May 25, 2018
1. How we collect your personal data
We may collect personal data that you choose to provide to us through the Site, including, but not limited to, your first and last name, physical address, e-mail address, or telephone number, such as when you:
Fill out a form on the Site
Sign-up to receive direct marketing communications on the Site
Sign-up to a feature that we offer on the Site and you provide your personal data in connection with that feature
Attend an event that we have organised or
Communicate with us (for example, on a social media platform or by sending us an email
Sign-up for or access our products and services
When you visit our Sites, we also may collect certain information by automated means using technologies such as cookies, non-cookie-based tokens, web server logs, tracking pixels, and web beacons. Cookies are files that websites send to your computer or other Internet-connected device to identify your browser uniquely or to store information or settings in your browser. Your browser may tell you when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Site. Non-cookie-based tokens are encoded URL-based identifiers that track e-mail click-thru activity or time-sensitive password reset keys and will work in scenarios where cookies are disabled or a session has not been initiated.
We may also collect personal data in other contexts that we will notify you of at the time.
2. What type of information we collect
Information That You Provide to Us
Personal data that you provide directly to us will be apparent from the context in which you provide it, for example:
If you fill out a form on our Site, you will generally provide your name, contact details and any other information requested by the form, such as the reason for your enquiry or your product preferences;
If you sign up to receive electronic marketing communications from us, you will generally provide your name, email address and other contact information, and your product preferences;
If you fill out a form when signing up for or obtaining access to our products and services, you will generally provide your name, contact details and any other information requested by the form. Each form on our Site varies in the information required and collected. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information within fields that are not required.
3. How We Use Information That We Obtain
Information That You Provide to Us
We may use personal data that you provide to us to provide you access to our products and services, respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, consider your application for employment, and contact you for other reasons related to offering and improving our services.
In addition to the uses discussed above, we may also use the personal data you provide on our Site to:
operate, evaluate, and improve our business;
develop new products and services;
perform market research;
advertise and market our products and services from time to time;
provide you with invitations to conferences or other events;
determine the effectiveness of our advertising and marketing;
analyse our products, services, and websites;
check and confirm your password;
to carry out our obligations arising from any contracts entered into between you or your employer and us;
administer the Site.
We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights and freedoms to protect personal data about you.
Information That We Collect Automatically
We use personal data that we collect automatically through cookies, non-cookie-based tokens, web beacons, and other automated means for purposes such as customizing and enhancing our visitors’ visits to the Site, facilitating use of the Sites, collecting statistics about your visits to the Site, and understanding the manner in which our visitors browse the Site. We also use the information to help diagnose technical and service problems, administer the Site, and identify visitors to the Site. We use clickstream data to determine how much time visitors spend on web pages of the Site, how visitors navigate through the Site, and how we may tailor the Site to meet the needs of our visitors. We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our Site that is not overridden by your interests, rights and freedoms to protect personal data about you.
4. Information We Share
We do not sell or otherwise disclose personal data that you provide to us or that we collect on our Site, except as described here. We may share personal data you provide to us or that we collect on the Site with the service providers that perform services on our behalf.
We may share personal data with service providers that perform services on our behalf such as payment service providers, analytics providers, hosting providers and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements.
In addition, we may disclose personal data about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (c) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
5. Data Transfers
We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we will protect that personal data as described in this Notice.
If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the EEA and Switzerland. In all such cases, we will only transfer your personal data if:
The country to which the personal data will be transferred has been granted a European Commission adequacy decision;
The recipient of the personal data is located in the U.S. and has certified to the US-EU Privacy Shield Framework; or
We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Contracts.
6. How Long We Keep Information
The time period for which we keep personal data depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfil the purposes for which we collected it. We will then delete the personal data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal data as follows:
Personal data you provide to us through our Site: we keep this personal data for as long as necessary in order to respond to your request, and for a short further period in case you send us further requests.
Personal data you provide to us through the account setup or access process: we keep this personal data for as long as necessary in order to manage access to your account, and for a short further period in case you send us further requests.
Personal data you provide when you sign-up to receive direct marketing communications: we keep most of this personal data for the duration of our relationship with you until you opt-out or we do not have any contact with you for a long period of time.
Personal data collected for analytics purposes: we keep this personal data for a short period of time necessary for us to carry out the analytics.
Website logs: we keep Site audit logs, which may contain your personal data, for as long as necessary to fulfil the purpose for which it was collected.
7. Your Rights and Choices
If you are located in the European Economic Area (“EEA”) or Switzerland, you may have the following rights in relation to personal data that we hold about you:
To request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
To request that we rectify or update your personal data that is inaccurate, incomplete or outdated.
To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
Where you have given us consent to process your personal data, to withdraw your consent; and
To request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances.
You may contact us by e-mail or as described in the “How to Contact Us” section below to exercise your rights described above.
You also have the right to lodge a complaint with the data protection supervisory authority in your country. You can find the contact information of the data protection supervisory authority in your country here.
8. How to Contact Us
If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data, or if you would like us to update information we have about you or your preferences, you may contact us:
By e-mail at: [email protected]