Effective Date: 05/25/2018
Last Updated: 01/07/2019
This policy sets out what personal data we may collect, how we process and protect that data, the lawful grounds for that processing, and your related rights. Essentially, “personal data” means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly, from that information alone or in conjunction with other information.
In most cases, the lawful ground will be that the processing: (i) is necessary for our legitimate interests in carrying out our business, including to maintain, improve and market our products and services, provided those interests are not outweighed by your rights and interests (“Legitimate Interests”), (ii) is necessary to perform a contract with you (“Contract”), or (iii) is necessary to comply with our legal obligations (“Legal Obligation”). Where processing is based on your consent (“Consent”), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.
- Information Collection and Use
We collect or are provided Personal Data in the normal course of business, for example:
- you may provide us with your details during discussions about buying our products or services,
- when you visit the Website, we may collect information about your visit such as your IP address and the pages you’ve visited,
- you may provide us with your details when you ask about our Services (through the Website, by email or otherwise) and we may obtain legally-compliant lists of potential customers for our Services for our marketing purposes.
We may collect the following Personal Data from or about you:
- contact Information such as name, email address, mailing address, phone number
- information about your business role, such as job title and company name
- information about your interests in our services and products
We use this information for our legitimate business interests, including to:
- respond to enquiries and provide advice and support related to our Website and Services. Lawful basis: Legitimate Interests or Contract.
- analyze and improve the Website, the Services. For example, for technical or security purposes and to improve the customer experience. Lawful basis: Legitimate Interests, however, where for example applicable law requires your consent to use certain cookies, we will ask for your Consent having provided you with relevant information.
- market our Services – if we do so, we will provide you with an easy and free way to opt-out of receiving such communications in the future. Lawful basis: Legitimate Interests (or Consent as above).
- administer and manage delivery of our services and products to you. Lawful basis: Legitimate Interests (or Consent as above).
- in certain circumstances, to share it with a limited number of third-parties as described in this policy, for example for operational requirements and business continuity purposes. Lawful basis: Most processing will be based on Legitimate Interests. Some processing is based on Contract and, where necessary (as above), some processing may be based on your prior Consent.
When you provide us with personal data about yourself or another person, you are confirming to us that you are authorized to provide us with that information and that any personal data you give us is accurate and up-to-date.
Given the nature of our business, we do not ask for “sensitive” or “special categories of personal data,” such as information about your health, political opinions, racial origins or sexual life and we would ask you not to send any to us.
- Information Sharing
- For provision of the Services, and for our own disaster recovery and business continuity purposes, we may store or transmit personal data to or through third party providers, such as with our contractors and advisors to help us operate, secure and analyze our business. Lawful basis: Legitimate Interests or Contract.
- We may be obliged to disclose your personal data to comply with a law, order or request of a court, government authority, other competent legal or regulatory authority or any applicable code of practice or guideline. We may also be obliged to disclose personal data when we believe in good faith that disclosure is necessary for our legitimate interest such as investigating fraud, to make or defend a legal claim, to protect your safety or the safety of others, or to maintain our compliance or that of our personnel with applicable laws, regulations and/or professional obligations, all in accordance with applicable law. Lawful basis: Legal Obligation.
- If Cordium is involved in a merger, acquisition, or sale of all or a portion of its assets, we may disclose such Personal Data as is necessary for our legitimate interests in completing that transaction and always provided that appropriate safeguards are in place including limitations and restrictions on use, access and retention. Lawful basis: Legitimate Interests.
- In other situations, only with your prior consent. Lawful basis: Legitimate Interest and Consent.
Cordium may be held liable for unlawful transfer of personal data to third parties.
- Transfers outside the EEA
- Participation in the EU-U.S. and Swiss-U.S. Privacy Shield Programs
Cordium complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Cordium has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
Organizations that participate in the U.S.-E.U. and Swiss-U.S. Privacy Shield Programs must comply with the seven Privacy Shield Principles, which require the following:
A. Note. Organizations must publish online privacy notices containing specific information about their participation in the Privacy Shield (including, where applicable, the entities or subsidiaries of the organization also adhering to the Principles); their practices around collecting, using and sharing personal data with third parties; their privacy practices, including an individual’s rights to access and correct data, and the choices they make available to individuals regarding limiting data collection and use. The thirteen specific items to be addressed in the notice also include (i) any relevant establishment in the EU and Switzerland, respectively, that can respond to inquiries or complaints, (ii) the independent dispute resolution mechanism designated to address complaints, a hyperlink to the complaint submission form of that dispute resolution body, (iii) the possibility, under certain circumstances, for EU and Swiss individuals to invoke additional binding arbitration; (iv) the possibility that the organization may be held liable for unlawful transfer of personal data to third parties; and (v) the organization’s obligation to disclose personal data in response to national security or law enforcement requests.
B. Choice. Participants must provide a mechanism for individuals to opt out of having personal information disclosed to a third party or used for a materially different purpose than that for which it was provided. Opt-in consent is required with respect to the sharing of sensitive information with a third party or its use for a new purpose.
C. Accountability for Onward Transfer.
a. To transfer personal information to a third party acting as a data controller, a participant must comply with the Notice and Choice Privacy Shield Principles. It must also enter into a contract with the third party controller limiting the purposes for which the data may be processed and ensuring that the recipient will provide the same level of protection as the Principles.
b. To transfer personal data to a third party acting as an agent (such as a service provider), an organization has additional obligations. It must: transfer the data for limited and specified purposes; ascertain that the agent is obligated to provide at least the same level of privacy protection as required by the Principles; take reasonable steps to ensure that the agent effectively processes this data in a manner consistent with Principles; upon notice, take reasonable steps to stop and remediate unauthorized processing; and upon request, provide a summary or copy of privacy provisions of its contract with the agent to the Department of Commerce.
D. Security. An organization creating, maintaining, using or disseminating personal data must take reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into “due account” the risks involved in the processing and the nature of the personal data.
E. Data Integrity and Purpose Limitation. An organization must take reasonable steps to limit processing to the purposes for which it was collected, and to ensure that personal data is reliable for its intended use, accurate, complete, and current. It must only retain personal information for as long as needed for the purpose of collection. An organization must adhere to the Privacy Shield Principles for as long as it retains such information.
F. Access. An organization must provide a mechanism by which data subjects may request access to personal information the organization holds about them and enable them to correct, amend, or delete information that is either inaccurate or processed in violation of the Principles.
G. Recourse, Enforcement and Liability. This Principle addresses three topics: recourse for individuals affected by non-compliance; consequences to organizations for non-compliance, and compliance verification.
- Your Rights
You have the right to ask whether Cordium processes your Personal Data and to request a copy, to access your data, to object to direct marketing and in certain circumstances to have the data rectified or blocked or withdrawn. To request this information, please email email@example.com. If your personal information changes, or if you no longer desire our services, you may ask to have your Personal Data corrected, amended, removed or deleted by emailing firstname.lastname@example.org. You have the right to ask us to restrict processing certain of your personal data, to erase your personal data, and to ‘port’ certain of your personal data to you or another provider, provided in each case that we have such data and certain conditions are met. You also have the right to object to direct marketing and, under certain circumstances, to object to our processing of your Personal Data. We will respond to your request within 30 days.
If you subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in such emails or by contacting us at email@example.com.
- Tracking Technologies / Cookies
Analytics / Log Files
As is true of most web sites, we gather certain information automatically. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and clickstream data to analyze trends in the aggregate and administer the site. You are not identifiable from any of this data.
Social Media Widgets
The security of your Personal Data is important to us. We follow industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your Personal Data, you can contact firstname.lastname@example.org.
We will retain your information for the longer of the period we are required to do so by law, as is reasonably necessary for the purpose (for example to comply with our legal obligations, resolve disputes, and enforce our agreements), or as needed to provide you services. If you opt-out of communications, we will retain your name and contact details to enable us to respect your request.
- Additional Information
Links to 3rd Party Sites
With consent from the individual, we display personal testimonials of satisfied customers on our website in addition to other endorsements, including their name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
Changes To This Policy
- “Do-Not-Track” / California Privacy Notice
The Web Sites do not respond to “Do-Not-Track” signals communicated by your internet browser.
If you’ve any question you can always contact us by email at firstname.lastname@example.org. You have the right, at all times, to notify a complaint to any regulator such as the UK Information Commissioner, although we would welcome the opportunity to discuss and resolve any complaint with you first.
- Enforcement and Dispute Resolution
Cordium has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism operated by TRUSTe. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://feedback-form.truste.com/watchdog/request for more information and to file a complaint.
Cordium is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. There is the possibility, under certain circumstances, for EU and Swiss individuals to invoke additional binding arbitration.
Cordium retains sole and absolute discretion in resolving all questions relating to the administration, interpretation and application of this Policy. This authority includes construing the terms of this Policy, including any disputed or doubtful terms.
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