PRIVACY POLICY

Welcome! We are Gray Consulting, Inc. (referred to herein as “we” or “Gray Consulting”). We provide corporate meeting and event planning services to our clients (our “Clients”) in connection with certain events that they host (the “Events”), and in connection with our provision of these services we may be required to collect certain information from you. This Privacy Policy is intended to explain what type of information we collect from you, how we use that information, and who we share that information with. This Privacy Policy applies to the information collected online at www.gcimi.com (our “Site”), as well as to information collected by us offline.

SAFE HARBOR CERTIFICATION

In light of the international nature of our business, we comply with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. Gray Consulting has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. For more information about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/.

WHAT TYPE OF INFORMATION DO WE COLLECT?

1. Personal Information

We collect certain personal information from you when you register for an Event. The personal information that we could collect includes your first and last name, mailing address, email address, and bank account information (where required and permissible), travel information relating to your travel plans to and from the Event, and any other information that you choose to provide to us. This information is referred to as “Personal Information” in this Privacy Policy.

2. General Browsing and Tracking Mechanisms used on our Site

We gather navigational information about where visitors go on our Site and information about the technical efficiencies of our Site (i.e., time to connect to our website, time to download pages, etc.). This information is referred to in this Privacy Policy as “Navigational Information” (and, together with Personal Information, collectively referred to as your “Information”) and allows us to see which areas of our Site are most visited and helps us better understand our visitors’ experiences at our Site. In the process of gathering Navigational Information, non-personally identifiable information (for example, domain type, browser version, service provider and IP address) may be collected which will provide information regarding a visitor’s use of our Site.

We collect Navigational Information from technology such as cookies. Cookies are small text files that help us to personalize the content of our Site. We use cookies and other tracking technology to compile aggregate data about our Site’s traffic so that we can offer better experiences and tools in the future. If you prefer, you can choose to turn off all cookies via your browser settings. However, if you turn your cookies off, some features of our Site may not function properly.

HOW DO WE USE YOUR INFORMATION?

We use your Information to:

  • provide services to you or our Clients;
  • deliver information to you through the various communication channels you have provided to us about the Event(s) that you have registered for and/or services that we provide to you or our Clients;
  • develop and improve our services and the Site; and
  • respond to your inquiries.

WHAT INFORMATION DO WE SHARE WITH THIRD P ARTIES?

We will share your Personal Information with our Clients in connection with their hosting and administration of the Event(s) for which you register. We may also share your Personal Information with our travel assistance partners, in connection with booking airfare, hotel and/or train reservations on behalf of you in connection with your attendance at Event(s). With your prior approval, we may also share your Personal Information with your bank(s) for reimbursements of Event expenses that you are entitled to, as determined by the Client hosting the applicable Event.

We may use third party vendors to assist us with our business (“Third Party Vendors”). Some examples of the assistance that may be provided by third party service providers are: operations and marketing assistance, maintaining our database, and hosting our Site. We will share your Information with these Third Party Vendors as necessary for them to perform their functions. Use of your Information by these Third Party Vendors is governed by their own privacy policies and procedures and not by this Privacy Policy.

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, some or all of the Information may be part of the transferred assets.

To the extent permitted by law, we may also disclose Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others.

IMPORTANT NOTICE TO NON-U.S. RESIDENTS

We abide by the principles set forth in the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union member countries and Switzerland. However, it is important to note that the servers that store your Personal Information are operated in the United States. If you are located outside of the United States, please be aware that any Personal Information that you provide to us may be transferred to the United States. By providing us with any Personal Information, you consent to this transfer, except in the case of data transfers from the European Union member countries and Switzerland, which are covered under the U.S.-EU Safe Harbor Framework and U.S.-Swiss Safe Harbor Framework.

In order to comply with the Safe Harbor framework, we commit to the resolution of complaints about your privacy and our collection or use of the information. We have committed to resolve any complaints by European Union citizens relating to this Privacy Policy, which cannot be resolved directly with us, through the Council of Better Business Bureaus, Inc.’s Safe Harbor Privacy Dispute Resolution Procedures. If you have any questions or concerns regarding this Privacy Policy, please contact us as set forth in the “Questions or Comments” section below. We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your question. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

UPDATING YOUR PERSONAL INFORMATION

If any of your Personal Information changes after you provide it to us, please contact us at privacy@gcimi.com so that we can update your Personal Information.

CHILDREN

We do not knowingly collect Personal Information from children under the age of 13. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children to never provide Personal Information via the Internet without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

LINKS TO OTHER WEBSITES

For your convenience, our Site may contain links to web sites that are owned and/or operated by third parties (each, a “Third Party Site”). We are not responsible for the privacy practices, advertising, products, services or the content of any Third Party Site. Links that appear on our Site should not be deemed to imply that we endorse or have any affiliation with any Third Party Site or the products, services, or content made available through any Third Party Site. We encourage you to review the separate privacy policies and terms of use of each Third Party Site that you visit.

SECURITY STATEMENT

We take commercially reasonable steps to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from our Site may not be secure, and you should therefore take special care in deciding what information you send via e-mail.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the bottom of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on our Site as they go into effect. By providing us with any Personal Information after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

QUESTIONS OR CONCERNS

If you have additional questions or would like more information regarding our information collection, use or disclosure practices, please feel free to contact us at privacy@gcimi.com.

This Privacy Policy was last updated October 9, 2014.

We self-certify compliance with

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