This Privacy Notice is issued by Apex US Distribution LLC (“Apex Invest”, “we” or “us” in this Privacy Notice).

1. Who We Are

Apex Invest is a wholly owned subsidiary of Apex Group Limited (Apex Invest and other subsidiaries of Apex Group Limited together “Apex Group”). For more information about Apex Group please visit www.apexgroup.com.

Apex Invest operates an online research and discovery platform (“Website”) and hosts events (“Events”).

2. About This Notice

At Apex Invest we collect personal information about you, and we are committed to protecting your personal information and privacy. This Privacy Notice sets out how we collect, use, transfer, and store your personal information in connection with our services. It summarizes the nature of the information we hold about you, why and how we use it, your rights in relation to this information, and how we safeguard it. We aim to ensure that your information is processed in compliance with applicable data protection laws, including the Californian Consumer Privacy Act (“the “CCPA”) and the European Union General Data Protection Regulator (the “GDPR”). This Privacy notice applies to current and former users of our products and services.

3. What personal information Apex Invest collects and where we get it from

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

4. Cookies And Other Automated Tracking Technologies

Our website uses browser cookies. A browser cookie is a small file of letters and numbers that we put on your computer or device if you agree. Cookies help us to provide you with a good experience when you browse our website. Our website will place a cookie on your computer or device when you access a password protected part of the Website such as app.apexinvest.io. This cookie is placed for security purposes to store your login information and is strictly necessary to enable you to navigate the Website. We may also use flash cookies and other types of tracking technologies. Certain features of our services, such as our website, platform or apps may use local stored objects or flash cookies to collect and store information about your preferences and navigation to, from, and on our website or apps. Flash cookies are not managed by the same browser settings as are used for browser cookies.

In addition to different types of cookies, pages of our website, apps and our e‐mails and other parts of our services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single‐pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Our services also track data and information using “deep links” which allows you to travel between the Website, apps and platforms and/or a third-party website, apps and platforms. As a result, we can look for connections or deep links between your experiences on the Website and when you visit other websites or apps, and especially where we have directly provided you with links or information to a third-party website or app. In some instances, this enables us to track your preferences and streamline and customize our services.

For additional information about managing your privacy and security setting for cookies, please see the Apex Group cookie notice here.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use different types of cookies and other tracking technologies, over which we have no control even in instances when such third parties share certain data with us. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of our website.

5. How we use your personal information

1. Information you give to us
   We use information received by you in the following ways:
   • to share with our employees, agents and representatives who have a valid business reason to have access to such information;
   • to share with Event sponsors and sponsors of our online platforms, Event attendees and participants in order for us to give effect to the Apex Invest product and services you have chosen and to allow our Event sponsors and advertisers to contact you about their products or services which may be of interest to you;
   • if you are a user of the Website, to share with other users, sponsors and advertisers on the platform and related services in order for us to give effect to the Context product and services you have chosen and to allow those sponsors and advertisers to contact you about their products or services which may be of interest to you;
   • to keep you informed of relevant Apex Invest events or related products and services, including the products and services of our affiliates and our Events sponsors and Apex Invest;
   • to verify your identity for Know Your Client (KYC) purposes;
   • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
   • to notify you about changes to our products and services, this Privacy Notice or our other terms of business.
2. Information we collect about you
   We will use this information:
   
   • to administer our website and for internal operations;
   • to improve our website to ensure that content is presented in the most effective manner for you and for your computer or device;
   • to allow you to participate in interactive features of our service, when you choose to do so, which may include communications with sponsors and advertisers;
   • to ensure that content from our Website is presented in the most effective manner for you and for your computer or device; or
   • as part of our efforts to keep our Website safe and secure.
3. Information we receive from other sources
   We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive and from what source).

6. Notice to Data Subjects based outside of the U.S

Basis for use of your information

Apex Invest will only process your personal information when we have a legal basis for doing so. Our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will process your personal information under one or more of the following conditions:

• In connection with a contract to provide you with our products and services;
• to comply with a legal obligation under applicable law;
• for a legitimate business interest, where your interests and fundamental rights do not override those interests including, but not limited to:
  • providing the services for which you have enrolled;
  • to keep our records updated;
  • to study how customers use our products/services, to develop them and grow our business and inform our marketing strategy;
  • the running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercises;
  • contacting you about our products, or responding to your requests.
• Where we have your consent such as sending you marketing communications that you have opted in to receiving and placing cookies and similar technologies.

Where we rely on your consent to process your personal information, you have the right to withdraw consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object by emailing us at DPO@apexfs.com

7. Disclosure and sharing of data

Personal information may be disclosed to third parties. The recipients of such information will depend on the nature of our relationship with you and the context in which we hold your personal information.

Subject to any restrictions around confidentiality such disclosures may be made to:

• other members of Apex Group who may use such information for the purposes permitted under this Privacy Notice;
• selected third parties in the normal course of our business, including: (1) companies (including accountants and attorneys) that provide products and services necessary to enable us to provide products and services to you, to effect a transaction that you request or to otherwise service you and/or your account; (2) sponsors of Events and Apex Invest and platform sponsors and advertisers, as described above; and (3) government agencies, courts, parties to lawsuits, regulators or other competent bodies having jurisdiction over Apex Invest. When we provide personal information to a service provider/vendor we expect these providers to safeguard your information, use the information only for the intended purposes and abide by applicable law.
• third parties you provide your information to (including, but not limited to, any Event attendees) in connection with your registration for, or participation in, any Event or Apex Invest event shall be subject to any applicable agreement or privacy notice/policy that governs your relationship with such party.
• Other attendees, participants, event and platform sponsors and/or advertisers, and third parties and posted on the Website. If you are attending an Event, your name and/or the participant company that you are registered for, sponsoring, attending, or otherwise associated with an Event, will be shared in this way.

We may also disclose your personal information to third parties:

• in the event of a merger, joint venture, business combination or similar transaction, purchase or sale of any business or assets, in which case we may disclose your personal data to the prospective participant, seller or buyer;
• if Apex Invest or all, or substantially all, of its respective assets are acquired by a third party, in which case personal data held by it about its customers, users or registrants may be one of the transferred assets and we may disclose such data to the prospective acquirer.

If you are attending an Event, your name and/or the participant company that you are registered for, sponsoring, attending, or otherwise associated with an Event may also be disseminated to other attendees, participants, event and platform sponsors and/or advertisers, and third parties and posted on the Website.

Cross-border transfers

Where there is a transfer within Apex or to a third party in a different jurisdiction, including, but not limited to transfers outside of the European Economic Area, we will take appropriate steps to ensure there is an adequate level of protection for personal information (which includes a legal agreement and appropriate security measures) in place in accordance with applicable legal requirements. Third parties are permitted to use the personal data only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.

Anonymized Data

Notwithstanding anything in this Privacy Notice to the contrary, we reserve the right to include your personal data as part of an anonymized aggregation of data and such aggregated data may be shared with third parties for any purpose.

8. Retention of your personal information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Data security

Apex Invest takes appropriate technical and organizational security measures to prevent unauthorized or unlawful processing, accidental loss of or destruction or damage to your personal data. Unfortunately, the transmission of information via the Internet is not completely secure. Although Apex Invest does its best to protect your personal data, we cannot guarantee the security of your data including information transmitted to our website; any transmission is at your own risk. For that reason, please do not use email to communicate information to us that you consider to be highly confidential. If you wish, you may contact us instead via telephone. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access or unlawful use.

10. Your choices and rights as a data subject

Subject to applicable law, you have several legal rights in relation to the personal information that Apex Invest holds about you. You may be entitled to additional rights based on applicable data privacy laws in your state or jurisdiction.

Depending on applicable law, these rights may include:

• Right to access. You have the right to request access to personal information, which we have collected from/of you. In response to your request we will endeavour, to the extent required so by law, to provide necessary information pertinent to your request.
• Right to rectification. You have the right to request that Apex Invest correct any information you believe is inaccurate. You also have the right to request Apex Invest complete information you believe is incomplete.
• Right to erasure. You have the right to request that we erase your personal information in certain circumstances. We will instruct any third parties whom we may have shared such personal information with, to do the same. However, there may be circumstances where you request us to erase your personal information, but we are legally entitled to retain it.
• Right to restrict processing. You have the right to request that Apex Invest restrict the processing of your personal information, including sensitive data under certain conditions. However, there may be circumstances where you object to or request us to restrict our processing of your personal information but we are legally entitled to refuse that request.
• Right to object to processing. You have the right to object to Apex Invest’s processing of your personal data under certain conditions.
• Right to data portability. You have the right to request that we transfer the data we have collected to another organization or directly to you under certain conditions.
• Lodge a complaint. You can lodge a complaint with our Data Protection Officer or with the relevant data protection authority in your jurisdiction if you think any of your rights have been infringed by us.

11. California Privacy Rights

If you are a California resident, subject to exceptions provided by law, certain additional rights may be available to you under the California Consumer Privacy Act of 2018 (“CCPA”), these include:

• the right to access categories and specific pieces of personal information collected about you in the last 12 months;
• know whether your personal information has been sold or shared, and to whom;
• opt Out of the 'Sale'/sharing of Your Personal Data. The CCPA defines the terms "sell" and "sale" very broadly, such that some of our research related activities might fall within the definition of "sale" under certain circumstances. We may share your personal information with cookie providers who may use this data for targeted advertising. You can opt opt-out of the sale or sharing of your personal information on our website by contacting us on DPO@apexfs.com. You may also modify your preferences through the use an opt-out preference signal that may be available on your browser.
• non-discrimination. You are entitled to exercise any of your CCPA rights free from discrimination. We will not penalize you for exercising your rights by taking actions such as denying you service, charge you different prices or rates for goods or services, provide you a different level or quality of goods or services or by suggesting you may receive a different price or rate for goods or services or a different level or quality of goods or services.

You can make any of the requests set out above using the contact details set forth in this Privacy Notice. Please note that we may only comply with your request to the extent as so required by law, therefore in some cases we may not be able to comply with your request.

Verification of Identity

Should you or any other party exercise their right of access to, or the correction or erasure of your personal information we will first need to perform a verification process in order to verify identity before disclosing the requested information.

12. Further CCPA Disclosures

Categories of personal information disclosed for business purposes in the preceding 12 months:

13. Email marketing and opting out

You can ask us or third parties to stop sending you marketing messages at any time by (i) logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences; (ii) by following the opt‐out links on any marketing message sent to you; or (iii) by contacting us at cs@apexinvest.io any time.

14. How to contact us

If you have any concerns or questions about this privacy notice, or would like to exercise your rights as a data subject, you can contact us via DPO@apexfs.com

15. Updates

We will update this privacy notice when necessary to reflect changes in the law, our practices and in our services, as well as to ensure it is accurate and up to date. When we make an update we will amend the date at the top of this notice, you are therefore advised to check this privacy notice periodically. We may also notify you in other ways from time to time about the processing of your personal information.