What information do we collect?
Personal Information (“Personal Information”) is personal information you provide us, or what we collect from you and your devices in connection with your access to and use of the Website. In legal terms, we collect and use this Personal Information as a data controller. There are two general ways in which we collect Personal Information when you access or use the Website.
- Information we automatically collect from your use of the Website – When you visit the Website, your browser and computer automatically provide to us certain technical information about your computer or device. This information may be collected using “cookies”, “log files” web beacons”, “tags” and “pixels”. For more information about cookies, and how to disable them, please visit allaboutcookies.org. The following are different kinds of information we automatically collect from your use of the Website:
- “Usage Information” – includes information about your use of our Website and how you arrived at the Website, including the URL that referred you, the pages you navigate through the Website, how long you stay on those pages, frequency, time and pattern of your Website use.
- “Technical Information” – includes information collected when you access our Website including your internet protocol address, your access date, browser type and version, time zone setting and location, operating system, device type and other technology of the devices you are using.
- Information you give us – When you fill out a form, send an email to our team or otherwise send us information through the Website, we collect personal information about you. The Website has webpages that allow you to submit an enquiry to contact us. The following are different kinds of information you give us from your use of the Website
- “Identity Information” – includes your first name and last name.
- “Contact Information” – includes your email address and telephone number.
- “Professional Information” – which includes employer or organization details.
- “Enquiry Information” – includes information contained in any enquiry you submit to us regarding our Website or the services that we provide.
Information we collect from our partners and other sources
We may also obtain information about you from other sources and combine that with information we collect about you through your use of the Website. For example, we may obtain your contact information if you attend a conference or webinar that we sponsor and the organizer provides us with a list of attendees. We may also obtain your contact information from third parties that market mailing lists. If we receive Personal Information from a third-party source and/or if we combine the information we receive from these third-party sources with your Personal Information, we will treat that information as Personal Information. We are not responsible for the accuracy of the information provided by third parties or how such third parties collect, use and share such information.
Use of Personal Information
We use the Personal Information we collect to provide, maintain, protect and provide our Website, to develop new products and services, and to protect us and our customers. For example, we may use Personal Information about you for the following purposes:
- Facilitate and improve your online experience of the Website;
- To enable you to access and use the Website;
- To communicate with you, including contacting you electronically for the purposes of responding to your comments, questions and requests, providing customer services and support, providing you with information about any of our services, if any, providing you with technical notices, updates, security alerts and administrative messages. You can opt out of receiving such information at any time.
- To monitor and analyze trends, usage and activities on our Website;
- To investigate and prevent authorized access to our Website and other illegal activities;
- To protect and/or enforce our legal rights and interests, including defending any claims; and
- For other purposes authorized by you or applicable privacy laws.
As described above, we use your Personal Information to communicate with you to provide you with information about any of our services or such other targeted advertisements or marketing communications that we believe may be of interest to you. For more information about how targeted advertising works, please visit the Network Advertising Initiative’s educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can also opt out of targeting advertising by using the links below:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/
Legal Basis for Use
Our legal basis for collecting and using Personal Information as a data controller will depend on the specific circumstances in which it was collected. In general, we process your Personal Information under the following legal basis:
- Consent – we process your Personal Information if you have consented to the processing activity. You may revoke your consent at any time, in which case we will cease further processing of your Personal Information based on your consent. This will however not impact the lawfulness of processing your Personal Information based on consent before it was withdrawn. Your access to and use of the Website might only be available based on consent.
- Contract – we process your Personal Information to perform our obligations to you under a contract.
Sharing of Personal Information
Except as set forth herein, we may disclose your Personal Information to our agents, vendors, consultants and other service providers to carry out work on our behalf. These entities acting on our behalf are prohibited from using your Personal Information for any purpose other than to provide this assistance.
We must disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In addition, we may share information about you as follows:
- To the maximum extent permitted by applicable law, in response to subpoenas or other legal process or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud;
- To protect the rights, property, life, health, security and safety of us or any third party;
- To the maximum extent permitted by applicable law, we may also use IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you;
- With our affiliates for internal business purposes; and
- In connection with, or during negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, or any other type of acquisition of all or any portion of our assets, financing, disposal, conveyance or transfer of all or a portion of our business to another company, in this event you will be notified via prominent notice on our Website of any change in ownership or uses of your Personal information, as well as any choices you may have regarding your personal information.
We may share your Personal Information with third parties to enable us to use your Personal Information as described above. We use Google Analytics to help up understand how you use the Website. You can read more about how Google uses your Personal Information at www.google.com/intl/en/policies/privacy. You can also opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
In our sole discretion, we may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
HOW LONG do we retain Personal Information?
We endeavour to only collect Personal Information that is reasonably necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary for such purposes. The length of time Personal Information is retained, and criteria for determining that time, are dependent on the nature of the Personal Information, the purpose for which it was provided and any statutory retention periods. This is subject to any valid opt-out or withdrawal of consent where processing based on consent, or other valid exercise of your data subject rights.
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Although we use reasonable efforts to help protect your information, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through the Website.
We implement rigorous procedures for our employees regarding confidentiality, security and privacy, and we emphasis the importance of complying with them. Our security procedures are consistent with generally accepted commercial standards used to protect personal information. We ensure that those who have regular or permanent access to Personal Information, or that are involved in the processing of Personal Information are trained and informed of their rights and responsibilities when processing Personal Information.
We use third party services to host our Website called WP Engine which stores your Personal Information on secure and controlled environments administered by WP Engine. Personal Information is encrypted when it is collected via the Website. For more information about WP Engine’s privacy protection and data security practices, please visit https://wpengine.com/legal/privacy.
We ensure that those who have permanent or regular access to Personal Information, or that are involved in the processing of Personal Information are trained and informed of their rights and responsibilities when process Personal Information. We take security seriously and will ensure that there are adequate policies and practices in place with respect to your Personal Information.
Links to third party sites
There may be features on the Website which enable you to subscribe to newsletters and other information about us. You can opt out of receiving communications from us at any time by following the instructions provided in those communications or emailing us at email@example.com with the subject of “Unsubscribe”. You may also remove yourself from our email list by clicking on the unsubscribe link presented in all communications we send to our users.
Our Website is not directed at minors or intended to be used by minors. Do not send any information about yourself if you are under the age of majority in your jurisdiction. In addition, if we learn that a person under the age of majority in his or her jurisdiction has submitted information to us, we will attempt to delete this information. If you have reason to believe that we may have accidently received information from a person under the age of majority in her or her jurisdiction, please contact us immediately at firstname.lastname@example.org.
Depending on where you are located when you use or access the Website, your Personal Information may be transferred across international borders outside the country where you use or access the Website, including to countries outside the European Economic Area (“EAA”) that do not have laws providing specific protection for personal data or that have different legal rules on data protection. In such cases, we ensure that there is a legal basis for such transfer and that adequate protection for your Personal Information is provided as required by applicable law, for example, by using standard contractual clauses approved by the European Commission or other relevant authorities, by using certain service provides that are certified under the EU-US Privacy Shield, and by requiring the use of other appropriate technical and organizational information security measures. You may contact us at email@example.com to obtain additional information about the safeguards we take in connection with these transfers.
You have a right to know what Personal Information we hold about you, and to access it. This section describes the mechanisms for you to control certain uses and disclosures of your information.
Upon request, we will provide you with information about whether we hold any of your Personal Information. You have the right to access the Personal Information we have about you. You may correct, amend, or delete that information at any time by emailing firstname.lastname@example.org with a Personal Information Request. We will respond to your access request within a reasonable time period. We may require additional information from you to allow us to confirm your identity. There may be circumstances in which we may not be able to accommodate your request to change information if we believe that the change would violate any law or legal requirement or cause the information to be incorrect. Please note deleting the Personal Information we hold about you may result in you not being able to access or use the Website. All requests for the removal of Personal Information shall be responded to within a reasonable period of time.
In the event you have provided Personal Information to subscribe for newsletters and other information about us, you are free to opt-out of receiving such information at any time. To opt out of receiving communications from us please email us at email@example.com with the subject of “Unsubscribe”. You may also remove yourself from our email list by clicking on the unsubscribe link presented in all communications we send to our users.
Your browser software can be set to reject all cookies, but if you reject our cookies, certain functions and conveniences of the Website may not work properly. To learn more about cookies, please check your browser’s help or similar feature or visit www.allaboutcookies.org. Some web browsers incorporate a “do-not-track” or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his or her online activity tracked. Please check your browser’s help or similar feature for more information about this process.
If you are an individual from the EEA, and access or use the Website from the EEA, we process your Personal Information both as a Processor and as Controller, as such terms are used in the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”). Our legal basis for collecting and using the Personal information will depend on the Personal Information concerned and the specific context in which we collect it. We process your Personal Information as a processor and controller when your access or use the Website and submit Personal Information to us. Our legal basis for acting as a controller and processor is further described above under the “Legal Basis for Use” section.
If you are an individual from the EEA, and access or use the Website from the EEA, you have certain additional rights provided by the GDPR as follows:
- Right to be informed of how your Personal Information is used – you have a right to be informed about how we will use and share your Personal Information. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and pain language.
- Right to access Personal Information – you have a right to obtain confirmation of whether we are processing your Personal Information, access your Personal Information and information regarding how your Personal Information is being used by us.
- Right to have inaccurate Personal Information rectified – you have a right to have any inaccurate or incomplete Personal Information rectified. If we have disclosed the relevant Personal Information to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible.
- Right to have the Personal Information erased in certain circumstances -you have a right to request that certain Personal Information held by us is erased. This is also known as a right to be forgotten. This is not a blanket right to require all Personal Information to be deleted. We will consider each request carefully in accordance with the requirements of any laws relating to the processing of your Personal Information.
- Right to restrict processing of Personal Information in certain circumstances – you have a right to block the processing of your Personal Information in certain circumstances. This right arises if you are disputing the accuracy of the Personal Information, if you have raised an objection to processing, if processing of the Personal Information is unlawful and you oppose erasure and request restriction instead or if the Personal Information is no longer required by us but you require the Personal Information to be retained to establish, exercise or defend a legal claim.
- Right to data portability – in certain circumstances you can request to receive a copy of you Personal Information in a commonly used electronic format. This right only applies to Personal Information that you have provided to us (such as Identity Information, Contact Information). The right to data portability only applied if the processing is based on your consent or if the Personal Information must be processed for the performance of a contract and the processing is carried out by automated means.
- Right not be to subject to automated decisions – you have the right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.
- Right to object to processing of Personal Information – you have a right to object to the processing being carried out by us if we are processing Personal Information based on a legitimate interest or if we are using Person Information for direct marketing purposes or if the information is being processed for scientific or historical or other statistical purposes. You will be informed that you have the right to object at the point of data collection and the right will be brought explicitly to your attention.
You may exercise any of your rights referred to above by contacting the Privacy Officer at firstname.lastname@example.org. We may require additional information from you to allow us to confirm your identity.
We will investigate all complaints and attempt to resolve those that we find justified. If necessary, we will amend our policies and procedures to ensure that other individuals do not experience the same problem.