This privacy notice describes how we, Exiger LLC, and our associated offices from time to time (“Exiger,” “we,” “us,” “our”), process, maintain, use and share information about individuals (each a “User,” “you,” “your”) who use our website (www.exiger.com) and related features (collectively, the “Site”) or who we communicate or interact with.
This policy sets out:
1.Information we collect about you
2.Cookies and other technologies
3.How we use your information
4.Our promotional updates and communications
5.Who we give your information to
6.Where we store your information
7.How we protect your information
8.How long we keep your information
9.Links to Third Party Sites
11.Provision of Professional Services
13.Changes to this policy
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By engaging with our Site, you acknowledge you have read and understood this privacy notice.
For the purposes of the applicable data protection law, the Data Protection Officer is: Clewin McPherson,
Senior Vice President-Global Operations
+1 (212) 382-8199
1.INFORMATION WE COLLECT ABOUT YOU
We will collect and process the following personal data from you:
·Information you give us
·This is information about you that you give us directly when you interact with us. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our site, subscribe to our service, search for a product, submit a query, and when you report a problem with our site.
·The information you give us may include demographic information, such as your name, job title, company name, country, e-mail address and phone number.
·If you register for an event we organize, you may submit additional information including your interest in compliance topics and products.
·If you respond to an advertised job vacancy or make a general inquiry regarding employment opportunities with us, you may submit various employment details about yourself, including a CV, resumé or other details of your educational and employment history. For further information on recruitment, please review Exiger’s Recruitment Privacy Notice.
·Information we collect about you from your use of our site: We will automatically collect technical information from you each time you visit our site. This includes:
·The Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
·Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
·Information we receive from other sources. This is information we receive about you:
·If you use any of the other websites or apps we operate or the other services we provide.
·From third-parties we work closely with (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
2.COOKIES AND OTHER TECHNOLOGIES
A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the site and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.
Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that. Your help screen or manual will tell you how to do this. If you disable cookies to our site, however, you may not be able to take full advantage of our site.
3.HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
·Information you give to us:
We will use this information to:
•Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us.
•Provide you with information about our goods or services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications.
•Ensure in our legitimate interests that:
oContent from our site is presented in the most effective manner for you and for your computer.
oWe provide you with the information, products and services that you request from us.
·Information we collect about you from your use of our site
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
•To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
•To keep our site safe and secure.
•For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
•To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
•To allow you to participate in interactive features of our service, when you choose to do so.
·Information we receive from other sources
We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4.OUR PROMOTIONAL UPDATES AND COMMUNICATIONS
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email and social media platforms about our products/services.
You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email at email@example.com.
5.WHO WE GIVE YOUR INFORMATION TO
We may give your information to any member of our group:
•We may give your information to any of our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
We may also give your information to selected third parties:
•Organisations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes in supporting the services we offer through the site in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
•Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy.
•Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual).
•Business partners who jointly with us provide services to you and with whom we have entered into agreements in relation to the processing of your personal data.
We will disclose your personal information to third parties:
•In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy notice.
•If Exiger LLC or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
•If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Exiger LLC, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
6.WHERE WE STORE YOUR INFORMATION
We are headquartered in the United States of America with offices and servers in Canada, among other places. Therefore, we may transfer, process, and/or store your personal information in the United States and Canada. When we transfer personal information to any destination outside the European Union (EU) or the European Economic Area (EEA), we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this privacy notice.
The European Commission has recognized that Canada has data privacy laws providing an adequate level of protection, and the United States offers adequate protection only to the extent of the EU-US Privacy Shield Framework.
As discussed in Exiger’s Privacy Shield Policy, Exiger complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.
7.HOW WE PROTECT YOUR INFORMATION
Exiger will use appropriate technical and organizational security measures to try to protect your personal data from loss, misuse, alteration, or destruction. Please be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8.HOW LONG WE KEEP YOUR INFORMATION
Exiger will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with applicable local, state, federal, or country specific regulations and requirements.
We may also retain aggregate information without time limits for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
9.LINKS TO THIRD PARTY SITES
Protecting the safety of children when they use the Internet is important to Exiger. Our services and this Site are intended for use by adults, primarily in their business or professional capacities. Our services are not directed to children; we do not target or knowingly collect information from children under the age of 13.
11.PROVISION OF PROFESSIONAL SERVICES
Exiger will also often receive personal information in the course of providing professional services – ordinarily when we provide services to private individuals, employers, businesses with personal customers, and public-sector clients with constituents. Our engagement letter and terms of business govern our relationship with clients, including what we may do with personal data that is provided to us. Exiger provides many different types of services and its role may not always be visible to the individuals who are data subjects.
·We will honor your rights under applicable data protection laws. You may have the following rights under European laws, and may have similar rights under the laws of other countries.
•Right of subject access: You have the right to make a written request for details of your personal information and to be provided with a copy of your personal data held by us.
•Right to rectification: You have the right to have inaccurate information about you to be corrected or removed.
•Right to erasure: You have the right to have certain personal information about you erased. We will comply with your request unless there is an overriding legitimate ground for retaining the information.
•Right to restriction of processing: You have the right to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example).
•Right to object: You have the right to object to the further processing of your personal data, including the right to object to marketing (as mentioned in “Our promotional updates and communications” section).
•Right to data portability: You have the right to request that your provided personal data be transferred to you or to a third party in machine-readable format.
•Right to withdraw consent: Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent.
You can also exercise the rights listed above at any time by contacting our Data Protection Officer:
Senior Vice President-Global Operations
+1 (212) 382-8199
For data subjects located in the EU: if we are not able to satisfactorily resolve your questions, concerns, or complaints, or if you believe that the processing of your personal data infringes on your rights under applicable data protection laws, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. Contact information of the supervisory authorities may be found here: https://ec.europa.eu/justice/article-29/structure/data-protection-author...
For data subjects in the UK, the Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data. Contact information for the UK Information Commissioner can be found here: https://ico.org.uk/
13.CHANGES TO THIS POLICY
Exiger keeps this policy under regular review and may modify it from time to time at our discretion. Any changes we make will be posted on this page. This policy was last updated on April 19, 2019.
If you have questions, comments, or complaints about our handling or protection of your personal data or this privacy notice, you may send a message by email to firstname.lastname@example.org or may contact our Data Protection Officer:
Senior Vice President-Global Operations
+1 (212) 382-8199