We, or our authorized third-party service providers, automatically collect technical and/or analytics information about how you use and/or interact with our Websites, including, but not limited to, the log data and device data collected below (collectively, “Usage Information”). Usage Information allows Privacera to understand how users are interacting with and using our Websites, and other actions taken in connection with the use of our Websites. We use this information for our internal purposes, specifically to operate, maintain, secure and improve our Websites.
When you visit our Websites, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details
We may also collect data about the device you’re using to access our Websites. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Personal Information Privacera Collects Directly From Users
When you contact us through the Websites and/or sign up to receive marketing communications from us, we may ask for personal information, such as your:
- Social Media Profiles
- Date of Birth
- Phone/Mobile Number
- Work Address
Social Media Interactions
If you interact with us through our social media pages and/or accounts through third party social networking sites (e.g., LinkedIn, Facebook, Instagram, or Twitter), we will collect data and/or information related to such interactions.
Legal Bases for Processing
We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.
We process your personal data for the following legal bases:
- it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
- it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
- you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
- we need to process your data to comply with a legal obligation.
Personal information is processed for the period necessary to fulfill the purposes for which it is collected, to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights. In order to determine the most appropriate retention periods for your personal information, we consider the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal information, and applicable legal requirements.
In some instances, we may choose to anonymize personal information instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal information can be linked back to any specific individual.
While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, please note that no method of electronic transmission or storage is 100% secure and we cannot guarantee absolute data security.
We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:
- to enable you to customize or personalize your experience of our Websites;
- to host and provide our Websites;
- to deliver direct marketing communications to you regarding products and services of ours that we may think are of interest to you;
- to respond to your queries and requests, or otherwise communicate directly with you;
- to provide customized advertisements, content, and information (provided that, where required under applicable law, we will only provide you with tailored content with your opt-in consent);
- where we need to process your data to comply with a legal obligation.
We may disclose personal information to:
third party service providers that help us in the operation, provision, administration and management of our Websites, and to otherwise operate our business. Depending on how you use our Websites, the following categories of third party service providers collect data on our behalf or receive personal information: IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators; and our employees, contractors and/or related entities.
To successors and/or acquires of our business and/or assets. If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy. law enforcement and/or other government agencies if we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or other agencies with proper jurisdiction. Under such circumstances, unless prohibited by applicable law, we will attempt to provide you with prior notice that a request for your information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address. However, government requests may include a court-granted non-disclosure order, which prohibits us from giving notice to the affected individual. In cases where we receive a non-disclosure order, we will notify you when it has expired or once we are authorized to do so. Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.
The European Union’s General Data Protection Regulation (“GDPR”) allows for transfer of personal data from the European Union to a third country in certain situations. We rely on legally-provided mechanisms to lawfully transfer personal information across borders. For example, we may enter into the EU Standard Contractual Clauses adopted by the EU Commission. More information about the Standard Contractual Clauses is available here.
The right to erasure (also known as the ‘right to be forgotten’): You have the right in certain circumstances to ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it).
Withdrawing Consent: You have the right to revoke any consent you may have previously given us at any time, if we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
The right to object: You have the right to object to us processing your personal data (for example, if you object to us processing your data for direct marketing).
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our Websites.
Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches: We will comply laws applicable to us in respect of any data breach.
Rights in relation to automated decision-making and profiling: You have the right for us to be transparent about any profiling we do, or any automated decision-making.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
These rights are subject to certain rules around when and to what extent you can exercise them.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We will respond to all legitimate requests within the time periods required by law. Occasionally it may take us longer than the minimum timeframes under applicable law if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.
Finally, if you are located in the European Economic Area, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us first.
Privacera does not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health and genetics, or biometric data to use the Websites.
Privacera does not target the Websites, or any of our products and/or services, to persons under the age of 18, nor does Privacera knowingly collect personal information of, persons under the age of 13 or the equivalent age as specified by law in the applicable jurisdiction (e.g., 16 years of age if you are located in the EEA). Therefore, we ask you not to provide us with personal information of persons under the age of 13 or the equivalent age as specified by law in your jurisdiction. If we learn that personal information of persons under the age of 13 or the equivalent age as specified by law in the applicable jurisdiction, has been collected on or through the Websites, then we may deactivate the account or otherwise terminate access to the Websites and/or make the user content inaccessible.
On or through the Websites, we may provide third-party “share” buttons which enable you to share certain content via social media sites (e.g., Facebook, Twitter, Instagram, YouTube, and LinkedIn). These “share” buttons may function as web beacons when you interact with the button. Please note that when you “share” using the buttons, you may send to the third party provider of the “share” button the information that you are viewing. If you are not logged into your account with the third party provider, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the Websites to your account with the applicable third party provider. Please refer to each third party’s privacy policies to learn more about its data practices.
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