Privacy Policy

There are laws about how businesses can collect and use information from their customers, event participants, or anyone visiting their websites. These laws set different requirements, but they all relate to the same idea, which is that you have the right to know what information you’re sharing with us, what we’re doing with it, and why. When the information that we collect identifies you or your household — or if it could identify you or your household – it’s called “personal data.” We want to, and have to, protect your personal data. Our Privacy Policy explains how we try to do so, but it’s a long document with a lot to discuss. So, you can:

Go to the section that has the topic you’re interested in in the table of contents;
Use a keyword search for your topic; or
Get in touch with us to ask a question, ask us to show you the data we have about you, or ask us to delete your personal data.

+1. General Statements
1.1 This is the Privacy Policy for Hilco Trading, LLC and its affiliated companies, but we’ll refer to ourselves as “Hilco Global,” or “the Company,” or use “we/us/our” pronouns.

+2. Information About Hilco Global and this Privacy Policy

2.1 This Privacy Policy outlines how Hilco Global collects and processes your personal data through your use of Hilco Global’s websites, apps, or any other services sponsored or controlled by Hilco Global (a conference or an in-person survey, for instance). In other words, if we’re collecting personal data in any form, this Privacy Policy applies.

2.2 We’ll provide links to this Privacy Policy wherever we can. You should read this Privacy Policy, think about it, ask questions, and decide if you’re comfortable with it. Also read our Terms and Conditions, which control how we provide our services, and any other notices or policies we post, so that you can make an informed decision about interacting with us.

2.3 When we make a change to this Privacy Policy, we’ll post a notice for you to review.

2.4 We are not responsible, though, for links to third party sites that we present to you, either on this website or elsewhere online. Once you access sites or apps via those links, our Privacy Policy no longer applies, and so you’ll need to read their privacy policies as well.

+3. What Data Are We Collecting About You?

3.1 For purposes of this Privacy Policy, personal data is: Any information that can, either alone or with other information, be used to identify an actual human person or their household. 3.2 These are the categories of personal data that
we collect:

“Basic Data” means your name and your email address. Basic Data is collected only if you elect to provide it to Hilco Global in the course of using the Hilco Global goods or services or our websites.
“Transaction Data” is all Basic Data plus any other information related to the movement of financial data through our systems or services. This means banking data (like account balances or transactions), credit information
(like credit limits or credit ratings).
“Technical Data” means any information we collect as we operate our websites and applications, like your IP address when you connect to our websites, your mobile device identifier, what browser you used to access our site and
what operating system you’re using, the movement of your mouse on the screen (mouse hovers and clicks, for example) the length of time you spend on our website, any extensions or apps you use along with ours.
“Profile Data” means the more detailed Hilco Global information that you’ve set up and shared with us. Your profile data includes any information necessary for you to access your account or other information we hold about you
(including email address, any password or login details etc), and your activity while logged in (including reviews, ratings, submissions, comments, and feedback).
“Feedback and Marketing Data” means information that we collect to create new products or services that customers might find interesting. This includes any surveys or questionnaires we conduct (whether they’re in an email, on
our website, or at a physical location). Feedback and marketing data also means all other forms of Personal Data, your preferences when it comes to how, when, and why we communicate with you about our products and services, and any
interactions you have with our marketing materials (for instance, whether you opened a survey or responded to an in-store questionnaire). Feedback and Marketing Data is collected whenever you provide the types of feedback described
in this section or interact with our marketing materials. We talk a lot more about marketing in the section below called “Marketing our Products.”
“Third Party Data” means any personal data about you that we obtain – whether by purchasing it or simply receiving it – from anywhere outside of Hilco Global. Often times, this data is publicly available information like an
address, business title, or social media profile, but it could be just about anything.

3.3 As explained below, we may combine different kinds of personal data in the performance of our services. We’ll also sometimes combine the personal data you’ve given us with non-personal data. If the combined data can identify you, we’ll treat it like personal information, even though some parts of the combined data (like the weather) can’t identify you. 3.4 We do not collect any “Special Categories” of Personal Data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, or information about criminal convictions or offenses.

+4. Cookies

We use Cookies and other tracking technology to make our websites operate properly and to provide you with a better experience. You can control how non-technical cookies operate on our sites by clicking on the cookie banner that appears when you visit one of our sites.

+5. How We Collect Personal Data

We collect personal data in a variety of ways, depending on how you interact with us, including:

5.1 Direct interactions. You may give us your Basic, Purchase, Technical, Transaction, Profile, or Feedback and Marketing Data, by interacting
with us, as when you:

sign up for or use any of our products or services;
create an account or profile;
link your account to our service or share your data with us through another service;
sign up to receive information, including marketing information, from us;
make a claim based on your account or use of our services or communicate with us about any matter;
contact customer support or request technical assistance;
access Hilco Global via social media accounts or Hilco Global’s website(s);
enter a promotion or survey; or
give us feedback or reviews.

5.2 Through automated technologies or interactions. As you interact with our website, we automatically collect Product Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Product Data about you if you visit other websites employing our cookies.

5.3 From third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. We also store or process personal data through our third-party vendors, including:

professional advisers, partners, and agents of Hilco Global to you with services, as required, and to administer our relationship with you;
vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, loan
servicers, customer relationship management databases and other cloud-based solutions, third party companies providing us with business analytics and statistics to assist with our marketing campaigns, and third party venues in which
we may host events and seminars. We contract with such vendors to ensure that they only process your personal information under our instructions and ensure the security and confidentiality of your personal information by
implementing the appropriate technical and organizational measures for such processing;
any law enforcement, regulatory, or government agency requesting personal information in connection with any inquiry, subpoena, court order, or other legal or regulatory procedures, with which we would need to comply. We may also
share personal information to establish or protect Hilco Global’s legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims; and
any third party connected with business transfers; we may transfer your personal information to third parties in connection with a reorganization, restructuring, merger, acquisition, or transfer of assets of the Company, provided
that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.

+6. Why (and How) We Use Personal Data

6.1 We only use personal data when we have a lawful basis for doing so. Sometimes we rely on your consent to use personal data. When we do, we will give you the option to withdraw your consent at any time.

6.2 The following list sets out how we use personal data, and the lawful basis for doing so:

Completing a transaction. We use any and all categories of Personal Data we have which are necessary to complete a transaction at your request, whether that transaction is for the movement of Financial Data, the creation of
an account, the lodging of a request, or any other service or activity. We need this information in order to be able to fulfill our part of our contract with you and because we have a legitimate interest in being able to carry out
your express requests.
Providing customer service. Depending upon what you contact us for and request, we will use any and all categories of Personal Data we have in order to provide you with customer service. For instance, if you call us to
discuss a problem with your account, we’ll use Basic Data, Transaction Data, and likely also Profile Data to be able to respond to your query. We need this information in order to be able to fulfill our part of our contract with
you, and because we have a legitimate interest in being able to respond to your questions.
Marketing to you and others. See section 7 below, “Marketing our Products.”
Managing our website and services. We’ll use Basic Data, Technical Data, Purchase Data, and Profile Data to keep our website and other online services operating properly (fraud detection and prevention, site maintenance and
updates, app maintenance and updates, IP logs). We use this data because we have a legitimate interest in administering/improving our site and apps, running IT services, ensuring network security, preventing fraud, and because we
need to demonstrate our compliance with data security obligations both as a legal matter and if we are involved in a business reorganization (a merger or acquisition).
Creating insights and analysis. We’ll use Basic Data, Event Data, Profile Data, and Feedback and Marketing Data to analyze what customers are reading, how they use their subscriptions, how they use other products and services
related to ours, how we might be able to build better products (better layouts for a publication, for instance) and to understand general trends in the market. We may share or sell those analyses to third parties, and we may also
sell or share data about you to providers who would like to market to you. As we explain below, you can decide how much information we share with third parties.
Creating and managing your profile. When you create a profile or account on our website or in an app, you agree to share Basic Data, Transaction Data, Usage Data and Profile Data with us so that we can provide you with a
tailored, custom experience (use metrics, recommendations, trends, etc.). We need this information in order to be able to fulfil our part of our contract with you, and so collecting this data is necessary to the performance of our
contract with you.

We also use this information to create our own internal user profile for you, which we use to market products to you, deliver content that we think is relevant to you, to advertise to you, to learn about you in particular and our customers more generally, and to create an analysis of our business, our customers, and our market. We have a legitimate interest in doing these things in order to grow our business and learn about our industry, but we will only process this information in this way if you have agreed (consented) to us doing so, and you can withdraw your consent at any time.

6.3 We will only keep your Personal Data for as long as necessary under the circumstances in which we collected it, including our obligation to hold onto it for legal, regulatory, or accounting purposes. If we are able to make data completely anonymous (that is, it can’t be used to identify you), we may keep that data indefinitely for statistical or analytic purposes.

+7. Marketing our Products

7.1 Promotional offers We use your Basic, Event, Usage, Profile, and Feedback and Marketing Data to create a marketing profile for you so that we can send you information about what products, services, or other goods you may find interesting. If you’ve opted-in to receive communications, we’ll send you emails, texts, or other communications in the format you’ve chosen. We may ask you to opt-in to marketing communications via email, on our website, in the app, or in a physical location like a store or a festival.

7.2 Third-party marketing As explained above, we do not share Marketing and Profile data about you with commercial partners and third parties who may want to directly market to you.

7.3 Opting out You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of
a product/service purchase, warranty registration, product/service experience or other transactions.

7.4 Cookies Cookies are small files that track your activity online. Some of them are purely functional (they allow website to load faster) and some of them are for marketing (tracking how you interact with websites). We use cookies for both purposes, but you can read more about cookies (and how to block them) in our cookie policy.

7.5 Change of purpose We only use your Personal Data in the ways we’ve outlined in this Privacy Policy, unless we think there is a reason that we can use it for another purpose that 1) is fair, and 2) is compatible with the original reason we collected it. We’ll tell you if we need to use your Personal Data for a purpose other than the original purpose for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

7.6 Data retention

We delete or anonymize your Personal Data as soon as it is no longer required for the purposes we have collected, unless we are legally required to continue processing or your Personal Data. The one primary exception here is that, if you ask us to delete your data and “forget” you, or ask us not to contact you, we’ll keep your email address on our master do-not-contact list as proof that we followed you request and so that we can avoid contacting you in the future.

+8. Disclosures of your personal data

8.1 Sometimes, we will share your Personal Data with:

Outside third parties. As explained above, we use outside vendors and service providers to enable our company to function. The third parties we share or combine your data with are:

– Service providers acting as processors who provide IT and system administration services including cookies/user experience/analytics.
– Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
– Servicers who augment, support, or improve our services:

Alitu	Podcast tools
BuzzSprout	Podcast tools
Cision	Media services
Consensus	Web
DSMN8	Social media management
Faye	CRM
GuestManager	Events planning and oversight
Net Results	Marketing Automation
Salesforce	CRM
Sugar	CRM
Whatagraph	Business Devoelpment
Wipfli	CRM
Zoominfo	Business Development

– We’ll also share Personal Data if we buy, sell, transfer, or merge parts of our business with another company.

Regulators. If we are subject to an audit, review, or other inquiry by a properly constituted regulatory agency (like the Federal Trade Commission, for instance), they may require us to share the data we have, including
Personal Data.
Subpoenas and legal demands. We have to comply with lawful subpoenas or investigative demands from courts and law enforcement agencies.

8.2 We share your Personal Data outside third parties only to enable us to fulfil our part of our contract with you, because you have consented to it, or because it’s necessary for a legal or regulatory requirement. None of these third parties are allowed to use your Personal Data in any way that is different from the reasons we outline here.

+9. International transfers

9.1 We are based in the United States and do not transfer data from other parts of the world as outlined in this Privacy Policy.

+10. Data security

10.1 We work hard to keep your data (and ours) safe. We use a variety of tools – technological, administrative, and physical – to keep data secure. These safeguards are designed to ensure that whatever Personal Data we keep is protected against unlawful access or use. Despite our best efforts, however, no security measures are completely impenetrable. 10.2 We have 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.

+11. Your legal rights

11.1 When you provide us with personal data, you have rights about how we use it, and why. In some circumstances, those rights are set out in specific legislation like the European Union’s GDPR, Canada’s PIPEDA, or California’s Consumer Privacy Act. In general, you have the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

11.2 No fee usually required In some rare circumstances, you may have to pay a fee regarding a request, but in general you don’t have to pay anything to exercise these data rights.

11.3 What we may need from you In order to make sure that you’re the person entitled to exercise the rights listed above, we’ll sometimes request information to verify your identity. We will not ask for more data than is necessary to confirm your identity.

11.4 Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may 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.

+12.Third Party Services

As explained above, we may provide links to websites or services operated by third parties. This Privacy Policy does not apply to these third-party websites or services. If you follow a link to any of these websites or services, please note that these websites or services have their own privacy policies and terms & conditions, and that we do not accept any responsibility or liability for their policies.

+13.Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: [email protected]

By mail:
Hilco Global
5 Revere Dr., Suite 206
Northbrook, IL 60062
Attn: legal department

Your California Privacy Rights

If you are a California customer, you have the right to receive, once per year, free of charge, 1) the identity of any third-party company to which we have disclosed your personal information as defined by California’s “Shine the Light” law for that company’s own direct marketing purpose; and 2) a description of the categories of personal information disclosed. To request this information, please contact us at [email protected] or the mail address set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email or mail address.

If you are a consumer located in California, we process your personal information in accordance with California law (e.g. the “CCPA”).

Your Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information. In addition to the above rights, please note these
other California-specific rights:

– Exercising the right to know: You have a right to request additional information about the categories ofpersonal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.
– Exercising the right to opt-out from a sale: We do not sell “Personal Information” as defined by the CCPA and have not done so in the past 12 months.
– Exercising the right to limit the use or sharing of Sensitive Personal Information: we do not sell or share Sensitive Personal Information as defined by the CCPA and have not done so in the past 12 months.
– Right to opt-out of sharing of cross-context behavioral advertising.

To submit a request to exercise any of the rights described above, please contact us using the methods described in the Contact Us section below. We will verify your request by asking you to send it from the email address associated
with your account or requiring you to provide information necessary to verify your identity, including name, address, transaction history, photo identification, and other information associated with your account.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Your agent may submit a request on your behalf by contacting us using the
methods described in the Contact Us section below. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.
Do Not Track and signals.