Privacy policy.

YOUR PRIVACY IS IMPORTANT TO GREATHEART CONSULTING.

This policy adopted by Greatheart Consulting, and any participating subsidiaries and joint venture partners, and other entities which directly or indirectly are controlled by Greatheart (each, an Affiliate, with Greatheart and its Affiliates being collectively referred to as Greatheart).

Greatheart understands your concerns about the privacy of data you may submit through this Greatheart Web site. This policy provides you information about what type of information is gathered and tracked on the Web site, how the information is used, and with whom the information is shared. Greatheart is committed to protecting our customers’ and employees’ privacy, online and offline. In the event that any inconsistencies should arise with respect to this policy concerning online privacy, the terms of this policy shall prevail.

The information we collect.

Greatheart collects two types of information about users of this Web site; “Personal Information” (including, but not limited to, your name, address, telephone number and e-mail address) and non-personally identifiable and anonymous “Aggregate Information” (such as information about how many users log onto our Web site). Unless you provide it to us voluntarily or the information is collected via cookies in the manner described in this policy, Greatheart does not collect Personal Information in connection with your use of this Web site. Please read this policy carefully to learn how you can verify the accuracy of any Personal Information we have concerning you and how you can request that Greatheart delete or update your Personal Information.

In order to accommodate your information request, we ask you to submit your name, title, company affiliation (if any), mailing address, telephone number and e-mail address. At your option, you may also provide us with the best time at which to contact you, the annual revenues of the company with which you are affiliated, the number of employees of the company you are affiliated with, and other relevant comments [if a comment field exists for the information you have requested]. By providing your personal information to Greatheart via its website, you agree to the terms of this policy and to receive communications from Greatheart.

How we use the information we collect.

We will use the information you submit (a) to answer your specific inquiry; (b) at your option, to send you additional materials relating to Greatheart and services that may be of interest to you; (c) in the administration of the Web site; and (d) as otherwise described in this policy.

How we use cookies and other technologies.

General – When you visit this site, information about your browser type, operating system, IP address, and the domain name from which you access this site is collected. In addition, we may collect information about your browsing behavior, such as the number of times you have visited the site, the date you visited the site, and the amount of time you spent viewing the site. In addition, Greatheart may track your response to Greatheart’s advertisements, e-mails and site content, determine your ability to receive HTML-based e-mail messages, learn how many users open an e-mail and allow our service providers to compile aggregated statistics about an e-mail campaign for Greatheart. This information is used solely for our internal purposes in managing the site and improving its functionality, as well as to assist us in better targeting interactive advertising, thereby enhancing customer support and site usability. The collection of such information, whether by us or by data aggregators, is subject to the terms set forth in this policy.

Transparent GIF Files – In addition to our own cookies, we may use pixels, or transparent GIF files, on our sites to help manage our online advertising and e-mail marketing. These GIF files may be provided by one or more third-party service providers, based on our specification as to where they are used. The files enable our service providers to recognize a unique cookie in your Web browser, which, in turn, enables us and our service providers to learn which advertisements and e-mails bring you to our website and how you use the site.

Examples of the ways in which Greatheart and our third-party service providers use GIF files include:

  • Tracking customer response to our advertisements, e-mails and site content.

  • Determining your ability to receive HTML-based e-mail messages. This capability helps us or our service providers send you e-mail in a format you can read.

  • Knowing how many users open an e-mail, thereby enabling our service providers to compile aggregate statistics about an e-mail campaign for us.

  • Allowing us to better target interactive advertising; enhancing customer support and site usability; and providing offers and promotions that we believe would be of interest to you, if you have given us permission to do so by opting-in to receive them.

To conduct these or other activities, we or our service providers sometimes may link Personal Information you previously provided us (such as, for example, your name and e-mail address) to the information the GIF files provide about how you arrive at, navigate through and leave our sites.

Your right to reject use of cookies.

You may choose not to accept the cookies, however, this may restrict the services that you can access at the Web site.

The information we disclose.

Subject to applicable law, we and our service providers (as defined below) disclose and share your personal information:

  • Among Greatheart and its Affiliates;

  • To unaffiliated third parties that are under contract to perform services for or on behalf of Greatheart (Service Providers), and are required to uphold and maintain policies with respect to privacy and the treatment of your Personal Information (e.g., vendors hosting the investor relations, or Greatheart Intellectual Property Management aspects of this web site or other vendors providing services of the nature referred to in this policy);

  • To a third party in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or division; and

  • To other persons as permitted or required by applicable law or regulation.

  • For credit card payments, we employ third parties to process these payments on our behalf. These third-party credit card processing parties will only have access to the personal information which you provide directly to them when you make a credit card payment. They are required under their contract with Greatheart to process this personal information securely and in accordance with the relevant privacy or data protection laws.

Any access to such information will be limited to the purposes for which such information was provided to us or our Service Providers. Greatheart, its Affiliates and Service Providers are located throughout the world. Accordingly, your Personal Information may be sent to countries which have a different level of privacy protection than the United States of America (USA) or your country of residence. For instance, if you inquire about services Greatheart provides in France and in Brazil, Greatheart may forward your inquiry to a Greatheart location in such countries. Greatheart will, at your request, provide you with details of companies and countries to which your information has been sent.

Links and third-party websites.

This policy applies only to this Web site. This site includes links to both our Affiliated Web sites and to non-affiliated Web sites, including access to content, products and services of such Affiliated and non-affiliated sites. In some cases, these other sites are made available via “seamless experience” technology, and may appear to be part of our Web site. Although some of the entities controlling these sites are under contract with Greatheart, we urge you to familiarize yourself with the individual privacy and other terms for each linked Web site prior to submitting your personally identifiable information.

How to opt out or request changes.

You are entitled to request that Greatheart:

  • provide you with a copy of your Personal Information that it holds;

  • cease processing your Personal Information, in whole or in part, as you direct us, for the purposes of direct marketing;

  • correct any errors in that Personal Information; and

  • update that Personal Information as required.

If you would like to receive a copy of the Personal Information we have about you as submitted to us via this Web site, or if you wish to opt out of receiving marketing related communications from us, please send a request to info@greatheartconsulting.com. You may also ask us to remove your name and other Personal Information from our databases. In each of the foregoing cases, we will make all reasonable efforts to honor your request promptly, subject to legal and other permissible considerations.

If you do not receive acknowledgement of your inquiry, or if you continue to have questions thereafter, then you may file a request for mediation of an online privacy issue with the American Arbitration Association at 335 Madison Avenue, 10th Floor, New York, New York 10017-4605, USA; telephone: 212-716-5800; fax: 212-716-5905 and e-mail: websitemail@adr.org. Any mediation shall take place at a location mutually agreed to as being convenient to both parties; if mutual agreement cannot be achieved, then it shall take place at a location convenient to the party which did not initiate the mediation request.

Changes.

Greatheart may, in its sole discretion, update this policy at any time and from time to time, by posting the amended policy on this Web site. We urge you to refer back to this page regularly and especially prior to providing any Personal Information via this Web site. You can determine if this policy has been revised since your last visit by referring to the “last updated” legend at the bottom of this page. This policy may not be otherwise amended without the written consent of Greatheart.

As we provide more services on our websites and as privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy without notice. You can determine if this Privacy Policy has been revised since your last visit by referring to the “last updated” legend at the bottom of this page.

How we protect and store your information.

Greatheart takes seriously the security of the information it collects. Greatheart takes measures to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the data concerned. Personal Information collected via this Web site is stored on servers in the USA, and these servers are subject to Greatheart’s IT security policies and procedures. If you are located in another jurisdiction, you should be aware that your Personal Information once collected will be transferred to our servers, and the USA currently does not have uniform data protection laws.

Children.

Greatheart is concerned about the safety of children when they use the internet, and will never knowingly collect Personal Information from minors (children under 13 years of age, or any other age defined under applicable law) [without prior verifiable parental consent]. If we become aware that a minor is attempting to or has submitted Personal Information via this Web site, we will notify the user that we may not accept his or her Personal Information. We will then remove any such Personal Information from our records.

Last Updated: 5 June 2023