Privacy Notice – California Privacy Schedule


This California Privacy Schedule supplements our General Privacy Notice and applies to California residents where the California Consumer Privacy Act, as amended by the California Privacy Rights Act – together, the CCPA – applies to our processing of personal information.


This Privacy Schedule is intended to provide additional California-specific disclosures, including a notice at collection, and should be read together with our General Privacy Notice.


For the purposes of this Privacy Schedule, “personal information”, “sensitive personal information”, “sell”, “share”, “service provider” and “contractor” have the meanings given under the CCPA.


Otherwise, unless defined herein, capitalised terms in this Privacy Schedule shall be as defined in our General Privacy Notice. In particular, “Agency” and “Agency Group” refer to the specific agency, legal entity or group of entities responsible for the relevant processing, as described in the General Privacy Notice.


  1. Who this Privacy Schedule applies to


    This Privacy Schedule applies to California residents whose personal information we process, including:


  2. Categories of personal information we collect


    We may collect the following categories of personal information:


    CCPA category

    Examples

    Collected?

    Identifiers

    Name, business email address, telephone number,

    employer, job title, business address, IP address, online identifiers

    Yes

    Personal information

    Business contact details, financial or transaction

    information, payment/invoicing details

    Yes

    Commercial information

    Records of services provided or received, event aAendance, business relationship information,

    purchase or transaction records

    Yes

    Internet or electronic

    network activity information

    Website usage, cookie data, browsing interactions, device/browser information, analytics data

    Yes

    Geolocation data

    Approximate location inferred from IP address

    Limited

    Professional or employment-related

    information

    Employer, job title, professional role, business contact details, work history where provided in a business

    context

    Yes

    Inferences

    Business interests, preferences, event interests, marketing preferences and relationship management

    notes

    Yes

    Sensitive personal information

    Account log-in details, government ID, financial account information or precise geolocation only

    where relevant and necessary

    Not usually / limited where required


    We do not knowingly, deliberately collect personal information from children under 16.


  3. Sources of personal information


    We may collect personal information from:


  4. Purposes for which we collect and use personal information


    We collect and use personal information for the purposes described in our General Privacy Notice, including:


  5. Disclosure of personal information


    We may disclose personal information to the following categories of recipients:


    Category of recipient

    Purpose of disclosure

    Agency Group companies and The

    Independents Group companies

    Group administration, reporting, business operations, relationship

    management and service delivery

    Service providers and contractors

    IT, hosting, CRM, communications, marketing, event administration, analytics, compliance screening and business

    support

    Professional advisers

    Legal, audit, accounting, insurance, banking and consultancy services

    Clients, suppliers, event partners and

    business partners

    Business relationship management, service delivery, project

    administration and event administration

    Regulators, authorities, courts and law

    enforcement

    Compliance with legal obligations, regulatory requirements and

    protection of rights

    Corporate transaction parties

    Mergers, acquisitions, reorganisations, investments, integrations,

    financing transactions or asset sales


  6. Categories of personal information disclosed for business purposes


    In the preceding 12 months, we may have disclosed the following categories of personal information for business purposes:


  7. Sale, sharing and targeted advertising


    We do not sell personal information for monetary consideration.


    However, under California law, “sale” and “sharing” can include certain disclosures of personal information to third parties through cookies, pixels, analytics, advertising or similar technologies, even where no money is exchanged. Where applicable, certain cookie, pixel, analytics, advertising or similar technologies may be considered a “sale” or “sharing” of personal information under California law, even where no money is exchanged.


    Where applicable, we may “share” or “sell” the following categories of personal information for cross-context behavioural advertising, analytics or similar purposes:


    Category of personal information

    Categories of third parties

    Purpose

    Identifiers, such as IP address, cookie IDs or online identifiers

    Analytics, advertising or marketing technology providers

    Analytics, marketing measurement, advertising and

    website optimisation

    Internet or electronic network

    activity information

    Analytics, advertising or

    marketing technology providers

    Website analytics, marketing

    measurement and advertising

    Inferences, such as business interests or marketing preferences

    Analytics, advertising or marketing technology providers

    Marketing, audience insights and business development


    You may opt out of sale or sharing by:



  8. Sensitive personal information

    We do not use or disclose sensitive personal information for purposes that require a right to limit under the CCPA, unless we provide you with a right to limit such use or disclosure.


    Where we collect sensitive personal information, we do so only as reasonably necessary for permiKed business purposes, such as security, compliance, account administration, legal obligations or provision of requested services.


  9. Retention


    We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including for legal, regulatory, tax, accounting, audit, reporting, security, compliance, corporate recordkeeping or dispute purposes.


    In general:


    Type of personal information

    Indicative retention approach

    Business contact and

    relationship management data

    Retained for the duration of our relationship with you or your organisation and for a

    reasonable period afterwards for business administration, relationship management and legal purposes

    Contract, project,

    procurement, invoicing and account records

    Retained for the duration of the relevant relationship, contract or project and typically for 6–7 years afterwards, unless a longer period is required by law

    Marketing contact data

    Retained until you unsubscribe, opt out or object, after which we may retain limited suppression details to ensure that we respect your preferences

    Event attendance and

    preference data

    Retained for as long as necessary for event administration, relationship management

    and marketing purposes, unless you opt out earlier

    Website analytics and

    cookie data

    Retained for the periods described in our Cookies Policy or cookie consent tool

    Compliance, sanctions, KYC and due diligence

    records

    Retained for as long as necessary to satisfy legal, regulatory, audit, compliance and risk management requirements

    Complaints, disputes and legal claims records

    Retained for the duration of the matter and for such period afterwards as necessary to protect our legal rights and comply with applicable limitation periods


    Further details are set out in our Data Retention Policy, available on request.


  10. Your California privacy rights


    Subject to applicable law, California residents may have the right to:


  11. How to exercise your rights


    To exercise your California privacy rights, please contact us at: [email protected]

    Where available, you may also use any privacy request form, cookie consent tool or opt-out link made available on the relevant Agency website.


    We may need to verify your identity before responding to your request. The information required for verification may depend on the nature of your request and your relationship with us.


  12. Authorised agents


    You may use an authorised agent to submit a privacy rights request on your behalf.


    We may require the authorised agent to provide proof that you authorised them to act on your behalf. We may also require you to verify your identity directly with us or confirm that you provided the authorised agent with permission to submit the request.


  13. Non-discrimination


    We will not discriminate against you for exercising your rights under the CCPA.


  14. Financial incentives


    We do not offer financial incentives or price or service differences in exchange for the collection, retention, sale or sharing of personal information, unless we provide you with separate notice as required by applicable law.


  15. California “Shine the Light”


    California residents may request information about certain disclosures of personal information to third parties for their own direct marketing purposes, where applicable.


    To make such a request, please contact: [email protected]


  16. Contact


    If you have questions about this Privacy Schedule or our privacy practices, please contact: [email protected]


  17. Updates


We may update this Privacy Schedule from time to time. The latest version will be made available on the relevant Agency website or otherwise provided as required by applicable law.


Updated: April 2026