Librios Ltd. ("Librios", "we", "our", "us"), and our affiliated companies, are committed to protecting and respecting your privacy. We are a UK based company, with our principal offices located at Librios Americas, (the Subscription Services Reseller) PO Box 6577 Bridgewater, NJ 08807 USA, and

Librios Ltd, (the Subscription Services Provider), whose registered address is at The Stable Yard, Vicarage Road, Stony Stratford, MK11 1BN, United Kingdom Company No. 03014621, and for the purpose of this policy and the General Data Protection Regulation (the "GDPR"), we are the data controller.

When you visit the Librios website, www.librios.com ("Website"), or other website we may provide, you may provide us with specific personal information about yourself, such as your name, e-mail address, or telephone number via our "Contact Us" function. In addition, LIBRIOS will receive some general information regarding your use of the Website, such as your browser information or your Internet Protocol (IP) address. This Privacy Policy describes the types of information that LIBRIOS receives from you when you visit our Website, what we do with it, how we protect it, and how you can contact us if you have a question or concern about the information we hold about you.

If you are a Librios client, you may have access to software or functions in restricted areas of our Website that permit you to input information regarding your clients or insureds. This Privacy Policy does not apply to such information, as the treatment of such information is governed by your (or your employer's) agreement with Librios permitting you to use the applicable software or functions. In addition to the terms of any agreement, it is your responsibility to ensure that you have the authority to input such information and that you are doing so in accordance with your (or your employer's) agreement with Librios and any applicable laws and regulations, including privacy and data protection laws and regulations.

Your use of our Websites is also subject to the Terms of Use and other Legal terms and conditions.

Librios receives Personal Information or General Usage Information from you when you visit our Website. By "Personal Information", we mean information such as your name, e-mail address, telephone number, login information, mailing address, address, job title, and other information that personally identifies you. Librios only receives Personal Information about you if you choose to provide it to us. Librios receives Personal Information from you when you:

+ Use the client area of the Website limited to registered users with a login ID;

+ Register for a Librios event, such as our client conference;

+ Apply for a job via the "Careers" section of the Website; or

+ Ask us a question or send feedback using Librios contact information available on the Website.

We will also receive your Personal Information when our Website directs you to a third party's website to complete one of the above transactions, such as a website that processes your registration and credit card information for a Librios event.

By "General Usage Information", we mean your browser information, your IP address, device information, operating system, the pages you access on the Website or other information regarding your use of the Website. Personal Information and General Usage Information together will be referred to in this policy as "Information".

In general, we use your Personal Information to complete the transaction that you have requested from us. For example, we will use your Personal Information to:

+ Communicate with you;

+ Establish or verify your identity when you use an area of the Website limited to registered users;

+ Respond to you about your job application;

+ Register you for an event which you have selected;

+ Address the question or feedback which you have sent to us; and

+ Enforce our Website Terms of Use.

By submitting your Personal Information, you hereby and consent and agree for Librios to use your Personal Information for the purposes set forth above and marketing purposes, such as to tell you about Librios news, events, products and services that we think may be of interest to you, and to seek feedback from you after you have purchased an Librios product or service, attended an event, taken a training course, or entered into some other transaction with us. If you do not wish to receive these types of communication from us, you can let us know at any time in one of the ways described under "How can you contact Librios about your Personal Information" in Section 9 below.

With respect to General Usage Information, Librios will use this information to monitor, protect, maintain and improve its Website, to measure and understand the effectiveness of the content Librios serves to you and others.

Librios does not sell your Information to anyone. Nor do we provide this Information to non-LIBRIOS parties to market non-Librios products to you. Librios will share your Information with the following categories of recipients:

+ Librios employees, contractors and consultants (including employees, contractors and consultants of Librios subsidiaries and affiliated companies), in the United Kingdom and US, the European Economic Area (EEA) and South Africa, who have a need to know your information to provide Librios services and information to you;

+ Trusted non-Librios parties who assist Librios with submissions of resumes and CVs through the Librios Careers section of the Website, this includes companies such as LinkedIn or Indeed;

+ Trusted non-Librios parties who assist Librios with providing Librios products, services and information to you, such as Microsoft and PayPal, who help us with Librios event registration and processing of your payments;

+ Trusted non-Librios parties that provide customer relationship management applications such as Salesforce.com; and

+ Trusted non-Librios parties such as hosting, analytics and search engine providers such as Google Analytics that assist us in the improvement and optimisation of the Website and who may have access to your Information.

Whenever we provide your Information to non-Librios parties, we enter into agreements with these parties that restrict use of your Information only to the extent necessary for the non-Librios party to provide services to Librios.

Librios will also disclose your Information if we are required to do so by law, to enforce our Terms of Use, or in urgent circumstances to protect personal safety, the public, or our Website.

We will also disclose your Information to third parties in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets or if we sell all or substantially all of our assets or are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

Where the GDPR applies, you should be aware that this Website is hosted, and some Librios companies and service providers who process your Personal Information are located, in the United Kingdom. As we expand we may store information in other territories in the future. Some of these countries do not always provide the same level of protection for your information. In these circumstances, your Personal Information is transferred within the Librios group by way of the European Commission's model contracts for the transfer of Personal Information to third countries, pursuant to Decision 2004/915/EC or by way of the European Commission's model contracts for the transfer of Personal Information to third countries, pursuant to Decision 2010/87/EU (together, the "Model Clauses").

Librios protects your Personal Information by maintaining up-to-date physical, electronic and procedural safeguards. For example, we use computer safeguards such as firewalls and data encryption. In addition, we only allow employees to access Personal Information only when required to fulfil their job responsibilities.

We will retain your Personal Information as follows:

+ If you contact us via email we will keep your data for three years after such contact; and

+ your General Usage Information for three years.

In certain circumstances you have rights in relation to the Personal Information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing adequate proof of your identity, such as a passport or driver's license. To exercise any of your rights, please email dpo@librios.com. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

+ Access: You have the right to know whether we process Personal Information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

+ Correction: You have the right to require us to correct any Personal Information held about you that is inaccurate and have incomplete data completed.

+ Erasure: You may request that we erase the Personal Information we hold about you in the following circumstances: where you believe it is no longer necessary for us to hold the personal data; where we are processing it on the basis of your consent and you wish to withdraw your consent; where we are processing your data on the basis of our legitimate interest and you object to such processing; where you no longer wish us to use your data to send you marketing or you believe we are unlawfully processing your data. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.

+ Restriction of Processing to Storage Only: You have a right to require us to stop processing the Personal Information we hold about you other than for storage purposes in the following circumstances: you believe the personal data is not accurate for the period it takes for us to verify whether the data is accurate; where we wish to erase the Personal Information as the processing we are doing is unlawful but you want us to simply restrict the use of that data; where we no longer need the Personal Information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defence of legal claims; and where you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Personal Information whilst we determine whether there is an overriding interest in us retaining such Personal Information.

+ Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

Withdrawal of Consent

Where you have provided your consent to us processing your Personal Information, you can withdraw your consent at any time by emailing dpo@librios.com

Objection to Marketing

At any time you have the right to object to our processing of data about you in order to send you promotions, special offers and other marketing materials, including where we build profiles for such purposes and we will stop processing the data for that purpose. You can object to processing of your data for marketing purposes at any time by emailing dpo@librios.com

Like many websites, our Website uses "cookies" to collect information about how our Website is used. A cookie is a small data text file which a website stores on your computer's hard drive, if permitted by your web browser. A cookie can later be retrieved to identify you to us. For example, cookies can securely store a user's password, identify which parts of a site have been visited, and keep track of past selections.

We use cookies for the limited purposes of enhancing your visit to our Website and to enable us to track usage so that we can improve the website and our offerings to you. Librios uses the following categories of cookies:

+ Strictly necessary cookies: These are cookies that are required for the operation of the Website. They include, for example, cookies that enable users to log into secure areas of our Website.

+ Analytical/performance cookies: They allow Librios to recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Librios to improve the way the Website works, for example, by ensuring that you as a user are finding what they are looking for easily.

+ Functionality cookies: These are used to recognise users when users return to the Website. This enables Librios to personalize our content for you, greet users by name and remember a user’s preferences (for example, a user's choice of language or region).

+ Targeting Cookies: These cookies record a user's visit to the Website, the pages a user has visited and the links a user have followed. Librios will use this information to make the Website more relevant to users. We may also share this information with third parties for this purpose.

Most browsers are initially set up to accept cookies. You can reset your browser to notify you when you have received a cookie, or alternatively, to refuse to accept cookies. However, you may not be able to use certain features on our website if you choose not to accept cookies. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/

We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

Some web browsers give the ability to prevent tracking of your online activity by setting a preference in your browser alerting websites you visit that you do not want them to track your online activities. This is referred to as a Do Not Track ("DNT") signal. This is different than blocking or deleting cookies, as browsers with an enabled DNT Signal may still accept cookies.

Please note that the Website may not recognize or take action in response to DNT signals from your browser. Currently, there is no accepted industry standard for what a company should do when a DNT signal is detected. In the event a final standard is established, we will assess how to appropriately respond to these signals and we will update this Privacy Policy accordingly. For more information about DNT signals please visit http://allaboutdnt.com

Our Website includes social media features and widgets which allow you to share articles from our website, etc. These features are usually recognizable by their third party brand or logo and may collect your IP address, and set a cookie to enable the feature to work properly. These social media features and widgets are hosted by a third party and are not covered by this Privacy Policy. Your interactions with these features are governed by the privacy policy of the company providing it.

From time to time you will receive an e-mail or other communication from us regarding Librios products, services or information which we believe to be of interest to you. If you are not interested in receiving this information, you may follow the instructions in the communication explaining how you may be removed from our distribution list. Alternatively, or if there are no instructions in the communication, you may send an e-mail to dpo@librios.com requesting removal from our distribution list. We will endeavour to take prompt action to process your request.

You may send all other inquiries regarding your Personal Information, including requests to correct or update your Personal Information, to info@librios.com

In the event that you wish to make a complaint about how we process your Personal Information, please contact us in the first instance at dpo@librios.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

This Privacy Policy was last updated in December 2023. Librios reserves the right to modify, amend, add to, replace or remove this Privacy Policy at any time. You are advised to check the Privacy, Terms of Use and Legal links on the Website for updates when they occur.

Microsoft's official statement

https://learn.microsoft.com/en-us/legal/cognitive-services/openai/data-privacy

Librios utilises paid Microsoft services and is guided by their published policy. Note in particular the following from the article:

Your prompts (inputs) and completions (outputs), your embeddings, and your training data:

are NOT available to other customers.

are NOT available to OpenAI.

are NOT used to improve OpenAI models.

are NOT used to improve any Microsoft or 3rd party products or services.

are NOT used for automatically improving Azure OpenAI models for your use in your resource

(The models are stateless, unless you explicitly fine-tune models with your training data).

Your fine-tuned Azure OpenAI models are available exclusively for your use.

The Azure OpenAI Service is fully controlled by Microsoft; Microsoft hosts the OpenAI models in Microsoft’s Azure environment and the Service does NOT interact with any services operated by OpenAI (e.g. ChatGPT, or the OpenAI API).

You can contact the DATA PRIVACY OFFICER at support@librios.com with an queries about this policy.