online data collected through cookies with advertising partners. This means that you may be shown advertising based on your browsing patterns on our website on other websites. Analytical or performance cookies – Camelot uses these cookies to allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Functionality cookies – Camelot uses these cookies to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). How to manage cookies You can set your browser not to accept cookies or go to https://allaboutcookies.org to find out how to remove cookies from your browser. However, in a few cases, this may result in some features of our website not functioning properly.

12. EVIDENCING OUR DATA PROTECTION PROCESS We understand the risks associated with the data we store to be low-risk, meaning there is a low likelihood of breaches regarding personal data. Therefore, we have not completed a Data Privacy Impact Assessment (DPIA) at this time, however, we reserve the right to change this at any time via this policy. Where undertaking new products or potential data processors, we will review this risk and consider the potential necessity for completing a DPIA, which we will make accessible to data subjects. Where we rely on consent as the lawful condition for processing, we should be able to demonstrate and describe how we have reviewed our processes and systems to make sure that consent is freely and unambiguously given for specific purposes, and that we can evidence an affirmative action on the part of the data subject to have indicated their voluntary consent. For these purposes, data subjects must understand who is using their personal data, and what information is being used for what purposes through disclosed communication channels.

13. CHANGES TO OUR PRIVACY POLICY Camelot keeps its privacy policy under regular review and may place updates to this page from time to time. When we do, we will update the date on this policy, notifying you only of significant changes, at which point we may ask you to re-consent. By continuing to use our Website and/or services after any changes become effective, you agree to be bound by our revised policy. This privacy policy was last updated on 16th October 2023.

14. CONTACT US If you have any questions about Camelot’s privacy policy, the data we hold on you, or you would like to exercise your data protection rights, please do not hesitate to contact us. Email: info@camelotmarketplace.com Call us: +44 (0) 7946 185 230 Write to us: Camelot Offices 2 Adelaide Street St Albans Hertfordshire AL3 5BH

15. HOW TO CONTACT THE APPROPRIATE AUTHORITY If you have a complaint regarding any aspect of your personal data or this privacy policy, please write to us at the above address. If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office: Address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF You can also contact the Information Commissioner’s Office using their online form: https://ico.org.uk/global/contact-us/email/

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