At Scarritt Group, Inc.”Scarritt” we are committed to safeguarding the privacy of our customers. We will never sell, release, or transmit customer information externally for any purpose, other than with approved business partners, in secure circumstances, and only then for the benefit of creating successful meeting experiences for our clients. All internal information is gathered and retained only for the duration of retained services, except as defined by regulatory requirements, and then based upon the regulatory retention period, and/or client request for data archival.

The Privacy Statement describes how we collect, use, protect, and disclose the Personal Information that you share with us online and offline, unless otherwise provided pursuant to an informed consent signed by you. Scarritt websites that display this Privacy Statement are committed to only collecting, maintaining, and securing your Personal Information in accordance with the terms of this statement. We encourage you to read this Privacy Statement in its entirety before submitting any information. By using any Scarritt website, portal or services, submitting or requesting information, you acknowledge that you understand and agree with the provisions of this Privacy Statement.

Scarritt Group/Source 360 is a meeting planning company. We collect and process personal data for the sole purpose to provide clients with information and services, including, but not limited to, Available Service Menus, Request for Information or Proposal, Conference Registration, Travel Arrangements, Virtual Conference Center Access, Informational Portals, and Learning Management Systems. That personal data will be onward transferred only to third parties who are directly involved in the fulfillment of meeting and event related services for our customers and for that specific purpose only. These third parties include (but are not limited to) airlines, hotels, transportation services and other related service providers. We respect the privacy of your Personal Information (any information related to an identified or identifiable individual), and only collect volunteered information, and then only in relation to the provided service to the client.

In the course of providing its Services, Scarritt Group/Source 360 may collect, use, store, and disclose personal data. Personal data is any information that can be used to identify you or that we can link to you. You, user of the Services, may be asked to provide certain personal data when you use our Services, such as:

• Name
• Position title
• Company
• Address
• Phone number
• Email address
• Registration information

Where permitted by law, non-Personal Information and data may be automatically collected through the standard operation of Scarritt’s Internet service or through the use of “cookies” or “internet tags” and other similar techniques. This type of anonymous information allows Scarritt to evaluate customer interest in its websites and perform other market research activities. Cookies are small text files a website can use to recognize repeated usage, facilitate the user’s access to and use of the site, and allow a site to track usage behavior and compile aggregate data that will allow content improvement and targeted advertising. Cookies are programs that come into a user’s system but do not damage files. Generally cookies work by assigning a unique number to the user that has no meaning outside the assigning site. If a user does not want information to be collected through the use of cookies, there is a simple procedure in most browsers that allows the user to deny or accept the cookie feature; however, users should note that cookies may be necessary to provide the user with certain features (e.g., customized delivery of information) available on Scarritt’s websites. Scarritt also may collect and store the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our website; the Internet address of the website from which you linked directly to our website.

Some web browsers that you use may transmit “do-not-track” signals to websites with which the browser communicates. As of the Effective Date of this Privacy Statement, an industry standard on how to respond to these signals has not yet been established. Since industry standards are still evolving, Scarritt will not separately respond to or take any action with respect to “do-not-track” configurations in your internet browser. Scarritt will reassess its approach based upon future procedures, but will respond with similar guidelines, based upon only gathering information based upon providing services to existing clients.

Scarritt Group/Source 360 will only share information with Third Parties who are contractual business partners, and who have signed agreements with Scarritt, requiring that they abide by our data use policy, including, but not limited to, our requirements of not selling, transferring, or any use of the data, other than for the contracted purpose of providing goods and services to our clients, as well as the requirement that they will guarantee the destruction of user data upon completion of the goods and services provided.

In addition, we may use or disclose Personal Data about you as we deem necessary or appropriate

• under applicable law, including laws outside your state or country of residence;
• to respond to requests from public and government authorities including public and government authorities outside your state or country of residence;
• to comply with subpoenas and other legal processes;
• to pursue available remedies or limit damages we may sustain;
• to protect our operations or those of any of our parent company and Affiliates;
• to protect the rights, privacy, safety or property of Scarritt Group/Source 360, Affiliates, you and others.

Scarritt Group/Source 360 has established a privacy program designed to help respect and protect your data privacy rights. We maintain administrative, technical and physical safeguards intended to protect against the loss, misuse, unauthorized access, alteration, or disclosure of Personal Information and Collected Sensitive Personal Information. Although we take such precautions seriously, it is impossible for us to guarantee the safety and security of Personal Information or Collected Sensitive Personal Information. We cannot ensure or warrant the security of any information.

We reserve the right to retain any Personal Data as long as the Personal Data is needed to: fulfill the purposes that are described in above (Why and how we collect data) and comply with applicable law.

Scarritt Group/Source 360 websites are not directed or intended for children. The services offered on our websites are designed for individuals who are 18 years of age or older. If your child has submitted Personal Information and you would like to request that such information be removed, please contact privacyofficer@Scarrittgroup.com. For more information about protecting the privacy of children online in the United States under the Children’s Online Privacy Protection Act, please see http://www.ftc.gov/ogc/coppa1.htm (last accessed January 2013).

Many of Scarritt Group/Source 360 websites may contain links or references to third-party websites as a convenience to you. This Privacy Statement does not cover the practices of these websites. Accessing these sources requires that you leave Scarritt’s websites. Scarritt does not control the content of these third-party websites and is not responsible for the privacy practices of these websites. Please review the privacy policies on each website that you visit.
Your Rights

If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via the Scarritt Group/Source 360, you may submit a request to privacyofficer@Scarrittgroup.com.

If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via the Scarritt Group/Source 360, you may submit a request to privacyofficer@Scarrittgroup.com).

The foregoing terms are effective as of May 25, 2018. Scarritt may update this Privacy Statement from time to time based on, among other things, changes in applicable laws, development of new websites, and advances in technology. Scarritt reserves the right to modify, add, or remove portions of this Privacy Statement at any time at our sole discretion. If we decide to revise this Privacy Statement, we will post the revised Privacy Statement at this site. We encourage you to review the Privacy Statement each time you visit our site. This Privacy Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

If you have any questions about our Privacy Statement, please address all correspondence to email at privacyofficer@scarrittgroup.com.

As an International Company, Scarritt Group is committed to adhering to the guidelines and regulations of the areas we serve. General Data Protection Regulation (GDPR) provides additional requirements for the collection and retention of Personal Users data in EU (European Union).

At Scarritt Group we are in the business of selling ourselves to our customers, not selling our customer’s data to others. We do not collect, retain, or use any client data for any other purpose other than to ensure a successful outcome for our client’s meetings. Upon completion of services, data is only retained as specified by regulatory guidelines, and only for the period of time defined, or alternatively, as has been specifically contracted by clients to retain for their archival purposes.

We utilize industry leading Information System Products and enforce Information System Data Protection policies to safeguard all internal Personal Information. Please contact privacyofficer@scarrittgroup.com with any questions or request for information.