Updated: May 20, 2019
- Purposes of Processing
What is personal data?
We or our vendors collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2018 and any successor legislation, this includes any information which either alone or in combination with other information we or our vendors hold about you, identifies you as an individual, including, for example, your name, postal address, email address, phone number, Apvera username and password, and credit card information.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Services. If you created a profile/registered with us, you will have been asked to tick to agree to provide this information in order to access our services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services.
- Collecting Your Personal Data
We collect information about you in the following ways: Information You Give Us. This includes:
- the personal data you provide when you register to use our Services, including your name, email address, telephone number, username, and password.
- the personal data that may be contained in any alert, comment or other submissions you upload or post to the Service;
- the personal data you provide in connection with promotions we run on the Site
- the personal data you provide when you report a problem with our Site, Applications, or Services, or when we provide you with customer support;
- the personal data you provide when you correspond with us by phone, email or otherwise.
Information We Get from Others. We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners or with us at a conference or other public forum, we may add this to the information we get from our Service.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site, Application(s), or Service. For example, when visiting our Site, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the sections on cookies and Pixel Tags below.
Automated Decision Making and Profiling
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
Third Party Websites
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
What are cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site or Service.
We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third-party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
Our Site and Service use the following types of cookies for the purposes set out below:
Type of cookie
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use third-party tools including Bizible and Google Analytics to improve how our Site works.
Bizible uses its own cookies. You can find out more information about Bizible analytics cookies here: https://www.bizible.com/cookie-declaration
You can find out more about how Bizible protects your data here: https://www.bizible.com/privacy-policy
You can prevent the use of Bizible analytics relating to your use of our Site by changing the settings on your browser. Look at your browser’s help menu to determine the best way to modify your particular browser type’s cookie storage. For more information about how to control or delete cookies, visit http://www.aboutcookies.org/ Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Targeted and advertising cookies
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.
You can disable cookies that remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
- PIXEL TAGS
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.
- DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. Our website is configured to honor do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- Using Your Personal Data
We may use your personal data as follows:
- to operate, maintain, and improve our Site, products, and services;
- to manage your account, including to communicate with you regarding your account, if you have an account on our Service;
- to operate and administer promotions you participate in on our Site;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
- as described in the “Sharing of your Personal Data” section below.
- Sharing Your Personal Data
We may share your personal data as follows:
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so
- Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, alert delivery, auditing, and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
- Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
- Aggregated/Pseudonymized Data
When we use the term “aggregated data” or “pseudonymized data,” we are referring to personal data that has been aggregated or pseudonymized in ways designed to avoid a particular individual being identified or identifiable, either alone or when combined with any other information available to a third party.
We may create aggregated data from the personal data we receive about you and other individuals whose personal data we collect. Aggregated data might include analytics information and information collected by us using cookies. We make personal data into pseudonymized data by excluding information (such as your name) that makes the data personally identifiable to you. We use this aggregated/pseudonymized data to analyze usage patterns in order to make improvements to our Site.
- Third Party Sites
our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
- User-Generated Content
You may share personal data with us when you submit user-generated content to our Service, including comments and manually generated incidents. Please note that any information you post or disclose on our Site will be available to other users of our Service within your organization. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Service.
- International Data Transfer
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our service, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 18 below.
We will only retain your personal data as long reasonably required to provide you with the Service unless a longer retention period is required or permitted by law (for example for regulatory purposes).
- Our Policy on Children
Our Site and Service is not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in Section 18 below. We will delete such information from our files as soon as reasonably practicable.
- Sensitive Personal Data
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service or otherwise to us.
If you send or disclose any sensitive personal data to us when you submit user-generated content to our Site, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user-generated content to our Site.
- Your Rights
- Opt-out. You may contact us anytime to opt-out of (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the European Economic Area (the “te”). Please note that your use of the Service may be ineffective upon opt-out.
- You may access the information we hold about you at any time via your account or by contacting us directly.
- You can also contact us to update or correct any inaccuracies in your personal data.
- Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example, when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
- Object to processing. You may object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
- Request to restrict processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Withdraw consent. You may withdraw your consent for processing at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights, please contact us using the details in Section 18 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolving any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at email@example.com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however, if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
- Contact Information
We welcome your comments or questions about this Policy. You may contact us in writing at firstname.lastname@example.org.