- IMPORTANT INFORMATION AND WHO WE ARE
- THE INFORMATION WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL INFORMATION COLLECTED
- HOW WE USE YOUR PERSONAL INFORMATION
- DISCLOSURES OF YOUR PERSONAL INFORMATION
- INTERNATIONAL TRANSFERS
- INFORMATION SECURITY
- INFORMATION RETENTION
- YOUR INFORMATION ACCESS RIGHTS
Please note that this Website is not intended for children. No one under age 18 may provide any information to or on this Website. We do not knowingly collect personal information from children. If you are under 18, do not use or provide any information on this Website or on or through any of its features, use any of the interactive features of this Website or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at firstname.lastname@example.org.
Numecent Inc., 15635 Alton Parkway, Suite 100, Irvine, CA 92618, U.S.A.
EU Residents: you have the right to make a complaint at any time to your local supervisory authority for data protection issues. If you are based in the UK, the Information Commissioner’s Office (ICO) is your supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us at email@example.com in the first instance.
This version was last updated on March 22, 2019 and historic versions can be obtained by contacting us.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Please note that we also do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. If you are based in the United States you can opt-out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website at http://optout.networkadvertising.org. If you are based in the European Union you may visit the website of the European Interactive Digital Advertising Alliance (“EIDAA”) at https://www.edaa.eu as well as of the European Advertising Standards Alliance (“EASA”) at http://www.easa-alliance.org.
Public Forums, Blogs, Refer a Friend and Customer Testimonials
Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us by sending an email to our data privacy manager at firstname.lastname@example.org.
Numecent may, from time to time, send emails regarding our products and services to users who have posted to our discussion forums, blogs, user-editable documents, and commenting systems. Each participant’s opinion expressed is his or her own and should not be considered as reflecting the opinion of Numecent. Note also that your use of these online communication tools is subject to our Terms of Service, which contain disclaimers, limitations of liability and a choice of California law. Personal information given to Numecent may be transferred across state and country borders for data consolidation, storage, and simplified information management.
Social Media Features
Our Website includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Website. Your interactions with these Features are governed by the privacy policies of the companies providing them.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Technical Data includes internet protocol (IP) address, Media Access Control (MAC) numbers, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
If you fail to provide personal information
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our solutions and services). In this case, we may have to deny you access to solutions or services you have ordered from us but we will notify you if this is the case at the time.
We use different methods to collect information from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, chat or otherwise. This includes personal information you provide when you:
- register to download [one of] white papers or case studies;
- request a demo of our solutions;
- subscribe to our blog or our newsletter;
- request marketing to be sent to you;
- apply for one of our available positions; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs, and other similar technologies. Please see our cookie notice for further details.
- Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- Google based outside the EU;
- Twitter based outside of the EU;
- Linked In based outside of the EU; and
- search information providers.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal information.
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|Performance of a contract with you
|To process and perform a customized demo at your request
|Necessary for our legitimate interests (to show our customer how our technologies work)|
|Manage and answer your requests through our “Contact Us” form||(a) Identity
(c) Marketing and Communications
|Necessary for our legitimate interests (to allow users to contact us and to grow our business).
(d) Marketing and Communications
|Necessary to comply with a legal obligation
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)|
|To process your application for one of our available positions||(a) Identity
|Necessary in order to take steps at the request of the data subject prior to entering into a contract
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. We have established personal information control mechanisms.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal information with any company outside the Numecent group of companies for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, product/service experience or other transactions.
Do Not Track “DNT” Signals
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
EU residents: We share your personal information within the Numecent Group. This will involve transferring your information outside the European Economic Area (EEA).
Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will also involve a transfer of data outside the EEA.
Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Notice will be given promptly, consistent with the legitimate needs of law enforcement and any measures necessary for Numecent or law enforcement to determine the scope of the breach and to assure or restore the integrity of the data system. Numecent may delay notification if Numecent or a law enforcement agency determines that the notification will impede a criminal investigation, unless and until Numecent or the agency determines that notification will not compromise the investigation. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal information are available in our Retention Policy, which you can request from us by contacting us.
In some circumstances, you can ask us to delete your information: see [Request erasure] below for further information.
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please click on the links below to find out more about these rights:
- Request access to your personal information.
- Request correction of your personal information.
- Request erasure of your personal information.
- Object to processing of your personal information.
- Request restriction of processing your personal information.
- Request transfer of your personal information.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at email@example.com.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org.
Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in the Numecent Group acting as joint controllers or processors and who are based in the United States and provide IT, HR, Marketing, and system administration services and undertake leadership reporting.
External Third Partie
- Service providers acting as processors based in the United States who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United States who provide banking, legal, insurance and accounting services.
- Regulators and other authorities acting as processors or joint controllers based in the United States who require reporting of processing activities in certain circumstances.
YOUR INFORMATION ACCESS RIGHTS
You have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
This version was last updated on March 22, 2019