Privacy Policy

What is personal information?

“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Information may include the following: name, address, date of birth, gender and contact data (i.e. e-mail address, telephone number and employer name).

We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information.

Scope of this Privacy Policy

This Privacy Policy applies to Personal Information and other information collected by SSCI or its service providers from or about:

• Visitors to, or users of, its websites
• Prospective and current customers using SSCI services
• Service providers and business partners
• Prospective and current employees

Personal information collected by SSCI

Prior to collecting your Personal Information, SSCI will obtain your consent. At any point in time, you can revoke your consent and we will cease using and processing your Personal Information immediately.

1. Information Provided to SSCI for by SSCI Customers for Services

SSCI collects Personal Information about you, a customer of SSCI, in connection with our services according to what is provided by customers using our services and in order for us to provide these services to you. SSCI processes the Personal Information transferred by customers strictly in accordance with the respective agreement between us and the applicable customer and pursuant to the instructions of the customer.

2. Information Provided to SSCI for Employment Reasons

SSCI collects and processes Personal Information obtained directly from current or prospective employees for the purposes of human resource management including hiring, deployment, compensation, benefits, leave management, performance management, discipline and termination, as well as emergency contact. SSCI collects Personal Information as required by taxation law and as necessary to manage the workforce and contact employees.

3. Information Collected Automatically by SSCI

SSCI may collect Technical Information about you when you visit our website, which your web browser automatically sends whenever you visit a website on the Internet. Our servers automatically record this information, which may include your Internet Protocol (“IP”) address, browser type, browser language, and the date and time of your request. Gathering your information helps us ensure our websites and other services work correctly and support out customer analytic efforts.

In order to obtain access to portions of the SSCI website, SSCI may ask you to complete a registration form that identifies Personal Information or solicits comments. Upon registration, email and other Personal Information is collected to allow the interface with the user. This is done with express consent of the user, prompted by a request to agree.

Email communication: We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.

Cookies and Similar Technologies: We may collect information about your use of our websites through cookies and similar technology including, but not limited to, mouse tracking, user activity and screen recording. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites. For example, we may use these technologies to collect information about the ways visitors use our websites, to support the features and functionality of our websites, and to personalize your experience when you use our websites.

Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our websites.

4. Information Collected from Social Media Applications

Our website includes social media features. These features may collect your IP address and which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the organization providing it. For example, if you create or log into your account through a third-party social networking site, we may have access to certain information from that site, such as your name, account information and friends, in accordance with the authorization procedures determined by such third-party social networking site.

5. Information Collected from Other Sources

SSCI may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our services to you, and prevent or detect fraud. In order to provide services to you and improve SSCI’ website, we may engage the services of third-party vendors. In the process of supplying services to SSCI, these third-party vendors may need to collect Personal Information about you.

Permitted use of personal information

SSCI uses your Personal Information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your Personal Information to support our business functions, such as fraud prevention, marketing, and legal functions. To do this, we combine personal and non-Personal Information, collected online and offline, including information from third party sources.

Disclosure of personal information

SSCI does not sell or otherwise disclose the Personal Information it holds to third parties, except with the following entities or under the following circumstances:

• government and regulatory authorities, for example to respond to a legal request or comply with a legal obligation, in which case we will make reasonable efforts to give you notice of the disclosure, provided we are able to identify you and are lawfully able to do so;
• for the purposes of seeking legal or other professional advice;
• third party service providers engaged by SSCI; and,
• in a prospective business transaction subject to entering into an agreement that restricts disclosure for the purpose of the transaction.

Safeguarding of personal information

SSCI uses technical safeguards such as encryption, physical safeguards such as secure areas, and organizational measures such as access controls and due diligence to protect the security of your Personal Information from unauthorized disclosure. Data held on behalf of SSCI’ customers is secure and available only to registered users in the customer’s organization.

We also make all attempts to ensure that only necessary people and third parties have access to Personal Information. We require that our third party service providers and channel partners agree to keep all confidential information we share with them and to use the information only to perform their obligations in the agreements we have in place with them.

Data retention and storage

All Personal Information is retained only for as long as it is necessary for the purposes for which it was collected or transferred. SSCI retains your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. SSCI will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time.

GDPR Compliance

SSCI will process (collect, store and use) the information you provide us in a manner compliant with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. SSCI is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

The operational data we collect as it relates to our software and services is stored in order to: 1) to fulfil our contractual obligations to our customers and/or 2) is necessary for the use of services. Namely, we collect the data necessary to be able to provision the user account to be operational, and to ensure compliance within the terms of our licensing and contracts. We retain data as long as required, either by our contractual obligations to our customers, or by regulation. SSCI makes use of encryption to protect the transmission and storage of data. Access to data within SSCI is strictly controlled and limited to those that need access to perform their duties. SSCI does not share this data with any party that is not part of the contractual obligation.

We do store data on servers outside of the EU with countries recognized by the EU under Article 45 of Regulation (EU) 2016/679 as providing adequate data protection.

Your rights

You have rights pursuant to this Privacy Policy and the collection and use of your Personal Information by SSCI. If you would like to obtain further information or request deletion, access, or transfer of your data, contact SSCI’s Data Protection Officer at info@softwaresecured.com.

Last updated: November 27, 2018