(GCC PP Rev. 15-FEB-20)
WHAT INFORMATION WE COLLECT
We may ask You to register and provide information when You register as a visitor to the Gateway Checker Site, purchase Services or place orders, register to access an online demonstration or respond to a marketing campaign. We may also receive Your information if You participate in a focus group, contest, activity or event, apply for a job, request support, interact with Our social media accounts or otherwise communicate with Us. We may collect and receive use Your Data and other information and data in a variety of ways through user Data.
We also collect, generate and/or receive information, as follows:
1. Account Information. To create or update a Service or user account, You shall supply Us with an email address, phone number, password, domain and/or similar details.
2. Usage Information.
(a). Services Metadata. When an Authorized User interacts with the Services, metadata may be generated that provides additional context about the way Authorized Users work.
(b). Log Data. As with most websites and technology services delivered over the Internet, Our servers automatically collect information when You access or use the Gateway Checker Site or some of Our Services and record it in log files. This log data may include the Internet Protocol (“IP”) address, the address of the web page visited before using the Gateway Checker Site or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
(c). Device Information. We collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether We collect some or all of this Other Information often depends on the type of device used and its settings and the Services being used.
(d). Location Information. We receive information from You, Your user and other third parties that helps Us approximate Your location. We may, for example, use a business address submitted by Your employer, or an IP address received from Your browser or device to determine approximate location. We may also collect location information from devices in accordance with the consent process provided by Your device.
3. Cookie Information.
4. Third Party Services.
Users can choose to permit or restrict third-party services for their Services. Typically, third-party Services are software that integrate with Our Services, and You can permit its Authorized Users to enable and disable these integrations for their accounts. Once enabled, the provider of a third-party service may share certain information with Us. Authorized Users should check the privacy settings and notices in these third -party services to understand what data may be disclosed to Us. When a third-Party Service is enabled, We are authorized to connect and access other information made available to Us in accordance with Our agreement with the third-party Provider. We do not, however, receive or store passwords for any of these third-party services when connecting them to the Services.
5. Third-Party Data.
We may receive data about organizations, industries, the Gateway Checker Site visitors, marketing campaigns and other matters related to Our business from parent corporation(s), affiliates and subsidiaries, Our partners or others that We use to make Our own information better or more useful. This data may be combined with Other Information We collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries (e.g. how well an online marketing or email campaign performed, etc.).
6. Additional Information Provided to Us.
We receive Other Information when submitted to the Gateway Checker Site or if You participate in a focus group, contest, activity or event, apply for a job, request support, interact with Our social media accounts or otherwise communicate with Us. Generally, no one is under a statutory or contractual obligation to provide any user Data or Other Information (collectively, Information). However, certain Information is collected automatically and, if some Information, such as account setup details, is not provided, We may be unable to provide the Services.
HOW WE USE THE COLLECTED INFORMATION
User Data will be used by Us in accordance with user’s instructions, including any applicable terms in the user Agreement and user’s use of Services functionality, and as required by applicable law. We are a processor of user Data and user is the controller. User may, for example, use the Services to grant and remove access to an account, assign roles and configure settings, access, modify, export, share and remove user Data and otherwise apply its policies to the Services. We use Other Information in furtherance of Our legitimate interests in operating Our Services, the Gateway Checker Site and business. More specifically, We use Other Information:
1. To provide, update, maintain and protect Our Services, the Gateway Checker Site and busines This includes use of Other Information to support delivery of the Services under a user Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
2. As required by applicable law, legal process or regulation.
3. To communicate with You by responding to Your requests, comments and questions. If You contact Us, We may use Your Other Information to respond.
4. To develop and provide search, learning and productivity tools and additional features.
5. To send emails and other communication We may send You service, technical and other administrative emails, messages and other types of communications. We may also contact You to inform You about changes in Our Services, Our Services offerings, and important Services-related notices, such as security notices. These communications are considered part of the Services and You may not opt out of them. In addition, We sometimes send emails about new product features, promotional communications or other news about Our company. These are marketing messages, so You can control whether You receive them.
6. For billing, account management and other administrative matte We may need to contact You for invoicing, account management and similar reasons and We use account data to administer accounts and keep track of billing and payments.
7. To investigate and help prevent security issues and abuse.
WHO WE SHARE DATA WITH
We may share the information You provide with Our business partners acting on Our behalf for the uses described above. We do not sell Your information to third parties.
HOW WE OFFER OUR CUSTOMERS A CHOICE
If You do not want Us to contact You or Your company for marketing purposes by email, postal mail, fax or phone, You may opt out by contacting Our customer service department or by sending an email or writing to Us at the below address. Please note that We do not allow Our Customers to opt out of contact that is required for the functionality of Our Services or to maintain user accounts.
SECURITY OF YOUR INFORMATION
We use state-of-the-art security technology to protect Our user Data, and access to user information is restricted to authorized personnel only. We are very sensitive to the privacy concerns of Our Customers and visitors to the Gateway Checker Site.
CHILDREN, YOUNG ADULTS, AND PRIVACY
We do not knowingly target or solicit personal information from children under the age of 18 or send them requests for personal information.
The Gateway Checker Site may contain links to websites operated by third parties. We do not share Your personal information with those websites and We are not responsible for their privacy practices. Once You have left Our site, You should check the applicable privacy statement of the third-party website to determine how they handle information they collect from You. Please view the privacy policies of those companies by visiting their respective websites.
1. Cookie Tracking Technology.
2. The Information You Provide.
You may provide information to Us including, but not limited to, Your name, e-mail address, and credentials. Submitting this information to Us is voluntary, and You will still have access to the Gateway Checker Site without providing the information, except when needed to provide the information to access certain pages, resources, user groups, services or features.
3. Automated Information Collected.
The Gateway Checker Site may automatically collect information about You during Your visit. Cookies can be accepted or declined in Your browsers setting. Examples of information We may collect include browser type, operating system, pages You view, links You click on, and Your IP address.
4. How do We Use This Information.
We use information collected to provide You with information about products and services We oﬀer, increase Your user experience, and collect data to produce and provide You with information relating to Your activity on the Gateway Checker Site.
ADDITIONAL THIRD-PARTY COOKIES
We may provide links to third-party websites or content. We have no control over Cookies, external or third- party websites set when You interact with the link or their website.
We may utilize web beacons, images or scripts to collect data about Your visit and user behavior with Gateway Checker Site. Information collected from any of these include Your Cookies, time information of Your site visit and a description provided about Your visit.
We may collect Your IP address, operating system and browser information to track non-personal information including Your user-behavior on the Gateway Checker Site navigation ﬂow. Information collected is used for marketing purposes and to help manage the Gateway Checker Site by providing relevant content.
Other third-party tracking may be used on the Gateway Checker Site. We do not provide personal information to third parties.
To delete and block Cookies please see the settings on Your browser which allow You to set Your preferences and/or settings.
INTERNATIONAL DATA TRANSFERS
We may transfer Your Personal Data to countries other than the one in which You live. We deploy the following safeguards if We transfer Personal Data originating from the European Union to other countries not deemed adequate under applicable data protection law.
GENERAL DATA PROTECTION REGULATION (EU) 2016/679
Where and only to the extent that We process Your Data, on Your behalf, under the requirements of the EU’s General Data Protection Regulation (EU) 2016/679 (“GDPR”), We and You hereby agree to comply with the following provisions with respect to any Personal Data, defined below, which is subject to the GDPR’s requirements, each acting reasonably and in good faith.
1. GDPR Specific Definitions.
“Data Subject” means the identified or identifiable person to whom Personal Data relates.
“Data Subject Request” means a request from a Data Subject to exercise the Data Subject’s rights under the GDPR including the right of access, right to rectification, restriction of Processing, erasure (“right to be forgotten”), data portability, object to Processing, or its right not to be subject to automated individual decision making.
“Personal Data” means any information relating to (i) an identified or identifiable natural person and, (ii) an identified or identifiable legal entity (where such information is protected similarly as personal data or personally identifiable information under the GDPR), where for each (i) or (ii), such data is Your Data.
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Sub-processor” means any Processor that may be engaged by Us.
“Supervisory Authority” means an independent public authority, which is established by an EU Member State pursuant to the GDPR.
2. Processing of Personal Data.
(a) Roles of the Parties. The Parties acknowledge and agree that where Your use of the Services includes processing, which is subject to GDPR requirements with regard to the Processing of Personal Data, You are the Controller, We are the Processor, and may engage Sub-processors pursuant to the requirements set forth herein.
(b) Your Processing of Personal Data. Where Your use of the Services includes processing, which is subject to GDPR requirements, You shall Process Personal Data in accordance with the GDPR requirements directly applicable to Our provision of its Services. For clarity, Your instructions for the Processing of Personal Data shall comply with GDPR. You shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which You acquired Personal Data.
(c) Our Processing of Personal Data. We shall treat Personal Data as Confidential Information and shall only Process Personal Data on behalf of and in accordance with Your written instructions, which shall include email from You, for the following purposes: (i) Processing in accordance with applicable Order Form(s) and related documents; (ii) Processing initiated by Users in their use of the Services; and (iii) Processing to comply with other documented reasonable instructions provided by You (e.g., via email) where such instructions are consistent with the terms contained herein.
(d) Data Protection Impact Assessment. Upon Your request, We shall provide You with reasonable cooperation and assistance needed to fulfil Your obligation under GDPR to carry out a data protection impact assessment related to Your use of the Services, to the extent You do not otherwise have access to the relevant information, and to the extent such information is available to Us. We shall provide reasonable assistance to You in the cooperation or prior consultation with the Supervisory Authority in the performance of its tasks herein or to the extent required under the GDPR.
3. Rights of Data Subjects.
Taking into account the nature of the Processing, We shall use commercially reasonable efforts to assist You by appropriate technical and organizational measures, insofar as this is possible, to fulfil Your obligation to respond to a Data Subject Request under the GDPR. In addition, to the extent You, in Your use of the Services, do not have the ability to address a Data Subject Request, We shall upon Your request use commercially reasonable efforts to assist You in responding to such Data Subject Request, to the extent We are legally permitted to do so and the response to such Data Subject Request is required under the GDPR. You shall be responsible for responding to all Data Subject Requests and for any and all costs, at Our then-current commercial rate, arising from Our provision of such assistance.
4. Our Personnel.
We shall ensure that our personnel engaged in the Processing of Personal Data are informed of the confidential nature of the Personal Data, have received appropriate training on their responsibilities and have executed written confidentiality agreements. We shall ensure that such confidentiality obligations survive the termination of the personnel engagement. We shall take commercially reasonable steps to ensure the reliability of any of Our personnel engaged in the Processing of Personal Data. We shall ensure that Our access to Personal Data is limited to those personnel performing Services in accordance with the Agreement. We have appointed a data protection officer. The appointed person may be reached at firstname.lastname@example.org.
You acknowledge and agree that We may engage third-party Sub-processors in connection with the provision of the Services. We will enter into a written agreement with each Sub-processor containing data protection obligations not less protective than those in this Agreement with respect to the protection of Your Data to the extent applicable to the nature of the Services provided by such Sub-processor.
We shall maintain appropriate technical and organizational measures for protection of the security (including but not limited to protection against unauthorized or unlawful Processing and against accidental or unlawful
destruction, loss or alteration or damage, unauthorized disclosure of, or access to, Your Data), confidentiality and integrity of Your Data, in accordance with then-current industry best-practices. We shall use commercially reasonable efforts to monitor compliance with these measures, in accordance with then-current industry best-practices. We will not materially decrease the overall security of the Services during the Agreement term.
7. CLIENT DATA INCIDENT MANAGEMENT AND NOTIFICATION
We shall notify You without undue delay after becoming aware of the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Your Data, including Personal Data, transmitted, stored or otherwise Processed by Us or Our Sub-processors of which We become aware (a “Your Data Incident”). We shall make reasonable efforts to identify the cause of such a Your Data Incident and take those steps as We deem necessary and reasonable in order to remediate the cause of such a Your Data Incident to the extent the remediation is within Our reasonable control. The obligations herein shall not apply to incidents that are caused by You or Your Users.
8. Return and Deletion of Client Data.
Upon written request from You or upon termination of the Agreement, We shall return Your Data to You and, to the extent allowed by applicable law, delete Your Data. We reserve the right to charge a reasonable fee for the return of Your Data.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, You may have the right to request access to Information, as well as to seek to update, delete or correct this Information.
To the extent that Our processing of Your Personal Data is subject to the General Data Protection Regulation, We rely on Our legitimate interests, described above, to process Your data. We may also process Other Information that constitutes Your Personal Data for direct marketing purposes and You have a right to object to Our use of Your Personal Data for this purpose at any time.
QUESTIONS OR SUGGESTIONS