Updated: May 24, 2018

This privacy policy applies to the services and websites of Eurasia Group Ltd and those of each of its subsidiaries and controlled affiliates (collectively, the "Company" or "we" or "us"), including www.eurasiagroup.net, www.gzeromedia.com, and internal client portals (collectively, the "Web Site"). The Company understands and appreciates that website visitors (or "they" or "you") are concerned about their privacy and about the confidentiality and security of information we may obtain about them online. We want you to understand the steps we have taken to safeguard the information we receive online about visitors who access or interact with the Company and its services (the "Services").

Please read the following policy (the "Privacy Policy") to understand how your personal information will be treated as you make full use of the Web Site. Your use of the Web Site is subject to your acceptance of this Privacy Policy and the Terms of Use. If you do not agree with this Privacy Policy, please do not use the Web Site.

This Privacy Policy describes the types of information the Company, as a data controller, may collect from you or that you may provide. It also describes our practices for collecting, using, maintaining, protecting, and disclosing that information, including the following:

• Personal data we collect or process, including from the Web Site;
• Cookies policy;
• How we use the data;
• Legal grounds for the processing of your data;
• With whom we may share the personal data;
• Your EU privacy rights and choices;
• California disclosures;
• Retention periods and protection of your data;
• Children's privacy;
• Information about international transfers;
• Links to other sites;
• Privacy Policy updates; and
• How you can contact us.

By using the Web Site, you unambiguously consent to the Company's collection, processing, use, and disclosure of your personally identifiable information in the United States and other jurisdictions within or outside your country of residence, consistent with the terms of this Privacy Policy.

WHAT PERSONAL DATA DO WE COLLECT OR PROCESS?

The Company collects information in several ways from different parts of the Web Site. Some personal information is gathered from clients of the Company and users of the Services when they register to use the Web Site. During client registration, the Company asks for the name, email address, and other information on the preferences of the client. The more information volunteered (and the more accurate it is), the better we are able to customize the client experience.

The Company may at other times ask for a user's personal information, which you may choose to provide at or in your sole discretion. If you contact the Company or the Company contacts you, we may keep a record of that correspondence The Company also occasionally asks users to complete surveys that we use for research purposes that you may choose to complete at or in your sole discretion. Wherever the Company collects personal information, we make an effort to include a link to this Privacy Policy.

The Company may also collect information from you through mailing lists and service emails and links. Please be aware that the Company are not responsible for the privacy practices of other sites to which you may have linked to or through the Web Site.

COOKIES POLICY

The Web Site captures some information from visitors who browse the Web Site, automatically utilizing background local storage and session storage technologies to improve the user experience. This may include, subject to any opt-out preferences, "clickstream" data, such as their Internet Protocol (IP) address, the type of Web browsing software they are using, the web site they visited before linking to the Web Site and the web site they visit after leaving the Web Site.

As part of offering and providing the Services, the Company uses cookies to store and sometimes track information about you. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive. By modifying your browser preferences using most web browsing software, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you will be unable to use those Company Services that require registration to participate, such as where you are prompted to log in to the Web Site, or in sections of the Web Site that are customizable.

Generally, the Company uses cookies to remind the Company who you are and to access your account information (stored on our computers) to deliver to you a better and more personalized service. This cookie is set when you "Log In" and is modified when you "Log Out" of the client portal. In addition (even if you have not registered with the Web Site), we use cookies to help us measure certain traffic patterns, which areas of the Web Site you have visited, and your visiting patterns in the aggregate. We use this research to understand how our users' habits are similar or different from one another so that we can make each new experience on the Web Site a better one. For example, we may use this information to better personalize the content and Services that you and other users will see and use on the Web Site.

HOW YOUR INFORMATION IS USED

The Company's primary goal in collecting personal information is to provide you, the user, with a customized experience on the Web Site. By knowing a little about you, the Company is able to deliver more relevant Services and content and hence a better experience to you.

The Company uses the personal data we collect to respond to your inquiries, provide or enhance our Services, perform our contractual obligations, inform you of new Services or changes in Services, administer the Web Site, to enter into contracts for Services, to fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes.

You may also receive updates from the Company by email regarding your transactions with the Company and promotional material about the Company's Services and features if you have indicated in your preferences that you would like to receive them. You can change your account preferences at any time. (Please see "Your privacy rights and choices" for more information.)

The Company does research on Web Site users' demographics, interests, and behavior based on the information provided to us at registration, from our server log files, or from surveys or third-party analytics tools. We do this to better understand and serve our users. This research is compiled and analyzed on an aggregated basis. The Company may share this aggregated data with advertisers or business partners. (Please see "With whom does the Company share my information?" for more information on how the Company discloses aggregate data.)

We use your IP address to help diagnose problems with our server and to administer the Web Site. We also use your IP Address to identify you when reentering the Web Site, as described above with respect to our use of cookies. Your IP address is also used to gather broad demographic information.

LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA

We rely on the following legal grounds to process your personal information:

Consent. We may use your personal data as described in this Privacy Policy subject to your consent. To withdraw your consent, please contact us at privacy@eurasiagroup.net.
Performance of a contract. We may need to collect and use your personal information to enter into an agreement with you or to perform under an agreement that you have with us. When we process personal data on behalf of third parties, we do so in performance of agreements with such third parties.
Legitimate interests. We may use your personal information for our legitimate interests to provide our Services and to improve our Services and the content on the Web Site. We process information on behalf of third parties who have legitimate interests in operating their businesses. We may use technical information as described in this Privacy Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

WITH WHOM YOUR INFORMATION MAY BE SHARED

The Company is a global provider of Services headquartered in the United States, and as such may need to share information with internal personnel located in different geographic locations in order to fulfill our contractual and legal obligations. We may also share, as controller or as processor performing at the direction of our clients, your personal data with third parties (within or outside your country of residence) who perform services on our behalf, including without limitation our technology providers, payment processors, administrative and support personnel, and providers and professional advisers.

The Company may disclose within or outside your country of residence aggregated user statistics to describe our Services to current and prospective partners, advertisers, and other third parties, and for other lawful purposes. Some of our third-party advertising partners may, with your consent, distribute cookies to you in advertisements that are provided to the Company. The Company has no access or control over these cookies. If you do not wish to allow your information to be shared, you can choose not to register with the Web Site.

The Company may also disclose within or outside your country of residence account information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating the Company's Terms of Use or may be causing injury to or interference with (either intentionally or unintentionally) the Company's rights or property, other users of the Web Site, or anyone else who could be harmed by such activities. The Company may disclose information within or outside your country of residence or access this information when we believe in good faith that the law requires it, or for administrative and other purposes that we deem necessary to maintain, service, and improve our products and Services. The Company may disclose and transfer the Company's database of user and account information to third parties in connection with a merger, acquisition, or sale of all or substantially all of its assets.

We use analytics tools and other third-party technologies, such as Google Analytics, to collect non-personal information in the form of various usage and user metrics when you use our site. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and demographics, and other similar information. You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout.

The Company may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Web Site, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

YOUR EU PRIVACY RIGHTS AND CHOICES

If you reside or otherwise find yourself in the territory of the EU, we are committed to facilitate the exercise of your rights granted by the EU Data Protection Directive. Otherwise you can contact us at any time to discuss your privacy concerns.

Privacy rights under the EU data protection law include:

• Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us at any time.
• Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification, or deletion of such personal information, requests we will do our best to honor subject to any legal and contractual obligations. To make a request or ask us a question about our data practices, please contact us by email at privacy@eurasiagroup.net.
• Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
• Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial emails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal and contractual obligations. Some non-marketing communications are not subject to a general opt out, such as communications about transactions and disclosures to comply with legal requirements.
• Right to data portability. You have the right to data portability of your own personal data by contacting us.
• Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively affect you.
• Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes on your privacy rights according the EU privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.

With most web browsing software, by modifying your browser preferences you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you will be unable to use those Services from the Company that require registration in order to participate.

You may edit your Web Site preferences by contacting us by email at privacy@eurasiagroup.net. Some information that you provide to the Company, such as survey responses and clickstream data, may not be accessible in your Web Site.

A client's Web Site profile can be deleted or deactivated but doing so will result in not being able to access any Services of the Web Site that are for registered or client users only. Please contact us by email at privacy@eurasiagroup.net for further instructions about deleting or deactivating your Company account. Residual information will remain within our archive records and may be used by the Company in accordance with this Privacy Policy.

CALIFORNIA DISCLOSURES

California Information-Sharing Disclosure: California residents may request a list of all third parties to which we have disclosed any information about you for direct marketing purposes, as well as the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to privacy@eurasiagroup.net with "California Privacy Rights" in the subject line.
California Do Not Track Disclosure: Depending on the browser you are using, you may be able to choose to block third party cookies or browse in a private browsing mode. Our Website is accessible even when private browsing is turned on. The information we collect is governed by this Privacy Policy.

RETENTION PERIODS AND PROTECTION OF YOUR PERSONAL DATA

We retain the personal data we collect for as long as reasonably necessary to fulfill the purposes for which the data was collected; to perform our contractual, legal, and ethical obligations; and for any applicable statute of limitations periods.

We take reasonable administrative, physical, and technical precautions to protect your personal data and communications with us. This includes, when required or as we deem appropriate and feasible under the circumstances, obtaining written commitments from third parties that may have access to your data that they will protect the data with safeguards that are substantially equivalent to those used by the Company.

A client's Web Site preferences are password-protected. You are responsible for maintaining the confidentiality of your account and are fully responsible for all activities that occur under your account. You agree to (a) immediately notify the Company of any unauthorized use of your account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. The Company cannot and will not be liable for any loss or damage arising from your failure to comply with these provisions. Remember to sign out of your Web Site account and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, though we strive to protect your personal information, the Company cannot ensure or warrant the security of any information you transmit to us or from our online products or Services, and you do so at your own risk.

Once we receive your transmission, we endeavor to maintain its security on our systems. By using the Web Site and the Internet in general, you may be subject to various risks, including among others eavesdropping, sniffing, spoofing, forgery, spamming, "imposturing," tampering, breaking passwords, harassment, fraud, electronic trespassing, hacking. You may be subject to system contamination including without limitation, viruses, worms, and Trojan horses, causing unauthorized, damaging, or harmful access and/or retrieval of information and data on your computer and other forms of activity that may be considered unlawful. Information (including registration information, passwords and content) received or delivered or intended to be made available on and through the Web Site may be subject to these and other security or privacy hazards; or it may not reach its destination or reach an erroneous address or recipient. The Web Site is not different than other applications in this respect. Without limitation of the foregoing, although we take seriously the security of all client accounts and other personal and non-personal information associated with our visitors and participants, because of the open communication nature of the Internet, we cannot guarantee that your account will be free from unauthorized access by third parties.

CHILDREN'S PRIVACY

The Web Site is a general audience site and does not offer Services directed at children. Should an individual whom we know to be a child under age 18 send personal information to us, we will delete or destroy such information as soon as reasonably possible.

INFORMATION ABOUT INTERNATIONAL TRANSFERS

Eurasia Group, Ltd is a corporation organized and headquartered in New York, New York. If you are visiting the Web Site from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By visiting the Web Site or using the Company's Services, you understand that your information will be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

LINKS AND AFFILIATES

The Web Site may include links to third party sites. The inclusion of any link does not imply that we endorse the products and services offered at such linked site. We cannot control or be responsible for the actions of such other web site operators and the existence of an affiliation with, or a link from, the Web Site does not mean the affiliated or linked website has a privacy policy similar to this Privacy Policy. You should read the privacy policy of any website linked to or from the Web Site.

PRIVACY POLICY UPDATES

We may update this Privacy Policy from time to time at our sole discretion to reflect changes in our information practices. If we modify or update this Privacy Policy, we will post changes and updates on the Web Site so that you will always be aware of what information we collect, use, and disclose. Your continued use of the Web Site after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy. Please review this Privacy Policy periodically and especially before you provide personal data to us. The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.

HOW TO CONTACT US

To make a request, ask us a question about our data practices, or if you believe that we have not adhered to the terms of this Privacy Policy, please notify us by email at privacy@eurasiagroup.net, and we will do our best to address your concerns and promptly confirm and correct any problems. Please use the words Privacy Policy in the subject line of the email.

In addition, you may contact us at:
149 Fifth Avenue, 15th Floor
New York, NY 10010